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Are You Aware of the New EPA Lead Regulations?
by Ray Thompson, Jr.
July 14, 2010

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The EPA now requires contractors who perform renovation, repair and painting projects in buildings built before 1978 to be certified and trained to help prevent lead contamination.


Under new rules, the United States Environmental Protection Agency (EPA) requires contractors who perform renovation, repair and painting projects that disturb more than six sq. ft. of paint in homes, child care facilities, and schools built before 1978 to be certified and trained to follow specific work practices to prevent lead contamination. Implementation of the new rule was originally set for April 22, 2010 and has been delayed until October 1, 2010.

This new rule also requires renovation firms to be certified by the EPA, individuals to be trained in lead-safe work practices, and those providing training to be EPA accredited.

The EPA’s Renovation, Repair and Painting (RRP) program
The EPA issued a final rule under the authority of section 402/404 of the Toxic Substances Control Act (TSCA) to address lead-based paint hazards created by renovation, repairs and painting activities that disturb lead-based paint.

These new RRP rule requires firms working in pre-1978 homes and child occupied facilities to be certified in lead-safe work practices during renovations, including the installation of flooring materials. Each firm must be certified and must have a Certified Renovator on each job; any non-certified workers on the job must work under a Certified Renovator.

RRP Certified firms are not qualified to perform lead abatement. Their work is limited to disturbing lead in the materials they are working with. The EPA may revoke or modify a firm’s certification if the Certified Firm or Renovator is non-compliant, with civil penalties up to $32,500 for each violation.  Firms knowingly or willfully in violation of the regulation may be subject to an additional $32,500 per violation or imprisonment, or both.

Certified Renovators must:

Direct lead-safe work practices

Provide on-the-job training for non-certified workers

Keep copies of the initial and/or refresher training certificates on site

Be physically present while posting signs, containing work areas and cleaning work areas

Be available via telephone when off-site

Maintain the containment to keep dust and debris within the work area.

Implement the cleaning verification procedures

Prepare and maintain required records


Renovators working in Mississippi, North Carolina, Wisconsin, Iowa, Kansas, Rhode Island or Utah need to contact their states to learn more about applicable certification and training requirements. Those states have adopted their own Renovation, Repair and Painting (RRP) programs in lieu of EPA’s RRP program.

For more information visit the RRP program website at www.epa.gov/lead/pubs/renovation.htm. The EPA can also be reached at (800) 424-LEAD (5323).  


How to Become a Certified Renovator

To become a certified renovator, individuals are required to take eight hours of training, including two hours of hands-on training. The training is good for five years. The cost of the training is set by individual training providers, not by the EPA.

In addition, renovation firms must be certified by the EPA or by a state authorized by the EPA to administer its own program. Firm certification is obtained by sending in a two-page application to the EPA and paying a fee of $300. Certification is good for five years.

As of press time, the EPA has approved 212 training providers. Of these training providers, 114 are accredited to provide training in multiple states. A number of industry organizations, non-governmental organizations and private vendors are also accredited training providers.

The EPA continues to evaluate training provider applications; the EPA has been working with the Laborers’ International Union of North America (LiUNA) to accredit their local affiliates as RRP training providers.

To find a certified trainer near you, visit http://cfpub.epa.gov/flpp/searchrrp_training.htm.


nft-thompsonmug.jpg
Ray Thompson, Jr.
rthompson@cablespeed.com
A veteran of the flooring industry for more than 42 years and author of Focus on Resilient, Ray Thompson, Jr. is a renowned installation expert and president of the Ray Thompson Floorcovering Institute in Easton, Wash. Ray conducts resilient, hardwood and moisture in concrete training programs for installers, retailers, distributors and industry associations. He also serves as a consultant and operates his own inspection service. He most recently served as Armstrong World Industries' senior field technical specialist.

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