Understanding EPAs LRRP Program

Why the new Rule? Lead is especially dangerous to children under six years of age Reduced IQ and learning disabilities Behavior problems Even children who appear healthy can have dangerous levels of lead in their system Lead is also harmful to adults. High blood pressure and hypertension Transfer to fetus in pregnant women

Whats the problem? Dust is the main problem. Lead in dust is the most common way people are exposed to lead. Home renovation creates dust. Proper work practices protect you from the dust.

Lead Paint History Lead paint was used in more than 38 million homes until it was banned in Lead was also used in varnishes and shellacs When you hear the word paint, it includes all of these finishes. Homes likely to contain lead 87% built before % built between % built between

Implementation Timeline April 2008 Final rule published December 2008 Start distributing new pamphlet April 2009 Certified Renovator Training begins October 2009 Firms can apply for certification April 2010 Full compliance

What is LRRP? Lead Based Renovation, Repair and Paint Program A federal regulatory program affecting anyone who disturbs painted surfaces Applies to houses, apartments and child occupied facilities built before 1978 Includes pre-renovation education requirement Includes Renovator training and certification

Who must follow the rule? In general, anyone who is paid to perform work that disturbs paint in housing and child occupied facilities built before 1978, such as: Residential rental property owners General contractors Special trade contractors

What activities are subject? Any activities that disturb paint in an area larger than 6 square feet inside or 20 square feet outside. Remodeling and repair work Electrical work Plumbing Painting Carpentry All window replacements

Any exclusions? Housing or components declared lead- free by certified renovator Housing built after 1978 Housing for the elderly unless children reside there Zero bedroom dwellings Minor repair that disturbs less than 6 square feet

Owner Opt-out Provision Provides the owner the opportunity to opt out of Lead Safe Work Practices This opt out lead to a law suit against EPA EPA has agreed to remove this sometime summer 2010 Other parts of the rule also may change because of this law suit but no other changes in the near future

Education Requirement Pre-renovation education for all pre-1978 housing Distribute new pamphlet Renovate Right Distribute no more than 60 days prior work To owner To all occupants in multi-family setting Post on signs in common areas Signature of receipt or certification of attempt

Lead Save Work Practices Contain the work area Post warning signs Cover floors and furniture, seal doors and ducts Minimize the dust No open flame burning or torching No sanding etc with power tools No heat guns greater than 750 degrees Clean up thoroughly Use a HEPA vacuum Wet mop with plenty of rinse water

Recordkeeping Records must be kept for 3 years Verification of owner/occupant receipt of pamphlet or verification of attempt to inform. Verification of lead check test Documentation of the use of Lead Safe Work Practices Certified Renovator certification Certified Renovator tasks Proof of worker training

Firm and Renovator Two different Certifications under the rule: Firm Certification The company that is responsible for doing the renovation. The company must apply to become a Certified Renovation Firm. Renovator Certification The person on site that is responsible for the renovation. The Renovator must attend an 8 hour training course.

Firm Certification Under CCB Called a Contractors License not a Firm Certification All CCB licensed contractors that plan to do work on pre-1978 houses Apply to CCB for Certified Lead Based Paint Renovation Contractors License $50 per year application fee

Firm Certification Under DHS Any entity not licensed with CCB that will do work on pre-1978 houses Apply to DHS for Firm Certification $250 application fee good for five years

Firm Responsibilities Certified Firms must ensure that All individuals performing work are certified renovators or trained by the certified renovator A certified renovator is assigned to each renovation and performs all of the renovator responsibilities All renovations performed are in accordance with work practice standards of the LRRP rule Pre-renovation education requirements are met Recordkeeping requirements are met

Renovator Certification Renovators must be trained and certified Individual must complete an 8 hour training course Certification comes from the Training Instructor Certification good for 5 years

Renovator Responsibilities Use EPA approved lead test kit Provide on the job training for other workers Be physically present when signs are posted, during work area containment & during clean up Direct work being preformed by others Be available by phone when not required on site Have a copy of their Renovator Certification on hand at the work site Prepare required records Use lead safe work practices

OHBA Response Train and certify qualified instructors to teach: the entire 8 hour course; 5 hours lecture, 3 hours hands-on the 3 hour hands-on course that accompanies the online lecture course Create an online course to meet the lecture requirement of the Renovator training course

For More Information Visit To order Renovate Right call For more information on the EPA rule