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EPA & State RRP Lead Paint Certification Training

07 Sep September 07, 2011

EPA Updates RRP Rules

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On July 15 the EPA updated the Renovation Repair & Painting (RRP) Rules. These new rules go into effect October 30, 2011.  There are several changes that general contractors, specialty contractors, rental owners, property managers, and maintenance personnel must understand.

  1. No Dust Wipe or Clearance Testing – Despite the proposal that renovation jobs will require independent Clearance Testing or Exams, the EPA has stated that the Cleaning Verification procedure will remain in place and were careful not to hold contractors responsible for the removal of pre-existing lead hazards.
  2. Paint Chip Sampling – The EPA is going to allow Certified Renovators to collect and submit paint chip samples for lab testing. All labs must be NNLAP Certified. There will be additional paperwork required including Chain of Custody forms and a revised Post Renovation Report.
  3. Vertical Containment – By far the most onerous and costly requirement, both in time and money, is the new requirement that Vertical Containment be used if the renovation is being done within 10 feet of the property line. The EPA estimates that only 2% of jobs will require vertical containment. The only upside to contractors is the amendment allowing less than 10 feet of ground containment when using vertical containment as long as dust and debris is contained.
  4. Increased Enforcement – The EPA is requiring states to be more aggressive in enforcement, fines and homeowner education programs. States will be required to have a minimum fine of $5000 per day, per violation.
  5. Shrouded Power Tools – Power sanding, grinding, planing, etc. on painted surfaces is not allowed unless the tools are shrouded and attached to a HEPA vacuum. If you have attended one of our classes, this is the method that we have been teaching since the very beginning.
  6. HEPA Vacuums – must be operated in accordance with the manufacturer’s instructions, including frequency of filter changes.

These new rules go into effect October 30, 2011 and are the final blow to any hopes that the Renovation, Repair & Painting (RRP) Rules will be scaled back or repealed entirely. The EPA has made it extremely clear that the RRP Rules are here to stay. Larger fines and more aggressive enforcement from both individual states and the EPA are rapidly becoming a reality. If you have not obtained your Certified Renovator Training or registered your company as a Certified Firm, it’s not too late. For current class schedules go to www.LeadClasses.com and select your nearest city.

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