January 29, 2014 Community Development

Overview of the EPA Renovation, Repair and Painting Rule (RRP Rule) as it relates to the HUD Lead Safe Housing Rule and Renovations/Repairs EPA Renovation, Repair and Painting Rule (RRP Rule)

Authorization For a State to become authorized, it must be at least as protective as EPA CT is not authorized to administer or enforce RRP rule CT DPH Provides: Compliance assistance Education/outreach Awareness training

Who Must Follow the Lead Rule’s Requirements? Examples: Residential rental property owners Painters Home Improvement Contractors Renovators & Remodelers Carpenters School Administrators D aycare Owners/Operators Finishing Workers Property Managers Maintenance Staff Electricians and Plumbers Window Replacement Firms And Many Others……

What Activities Are Subject to the RRP Rule? Remodeling and repair/maintenance, electrical work, plumbing, carpentry, etc., (for payment) that disturbs: > 6 square feet of interior painted surfaces (per room) during projects on housing and child occupied facilities built pre-1978 > 20 square feet of painted exterior surfaces during projects on housing and child occupied facilities built pre-1978 Any window replacement (also pre-1978)

Exclusions Housing built after 1977 Certified lead free housing Lead abatement projects Full demolitions Housing for the elderly or disabled unless a child under 6 resides or is expected to reside there. Zero-bedroom dwellings (studio apts., dorms). Minor repair/maintenance Emergency renovations

HUD’s Lead Safe Housing Rule HUD’s Lead Safe Housing Rule (LSHR) is found in HUD’s regulations at 24 CFR Part 35, Subparts B through M Generally applies to work performed in target housing units receiving: HUD housing assistance Rehabilitation assistance Acquisition assistance Under LSHR, the program participant (person accepting funding) becomes responsible for compliance with federal laws

HUD’s Lead Safe Housing Rule Stages of the Job Planning and Set-up During the Job End of Job

HUD’s Lead Safe Housing Rule Planning and Set-up Renovators/renovation firms must be certified Renovators/renovation firms must complete curriculum in lead safe work practices RRP course is HUD-approved All workers and supervisors must complete a HUD approved lead safe work practice course Renovators must hand out “Protect Your Family from Lead in Your Home” brochure Renovators should hand out “Renovate Right” brochure

Protect Your Family brochure

EPA Renovate Right brochure

HUD’s Lead Safe Housing Rule During the Job HUD requires lead hazards be treated using interim controls or ongoing lead-based paint maintenance Prohibited practices EPA Prohibited Practices Open flame burning or torching Heat guns above 1100 degrees F (in CT 700 degrees F) Machine removal without HEPA vacuum attachment HUD Prohibited Practices Dry scraping or sanding farther than 1 foot of electrical outlet Volatile stripper in poorly ventilated space ** MUST FOLLOW ALL PROHIBITED PRACTICES **

HUD’s Lead Safe Housing Rule During the Job Threshold minimum amount of interior paint disturbance HUD has a lower “de minimus” than EPA HUD’s interior Threshold is 2 square feet per room 10% of small components HUD’s exterior Threshold is 20 square feet for total exterior 10% of small components

HUD’s Lead Safe Housing Rule End of Job HUD requires a clearance examination Must be done by independent party Clearance examination includes a Visual assessment at the end of the work for deteriorated paint, dust, debris, paint chips or other residue Clearance dust wipe tests of interior floors, window sills and window wells Independent party must a be a licensed lead inspector/risk assessor Licensed by the State of CT Department of Public Health

When is a DPH Licensed/Certified Professional Required? Sampling: Paint (XRF) Paint Chips Dust Soil Water

DPH Licensed Contractors/Consultants Lead Abatement Consultant Contractor Lead Abatement Contractor Lead Consultant Contractor Lead Inspector Lead Risk Assessor Lead Planner/Project Designer

How to Find a Lead Inspector/Risk Assessor

Paint Chip Sampling

Sample RRP Certificate

How to Find an RRP Certified Renovator

Checklist for Lead Safe Work Practices

When is Abatement Required?

When do the HUD/DPH Requirements Trigger Abatement? DPH Child under the age of 6 in residence Elevated Blood Lead Level (poisoned child) A licensed professional has tested and identified defective lead-based paint A code enforcement official has identified defective lead-based paint Additional dwellings in same unit with defective lead-based paint HUD Projects costing more than $25,000 When a contract specifies lead abatement

Sample DPH License

Checklist for Lead Abatement Projects

Question and Answer