Connecticut Department of Public Health Lead and Healthy Homes Program What You Should Know About EPA’s Lead Paint; Renovation, Repair, and Painting Rule (RRP)

o RRP is a federal regulatory program affecting contractors, property managers, and others who disturb painted surfaces o It applies to residential houses, apartments, and child-occupied facilities such as schools and day-care centers built before 1978 o It includes pre-renovation education requirements (406b PRE) as well as training, certification, and work practice requirements What Is the Lead-Based Paint Renovation, Repair and Painting Program (RRP)?

For a State to become authorized, it must be at least as protective as EPA CT is not authorized to administer or enforce RRP rule Authorization

CT DPH Provides: o Compliance assistance – typically conducted as part of a complaint response/investigation o Education/outreach – variety of audiences including contractors, property managers, tenants, daycares, etc. o Awareness training – audiences include building officials, housing authorities, professional organizations, etc. Target Audiences

Examples: o Residential rental property owners o Painters o Home Improvement Contractors o Renovators & Remodelers o Carpenters o School Administrators o Daycare Owners/Operators o Finishing Workers o Property Managers o Maintenance Staff o Electricians & Plumbers o Window Replacement Firms o And Many Others……… Who Must Follow the Lead Rule’s Requirements? Anyone who receives compensation for performing work on a pre-1978 dwelling and/or child occupied facility.

Remodeling and repair/maintenance, electrical work, plumbing, carpentry, etc., (for payment) that disturbs: o > 6 square feet of interior painted surfaces (per room) during projects on housing and child occupied facilities built pre-1978 o > 20 square feet of painted exterior surfaces during projects on housing and child occupied facilities built pre-1978 o Any window replacement What Activities are Subject to RRP?

o Housing built after 1977 o Certified lead free housing o Lead abatement projects o Full demolitions o Housing for the elderly or disabled unless a child under 6 resides or is expected to reside there. o Zero-bedroom dwellings (studio apts., dorms). o Minor repair/maintenance o Emergency renovations Exclusions

Pre-renovation education requirements: o Give pamphlet to the owner and occupants before renovation starts o Obtain receipt of the lead pamphlet Signed receipt Self-certification Certified mail from post office What does the RRP Program require Firms to do?

This pamphlet must be distributed to property owners, tenants, daycare & preschool operators, and parents … What does the RRP Program require Firms to do?

Current Receipt Form

For work in common areas of multi-family housing or child-occupied facilities, you must: o Distribute renovation notices to tenants or parents/guardians of the children attending the child-occupied facility o Or you must post informational signs about the renovation or repair job Informational signs must: o Be posted where they will be seen o Describe the nature, locations, and dates of the renovation o Be accompanied by the lead pamphlet or by information on how parents and guardians can get a free copy o Retain records for three years What does the RRP Program require Firms to do?

Trainer Accreditation: o The trainer that you take the certification training from must be accredited through EPA o Make sure you verify that the firm is accredited either by contacting EPA or by visiting their website o The link shows all the currently accredited training providers What are the Training, Certification, and Work Practice Requirements?

Firms: o A firm must be certified o Application to EPA (or an authorized State) o $ 300 Fee o Application on EPA Web site What are the Training, Certification, and Work Practice Requirements?

Renovators: o Must be trained & certified by an EPA accredited training provider o Lead-Safe Work Practices must be followed o Cleaning verification What are the Training, Certification, and Work Practice Requirements?

How can a renovator become trained and certified? Two options: o Must pass an eight-hour initial renovator training course offered by an EPA accredited training provider o OR, if you have already passed an accredited lead abatement worker or lead abatement supervisor course; or have passed an EPA/HUD model Lead Safe Work Practices training course, you only need to take a four-hour EPA RRP refresher renovator training course to become certified What are the Training, Certification, and Work Practice Requirements?

Certification: o The course completion certificate serves as certification o Renovation activities must be performed and/or directed by a certified renovator o Refresher training is required every 5 years o Other workers do not need certification but they must receive on-the-job training from a certified renovator o Certification allows the renovator to perform renovations in any authorized state, non-authorized state or Indian territories What are the Training, Certification, and Work Practice Requirements?

o Can use EPA approved lead test kit for testing painted surfaces being disturbed o Provide on-the-job training for other workers o Must be present when: Warning signs are posted Work area containment is being established What are the Requirements of a Certified Renovator?

o Direct work to ensure compliance with work practice standards o Be available on site or by phone o Perform project cleaning verification o Have course certificates available o Provide recordkeeping checklist to customer o Prepare/keep required records What are the Requirements of a Certified Renovator?

Examples of these practices include: o Work-area containment to prevent dust and debris from leaving the work area o Wet scraping o Prohibition of certain work practices like open-flame burning (>1100 degrees F.) and the use of power tools without HEPA exhaust control o Thorough clean-up followed by a verification procedure to minimize exposure to lead-based paint hazards What are Lead Safe Work Practices?

Written confirmation of receipt must be kept for three (3) years after the completion of the project Record Keeping

o Maximum 37.5K per violation per day o 1 year in prison o EPA can suspend, revoke or modify an individual’s or firm’s certification Enforcement Penalties for Non-Compliance

Renovations that disturb: o > 6 square feet of interior painted surfaces (per room) o > 20 square feet of painted exterior surfaces (total) o any window replacement Give the new “Renovate Right” pamphlet to: o The residents o Building owners o An adult representative or owner of the child-occupied facility before the renovation starts Get receipt: o Signed receipt o Self-certification o Certificate of mailing from post office o Keep for three years Key Points to Remember

o Firm must be certified o Certified Renovator must pass 8 hour approved renovator course offered by an EPA accredited training provider o OR, if you have passed an accredited lead abatement worker or supervisor course, or have passed an EPA/HUD lead safe work practices course, you only need to take a four-hour RRP refresher training course Key Points to Remember

EPA RRP Rule EPA accredited trainers providers Renovate Right brochure bwsept2011.pdf How to report a violation- by phone, , website center Frequently asked questions _december_19_2012_with_metadata_2.pdf Websites

KIMBERLY PLOSZAJ o (860) o DPH Lead and Healthy Homes Contacts