EPA RRP Lead Paint Fines & Enforcement – Dec 2014

In December 2014 the EPA announced 61 enforcement actions for violations of the Lead Based Paint Renovation, Repair & Painting RRP Rules. All violations were involving pre-1978 homes and child occupied facilities. Fines were issued in Connecticut, New Hampshire, Virginia, New York, New Jersey, Maryland, Pennsylvania, Illinois, Michigan, Wisconsin, Minnesota, Indiana, Ohio, Oklahoma, Missouri, Nebraska, Florida, Colorado, California, Idaho and Oregon. Fines ranged from as little as $100 to as much as $184,000. Violations included failure to

  • Educate the property owners and residents using the Renovate Right Brochure
  • Obtain Firm Certification from the EPA or the respective state in the 14 authorized states
  • Assign a Certified Renovator to the job
  • Retain all records for 3 years
  • Contain the work area
  • Contain the waste
  • Cover the floor or ground with impermeable plastic
  • Post warning signs
  • Train all non-certified workers
  • Use a HEPA exhaust on paint removing power tools
  • Perform a Post-Renovation Cleaning Verification
  • Clean properly
  • Produce records upon request
  • Have copies of both Certified Renovator and Certified Firm on the job site
  • Close and cover duct openings
  • Close all doors and windows

Notice that not only record keeping, but also job-site inspections have been performed to determine these violations.

How to make sure you aren’t fined

Never forget the #1 priority – Contain the Dust & Paint Chips.

Remember from your class the 3 Main Principles:

  1. Minimize the Dust You Create
  2. Contain What You Can’t Prevent
  3. Clean-up Everything

If you do these three things, you will do the job safely and ensure compliance with the work practices. But you must also make sure you have your records including:

  1. Proof that you educated the occupants, residents and owners with the Renovate Right Brochure
  2. Your Test Kit Documentation for testing results or presuming the paint contains lead
  3. Your Post-Job Report documenting your notification, work-practices and proper clean-up procedures.
  4. Proof that you have trained all non-certified workers

Clients must be given copies of the Test form and the Post-Job Report no more than 30 days after completion of the job or with your final invoice.

Remember, you can get copies of the paperwork off of our home page at: www.leadclasses.com/forms-downloads

Lastly, you must take the Refresher Training Class BEFORE your current Certificate expires. We are just beginning to put them on the schedule now. If you cannot find your closest city on our home page at www.LeadClasses.com please send us an email at Info@LeadClasses.com and we’ll do everything we can to help.

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