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The EPA?s Lead Renovation, Repair and Painting Rule
EPA Requirements
Common renovation activities like sanding,
cutting, and demolition can create hazardous lead dust and chips by
disturbing lead-based paint, which can be harmful to adults and children.
To protect against this risk, on April
22, 2008, EPA issued a rule
requiring the use of lead-safe practices
and other actions aimed at preventing lead poisoning. Under the rule,
beginning in April 2010, contractors performing renovation, repair and
painting projects that disturb lead-based paint in homes, child care
facilities, and schools built before 1978 must be certified and must
follow specific work practices to prevent lead contamination.
Until that time, EPA recommends that
anyone performing renovation, repair, and painting projects that disturb
lead-based paint in pre-1978 homes, child care facilities and schools
follow lead-safe work practices.
All contractors should follow these three
simple procedures:
- Contain the work area.
- Minimize dust.
- Clean up thoroughly.
Beginning in December 2008, the rule
will require that contractors performing renovation, repair and painting
projects that disturb lead-based paint provide to owners and occupants
of child care facilities and to parents and guardians of children under
age six that attend child care facilities built prior to 1978 the lead
hazard information pamphlet Renovate Right: Important Lead Hazard
Information for Families, Child Care Providers, and Schools.
The rule will affect paid renovators
who work in pre-1978 housing and child-occupied facilities, including:
- Renovation contractors
- Maintenance workers in multi-family housing
- Painters and other specialty trades.
Under the rule, child-occupied facilities
are defined as residential, public or commercial buildings where children
under age six are present on a regular basis. The requirements apply
to renovation, repair or painting activities. The rule does not apply
to minor maintenance or repair activities where less than six square
feet of lead-based paint is disturbed in a room or where less then 20
square feet of lead-based paint is disturbed on the exterior. Window
replacement is not minor maintenance or repair.
Information for Contractors
As a contractor, you play an important
role in helping to prevent lead exposure. Ordinary renovation and maintenance
activities can create dust that contains lead. By following the lead-safe
work practices, you can prevent lead hazards. All contractors should
follow these three simple procedures:
- Contain the work area.
- Minimize dust.
- Clean up thoroughly.
Beginning in December 2008, the rule
will require that contractors performing renovation, repair and painting
projects that disturb lead-based paint provide to owners and occupants
of child care facilities and to parents and guardians of children under
age six that attend child care facilities built prior to 1978 the lead
hazard information pamphlet Renovate Right: Important Lead Hazard
Information for Families, Child Care Providers, and Schools.
Under the rule, child-occupied facilities
are defined as residential, public or commercial buildings where children
under age six are present on a regular basis. The requirements apply
to renovation, repair or painting activities. The rule does not apply
to minor maintenance or repair activities where less than six square
feet of lead-based paint is disturbed in a room or where less then 20
square feet of lead-based paint is disturbed on the exterior. Window
replacement is not minor maintenance or repair.
Contractors who perform renovation, repairs,
and painting jobs in pre-1978 housing and child-occupied facilities
must, before beginning work, provide owners, tenants, and child-care
facilities with a copy of EPA's lead hazard information pamphlet
Renovate Right: Important Lead Hazard Information for Families, Child
Care Providers, and Schools. Contractors must document compliance
with this requirement. EPA?s Pre-renovation
Disclosure Form may be used
for this purpose.
Understand that after April 22, 2010,
federal law will require you to be certified and to use lead-safe work
practices. To become certified, renovation contractors must submit an
application and fee payment to EPA.
EPA will begin processing applications
on October 22, 2009. The Agency has up to 90 days after receiving a
complete request for certification to approve or disapprove the application.
Contractors who perform renovation, repairs,
and painting jobs should also:
- Take training to learn how to perform lead-safe work practices. A list
of training providers that have
been accredited by EPA to provide training for renovators under EPA's
Renovation, Repair, and Painting is available on the EPA?s website
(epa.gov/lead).
- Please note that if you previously
completed an eligible renovation training course you may take the 4-hour
refresher course instead of the 8-hour initial course from an accredited
training provider to become a certified renovator.
- Provide a copy of your EPA
or state lead training certificate to your client.
- Tell your client what lead-safe
methods you will use to perform the job.
- Learn the lead laws that apply
to you regarding certification and lead-safe work practices beginning
in April 2010.
- Ask your client to share the
results of any previously conducted lead tests.
- Provide your client with references
from at least three recent jobs involving homes built before 1978.
- Keep records to demonstrate
that you and your workers have been trained in lead-safe work practices
and that you followed lead-safe work practices on the job. To make recordkeeping
easier, you may use the sample
recordkeeping checklist that
EPA has developed to help contractors comply with the renovation recordkeeping
requirements that will take effect in April 2010.
Read about how to comply with EPA's rule
in the EPA Small
Entity Compliance Guide to Renovate Right.
Read about how to use lead-safe work
practices in EPA's Steps
to Lead Safe Renovation, Repair and Painting.
Information for Property Owners of
Rental Housing and Child-Occupied Facilities
Property owners who renovate, repair,
or prepare surfaces for painting in pre-1978 rental housing or space
rented by child-care facilities must, before beginning work, provide
tenants with a copy of EPA's lead hazard information pamphlet Renovate
Right: Important Lead Hazard Information for Families, Child Care Providers,
and Schools.
Contact the EPA for pamphlets. http://www.epa.gov/lead/pubs/renovation.htm
Owners of these rental
properties must document compliance with this requirement ? EPA's
sample Pre-Renovation
Disclosure Form may be used for this purpose.
After April 22, 2010,
property owners who perform these projects in pre-1978 rental housing
or space rented by child-care facilities must be certified and
follow the lead-safe work practices required by EPA's Renovation, Repair
and Remodeling rule. To become certified, property owners must submit
an application for firm
certification and fee payment
to EPA. EPA will begin processing applications on October 22, 2009.
The Agency has up to 90 days after receiving a complete request for
certification to approve or disapprove the application. Read more about
EPA's rules and lead-safe work practices in EPA's pamphlet Contractors: Lead Safety
during Renovation
Property owners who perform
renovation, repairs, and painting jobs in rental property should also:
- Take training
to learn how to perform lead-safe work practices.
- Learn the lead laws that apply
to you regarding certification and lead-safe work practices beginning
in April 2010.
- Keep records to demonstrate
that you and your workers have been trained in lead-safe work practices
and that you followed lead-safe work practices on the job. To make recordkeeping
easier, you may use the sample
recordkeeping checklist that
EPA has developed to help contractors comply with the renovation recordkeeping
requirements that will take effect in April 2010.
Information for Homeowners Working
at Home
If you are a homeowner
performing renovation, repair, or painting work in your own home, EPA's
RRP rule does not cover your project. However, you have the ultimate
responsibility for the safety of your family or children in your care.
If you are living in a pre-1978 home and planning to do painting or
repairs, please read a copy of EPA's Renovate
Right: Important Lead Hazard Information for Families, Child Care Providers,
and Schools lead hazard
information pamphlet. You may also want to call the National Lead Information
Center at 1-800-424-LEAD (5323) and ask for more information on how
to work safely in a home with lead-based paint.
Information for Tenants and Families
of Children under Age 6 in Child Care Facilities
and Schools
As a tenant or a parent
or guardian of children in a child care facility or school, you should
know your rights when a renovation job is performed in your home, or
in the child care facility or school that your child attends.
Before starting a renovation
in residential buildings built before 1978, the contractor or property
owner is required to have tenants sign a pre-renovation disclosure form,
which indicates that the tenant received the Renovate Right lead
hazard information pamphlet.
The contractor must also
make renovation information available to the parents or guardians of
children under age six that attend child care facilities and schools,
and to provide to owners and administrators of pre-1978 child care facilities
and schools to be renovated a copy of EPA's Renovate
Right: Important Lead Hazard Information for Families, Child Care Providers,
and Schools lead hazard information
pamphlet.
Information for Realtors and Property
Management Firms
Realtors and property managers should
make themselves aware of the requirements in the Lead Renovation, Repair
and Painting (RRP) Rule. EPA is working closely with the National Association
of Realtors to make realtors and property managers aware of the hazards
of lead paint poisoning and ways to prevent it, and the association
has developed a series of guidance videos aimed at realtors and property
managers. See: http://www.realtor.org/government_affairs/lead_paint_main
Related Notices, Final and Proposed
Rules, and Background Information on EPA's Lead Renovation, Repair and
Painting Program Rule
Read EPA's July 15, 2009, Federal Register notice announcing
a final rule to make minor revisions to the Renovation, Repair and Painting
Program Rule. Read summary information on
the final rule relating to
requirements for training providers to submit photos of trainees.Read other information related
to the Renovation, Repair and Painting Program Rule.
http://www.epa.gov/lead/pubs/renovation.htm
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