In 2010, the EPA’s RRP (renovation, repair and painting) Rule became effective. This rule was designed to protect against lead hazards that may occur when lead-based paint is disturbed during renovation, repair and painting work. Contracting firms and their workers must be trained and certified to conduct such work in pre-1978 housing in accordance with lead-safe work practices. Therefore, whenever painted surfaces may be disturbed during the performance of mold remediation work, plumbing work, window and door replacement work, etc., following the completion of the work, dust wipe sampling must be conducted to assure that levels of lead dust on surfaces in the work areas are below Federal clearance levels.
Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children.
On April 22, 2008, EPA issued a rule requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning. Under the rule, beginning in April 2010, contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination. Until that time, HUD and EPA recommend that anyone performing renovation, repair, and painting projects that disturb lead-based paint in pre-1978 homes, child care facilities and schools follow lead-safe work practices.
There are some differences between the EPA RRP Rule and the HUD Lead Safe Housing Rule (LSHR). A major difference is that the LSHR requires clearance examinations. All housing receiving federal assistance must still comply with the LSHR. OHHLHC provides Information on complying with the LSHR and RRP, and Frequently-asked Questions from Grantees. Additional information for renovators is available.
All contractors should follow these three simple procedures:
- Contain the work area.
- Minimize dust.
- Clean up thoroughly.
From December 2008, the rule has required that contractors performing renovation, repair and painting projects that disturb lead-based paint provide to owners and occupants of child care facilities and to parents and guardians of children under age six that attend child care facilities built prior to 1978 the lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF)
Starting on April 22, 2010, the rule will affect paid renovators who work in pre-1978 housing and child-occupied facilities, including:
- Renovation contractors
- Maintenance workers in multi-family housing
- Painters and other specialty trades.
Under the rule, child-occupied facilities are defined as residential, public or commercial buildings where children under age six are present on a regular basis. The requirements apply to renovation, repair or painting activities. The rule does not apply to minor maintenance or repair activities where less than six square feet of lead-based paint is disturbed in a room or where less then 20 square feet of lead-based paint is disturbed on the exterior. Window replacement is not minor maintenance or repair.
Read EPA’s Lead Renovation, Repair and Painting Program Rule.
Further information on this rule can be found at http://www2.epa.gov/lead/lead-renovation-repair-and-painting-program-rules.
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