Lead-Based Paint Renovation, Repair, and Painting Rule Overview of RRP Rule EPA Region 8 ************ Jim Maley

RRP Final Rule - Overview 2 Why are we concerned about Lead ? Lead is most dangerous to children under the age of six Childrens systems are more sensitive Childrens growing bodies absorb more lead

RRP Final Rule - Overview 3 How is Lead harmful to Children Affects a childs developing Central Nervous System Reduces a childs IQ and cause learning disabilities Causes behavioral problems as the child develops into adulthood

RRP Final Rule - Overview 4 Lead effects on Adults Harmful to the fetus Fertility problems High blood pressure

RRP Final Rule - Overview 5 Exposure to Lead Lead Dust is the most common way Deteriorating paint creates lead dust Lead contaminated outside soil creates dust Home renovations create lead dust

RRP Final Rule - Overview 6 New RRP Rule April 22, 2010 EPA issued a final rule under the authority of § 402(c)(3) of the Toxic Substances Control Act (TSCA) to address lead-based paint hazards created by renovation, repair, and painting activities that disturb lead-based paint in target housing and child-occupied facilities.

RRP Final Rule - Overview 7 Acronyms/Definitions RRP: Renovate, Repair and Paint Regulation also referred to as Renovate Right Target Housing: any housing built prior to 1978 Child Occupied Facility – a facility where children under 6 regularly visit

RRP Final Rule - Overview 8 The Renovate, Repair and Paint Regulation Applies to renovations for compensation in homes, schools and other child occupied facilitys built prior to 1978

RRP Final Rule - Overview 9 Who is affected by the regulation ? Renovation contractors Maintenance workers Painters Other specialty trades

RRP Final Rule - Overview 10 What does the rule say ? Contractors, painters, maintenance persons that disturb painted surfaces in pre-1978 homes, schools or other child-occupied facilities must: – be certified, – work for a certified firm – and work in a lead safe manner.

RRP Final Rule - Overview 11 Abatement vs. Renovation Abatements are intended to permanently eliminate existing lead hazards. Abatements are not covered by this rule. Renovations involve activities designed to update, maintain, or modify all or part of a building. The rule is designed to prevent the introduction of new lead hazards created by a renovation, not to address existing lead hazards.

RRP Final Rule - Overview 12 What activities and buildings are Subject to RRP ? In general, any activity that disturbs paint in pre housing, schools and other child-occupied facilities This would include remodeling and repair/maintenance, electrical work, plumbing, painting carpentry and window replacement Child-occupied facilities may be located in public or commercial buildings or in target housing. This includes schools, kindergarten classrooms and daycare facilities.

RRP Final Rule - Overview 13 What Activities and Buildings are excluded from the Rule Excludes: – Homes built in 1978 or later – Housing for the elderly – Zero-bedroom dwellings (studio apartments, dormitories, etc.). – Activities that disturb less than 6 ft 2 interior or 20 ft 2 exterior. This excludes window replacement, demolition and projects involving prohibited practices. – Work done by individuals in housing they own and occupy. – Public buildings

RRP Final Rule - Overview 14 Pre-Renovation Education brochure Renovate Right developed for all covered renovations Given to owner and possibly tenants Post signs

RRP Final Rule - Overview 15 Certification Individuals Must take 8-hour accredited training course: – Certified Renovators - perform & direct renovation activities – Dust Sampling Technicians - perform dust sampling not for an abatement Course certificate serves as certification (no application to EPA required) Refresher training is required every 5 years Other workers do not need certification but must be trained by a Certified Renovator on the job Certification allows the renovator to perform renovations in any non-authorized state or Tribal area.

RRP Final Rule - Overview 16 Work Practice Standards Firm Responsibilities Firms performing renovations must ensure that: – All individuals performing renovation activities are either certified renovators or have been trained by a certified renovator. – A certified renovator is assigned to each renovation and performs all of the certified renovator responsibilities. – All renovations performed by the firm are performed in accordance with the lead-safe work practice standards. – The firm supplies lead hazard information pamphlets to owners or managers of the home or building to be renovated prior to starting the work. – The Lead RRP Rules recordkeeping requirements are met.

RRP Final Rule - Overview 17 Recordkeeping Requirements All documents must be retained for 3 years following the completion of a renovation. Records to be retained include: – Reports certifying that lead-based paint is not present – Records required by the Pre-Renovation Education Rule – Documentation stating that the requirements do not apply – Documentation of compliance with the requirements

RRP Final Rule - Overview 18 Enforcement and Penalties EPA may suspend, revoke, or modify a firms certification if firm is found to be in non-compliance. Non-compliant contractors may be liable for civil penalties of up to $37,500 for each violation per day Contractors who knowingly or willfully violate this regulation may be subject to fines of up to an additional $37,500 per violation, or imprisonment, or both.

RRP Final Rule - Overview 19 For More Information: U.S. Environmental Protection Agency Region 8 Lead Program 1595 Wynkoop 8ENF-AT Denver, Colorado Jim Maley, Lead and Asbestos Inspector,

RRP Final Rule - Overview 20 For More Information U.S. Environmental Protection Agency Region 8 Lead Program 1595 Wynkoop 8P P3T Denver, Colorado Teri Bahrych, Tribal Lead Coordinator,