Making Sense of the EPA RRP Rule
The United States Environment Protection Agency (EPA) issued a new Renovation, Repair and Painting (RRP) ruling on April 22, 2010 that requires all building contractors and landlords to obtain certification approval from EPA before they can carry out renovation or repairs on homes, schools or buildings built before 1978.
Purpose
The RRP rule was implemented to ensure lead-safe practices are employed by contractors and landlords when they carry out renovation, repair or painting work in pre-1978 properties. Through safe work practices, the ruling ensure that adults and children are protected from the hazard of lead-based paint which was used on houses or buildings built before 1978. Lead is a toxic metal that can cause harmful effects on the brain, kidney and nervous system. For children, it is particularly harmful in causing learning and behavioral problems. Unborn babies are also extremely vulnerable when mothers are exposed to lead prior to giving birth. Adults and children are at danger to lead poisoning when they are exposed to disturbed lead paint surfaces, contaminated dusts in a lead-based painted area or lead from one’s clothes, car and shoes.
Affected Parties
The RRP rule affect contractors specializing in home or building renovation, plumbers, electricians and painters who may carry out work on homes, schools, child care centers or buildings built before 1978. The ruling also affects landlords of pre-1978 homes or buildings who intend to renovate and repair their properties.
Under the ruling, homeowners or tenants who reside in pre-1978 homes or buildings have the right to request for an EPA-approved certification from any contractor appointed to perform renovation, repair or painting at their premises.
Application
The RRP rule dictates that any work performed in a pre-1978 house or building affecting more than six square feet of interior painted surface or more than 20 square feet of exterior painted surface can only be carried out by an EPA certified contractor.
The ruling does not apply to renovation, repair or painting work in post-1978 homes or buildings. However, contractors are advised to take due diligence to obtain documentation proof that a property is built after 1978 prior to any renovation work. The ruling also does not apply to homeowners who perform their own renovation where work is not profit based. Minor repairs that do not affect paint surfaces are also exempt from the ruling.
The Renovation, Repair and Painting rule contains work instructions and best practices in dealing with lead-based paint properties. Certain work practices that are prohibited include open flame burning and the use of machines for high-speed procedures such as sanding, grinding, needle gun or sandblasting, unless HEPA exhaust control is utilized.
Certification
Contractors and landlords must obtain a firm certification by submitting an application to EPA together with a fee payment. EPA starts processing applications on October 22, 2010 and takes up to 90 days to reach a decision on whether an approval is granted.
Effective April 22, 2010, a contractor who performs paintwork, renovation or repair on a pre-1978 buildings or homes is also required to attend an eight-hour training conducted by EPA’s accredited trainer or state administered training. States that have been authorized by EPA to administer their own training programs include Wisconsin, Iowa, North Carolina, Mississippi, Kansas, Rhode Island and Utah; training programs in states other than those mentioned above will be centrally administered by EPA. Those who have sat for EPA’s previous eligible training courses can be allowed to take a four-hour refresher course instead.