The EPA RRP Renovation, Repair and Painting Rule
Why is the RRP Rule important?
When lead paint is sanded or scraped or disturbed, microscopic particles of the metal mingle with the dust that is created. That “lead-containing” dust is what can seriously impact people’s health, especially children and pregnant women.
Lead causes a long list of problems, including learning and behavioral problems, kidney disease, high blood pressure, miscarriage and birth defects. Lead can even cause depression and aggressive behavior. Experts say lead poisoning doubles the number of children in special education classes. Studies show it plays a major role in crime rates. Any amount of lead is bad for you. There is no safe level.
There has been a lot of publicity about toys and other consumer products containing lead. But, problems caused by all of those products put together is a drop in the bucket compared to the number of people harmed when contractors disturb old paint in pre-1978 buildings without taking some simple precautions. That’s why EPA and the State of California require contractors to protect people they work for.
To whom does the RRP Rule apply?
The RRP rule applies to anyone who works for compensation in pre-1978 housing and child-occupied facilities, including:
* Demolition workers
* Remodeling contractors
* Maintenance workers in multi-family housing
* Painters, plumbers and most specialty trades.
The RRP rule covers a lot of jobs: renovation, remodeling, painting, window replacement, plumbing, electrical work, heating & air-conditioning, demolition, plus work performed by trades like carpenters, electricians and handymen. The rule also applies to persons working for rental property owners, schools, and day care providers. And, it also applies to non-profits and governmental agencies.
Where does the RRP Rule apply?
The RRP rule applies to “Target Housing” and “Child-Occupied Facilities.”
Definition: Target Housing – is a house or apartment (including mobile homes) built before January 1, 1978 except for:
1) 0-bedroom units (like dorm rooms or studio apartments)
2) housing that is officially designated for the elderly or the handicapped
3) housing that has been tested by a State Certified Lead Inspector and found to be free of lead-based paint.
Definition: Child-Occupied Facility – is a building, or portion of a building, constructed prior to 1978, visited by the same child, 6 years of age or under, on at least 2 different days within any week, provided that each day’s visit lasts at least 3 hours, the combined weekly visit lasts at least 6 hours, and the combined annual visits last at least 60 hours. Such facilities may include, but are not limited to, day-care centers, preschools and kindergarten classrooms.
What does the RRP Rule require?
Pamphlet Distribution – Contractors must give clients a pamphlet called “Renovate Right” and get a signed receipt before beginning a job.
Contractors can call (800) 424-5323 and ask for free copies of “Renovate Right” and the “Small Entity Compliance Guide to Renovate Right” or both can be downloaded as PDF files from the EPA website.
Individual Certification – At least one RRP Certified Renovator is required at each job site. Certification involves taking a 1-day class from an EPA Accredited Training Provider.
Firm Certification – In addition to individual certification, each firm, agency or non-profit must also become RRP certified. (Note: This includes city agencies and school districts as well as small “one-man-band” handymen and owners of rental property.) Firms or “entities” must submit an application and pay EPA a fee ($300) which is good for 5 years.
The EPA Firm Certification Register your firm online at EPA web site. You do not need individual certification to submit a Firm Application. Firms should apply as soon as possible.
According to the EPA, after April 22, 2010, “… no firm working in target housing or child-occupied facilities, where lead-based paint will be affected by the work, may perform, offer or claim to perform renovations without EPA Firm Certification.”
Firm certification is NOT the same as individual certification attained by successful completion of an RRP course. There is no training requirement for Firm Certification.
John P. Lapotaire, CIEC
Certified Indoor Environmental Consultant
Microshield Environmental Services, LLC
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