connecticut department of public health lead and healthy homes program what you should know about...
TRANSCRIPT
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 administeror 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:Examples:
o Residential rental property owners
o Painterso Home Improvement
Contractorso Renovators &
Remodelerso Carpenterso School Administrators
o Daycare Owners/Operators
o Finishing Workerso Property Managerso Maintenance Staffo Electricians & Plumberso Window Replacement
Firmso 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 bedistributed to propertyowners, 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 seeno Describe the nature, locations, and dates of the renovationo 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:
oThe trainer that you take the certification training from must be accredited through EPA
oMake sure you verify that the firm is accredited either by contacting EPA or by visiting their website
oThe link shows all the currently accredited training providers
http://cfpub.epa.gov/flpp/searchrrp_training.htm
What are the Training, Certification, and Work
Practice Requirements?
Firms:
o A firm must be certifiedo Application to EPA (or an authorized State)o $ 300 Feeo 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 providero 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:
oThe course completion certificate serves as certification oRenovation activities must be performed and/or directed by a certified renovatoroRefresher training is required every 5 yearsoOther workers do not need certification but they must receive on-the-job training from a certified renovatoroCertification 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 workerso 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 phoneo Perform project cleaning verificationo Have course certificates availableo 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 scrapingo 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 dayo 1 year in prisono 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 residentso Building ownerso An adult representative or owner of the child-occupied facility before the
renovation starts
Get receipt:o Signed receipto Self-certificationo Certificate of mailing from post officeo Keep for three years
Key Points to Remember
o Firm must be certifiedo 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 Rulehttp://www2.epa.gov/lead/renovation-repair-and-painting-program
EPA accredited trainers http://www2.epa.gov/lead/renovation-repair-and-painting-program-training-providers
Renovate Right brochurehttp://www2.epa.gov/sites/production/files/documents/renovaterightbookletbwsept2011.pdf
How to report a violation- by phone, email, websitehttp://www2.epa.gov/lead/forms/lead-hotline-national-lead-information-center
Frequently asked questionshttp://www2.epa.gov/sites/production/files/documents/full_rrp_fqs_-_december_19_2012_with_metadata_2.pdf
Websites
