Renovation Repair Painting Program Rule 40 CFR Part

Renovation Repair Painting Program Rule 40 CFR Part 745 Subpart E (Residential Property Renovation) (epa. gov/lead)

WHY NOW? § Studies show that typical renovations create substantial amounts of dust. In pre-1978 homes this creates occupant exposure to lead based paint. Approximately 41% of children under the age of 6 who have EBL’s, live in homes that were renovated within the previous year. § Studies show that typical clean-up methods i. e. dust pan and broom and vacuuming are ineffective at removing existing lead dust and lead dust created during construction activity. § In 1992 Congress passed the "Residential Lead-Based Paint Hazard Reduction Act (“Title X”) and expected EPA to promulgate rules within 4 years (1996) that would govern renovation and remodeling activities to minimize the creation of lead dust. These rules were completed in 2008!

WHAT IS RRP? § § SCOPE Amends Title 40 of the Code of Federal Regulations Part 745 (40 CFR 745) – A federal regulatory program affecting contractors, rental property owners and managers and anyone else that disturbs painted surfaces in pre-1978 units; this rule primarily impacts remodeling/home improvement contractors and rental property owners – It applies to housing, apartments and child occupied facilities – This law presumes the presence of lead in paint unless proven otherwise § The Rule is made up of four basic parts: – Requires education of owners and occupants of “Target Housing” before work begins – Requires firms conducting renovations on target housing to be certified and to use a certified renovator – Requires lead safe work standards and practices be performed in order to pass clearance – Requires adequate enforcement

When is RRP Required? § For all renovations that disturb painted surfaces. Renovations include; removal, modification or repair including surface preparation. Renovation does not include minor repair and maintenance activities that disturb 6 square feet or less of painted surface per room for interior activities or 20 square feet or less for exterior activities. § Renovations for compensation

WHO IS IN CHARGE? § Right now the EPA is administering and enforcing the Rule § EPA wants States to Administer this Rule § Michigan is in the process of amending the current Lead Abatement Act to include Lead Abatement and Renovation. When approved the Healthy Homes Section will administer the RRP Rule.

“I AM A CONTRACTOR, WHAT SHOULD I BE DOING NOW” § DISTRIBUTE THE CORRECT PAMPHLET!! § The old blue pamphlet no longer applies to renovations § Maintain a record proving that you provided the pamphlet § Get training – become Certified Renovator § After Oct 22, 2009 apply to become certified firm

IMPORTANT DATES § After October 22, 2009 firms can start applying for EPA certification to conduct renovations in Target Housing § Our website will list names of training providers § Effective April 22, 2010 the entire rule becomes effective – training, certification and work practice requirements – Must be a certified firm – Must employ a certified renovator to oversee and manage the project – Must employ lead safe work practices – Must properly clean and clear the work area – Must maintain records

“WHEN WILL THE STATE TAKE OVER? ” § Changes to the Act will take about 18 months § EPA will be in charge until then § Once the State takes over…. . – You will need to obtain Firm Certification § Note: the renovator firm Certification fee is waived if you are already a Certified Lead Abatement firm – You will need to become a Certified Renovator – Enforcement will be conducted by the State § Note: EPA wants strict enforcement of this Rule – Training and education will be conducted during implementation of this Rule

WORK PRACTICE STANDARDS § POST SIGNS TO DEFINE THE WORK AREA § CONTAIN THE WORK AREA SO NO DUST OR DEBRIS LEAVES THE WORK AREA § REMOVE OBJECTS FROM THE WORK AREA OR COVER § CLOSE WINDOWS AND DOORS § COVER THE FLOOR § USE PRECAUSTIONS TO ENSURE THAT PERSONNEL, TOOLS AND OTHER ITEMS ARE FREE OF DUST AND DEBRIS BEFORE LEAVING THE WORK AREA. § POST RENOVATION CLEANING AND CLEARANCE

CONTACT INFO § STEVE M SMITH § (616) 240 -3926 § STEVEMSMITH@PEOPLEPC. COM