Topics covered today
Introduction to the problem of childhood lead
U.S. Environmental Protection Agency poisoning
Renovation, Repair, and Painting Rule
Federal Government’s response to childhood
lead poisoning
How the RRP Rule was developed
Presentation for
Hofstra University Continuing Education The regulated universe of RRP
April 1, 2011 facilities and activities
Jeanette Dadusc, US EPA Region 2
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Topics covered today
Certification requirements for
training providers, individuals, and firms
Childhood
Notification and work practice requirements
Cleaning Verification Card
Lead Poisoning
Proposed Rule Changes
RRP Frequent Questions
RRP Enforcement Strategy
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Childhood Lead Poisoning Childhood Lead Poisoning
Sources of Lead Statistics
Number one environmental health threat to April 2001 “HUD’s National Survey of Lead and
children Allergens in Housing”
96 million housing units in country
Routes of exposure 26 million had significant LBP hazards
Processing of lead in the body
Oct 2008 Study “Lead Exposures in US Children:
Symptoms of lead poisoning Implications for Prevention”
Lead-based paint in housing remains the most common
Demographics high-dose source of lead in children’s environments.
Blood Lead Levels / Action Level
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Childhood Lead Poisoning
Prevalence of Pb-based paint in housing: Federal
Year House Percent of Houses with
Lead-based Paint
Government’s
was Built
Response to
Before 1940 87 Percent
Childhood
1940-1959 69 Percent
Lead Poisoning
1960-1978 24 Percent
All Housing 40 Percent
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Federal Gov’t Response to Lead Poisoning Federal Gov’t Response to Lead Poisoning
1973 EPA regs to gradually reduce lead in gasoline
EPA’s Lead-Based Paint Program
1978 CPSC ban on lead in consumer paint
Section 1018—Real Estate Disclosure
1978 OSHA issued regulations to protect general
Section 402(a)/404—LBP Activities [“Abatement”]
Training and Certification
industry workers from lead exposure
1990 CDC phase-in of blood lead testing for young
Section 405—National Lead Laboratory Accreditation
Program [NLLAP]
children
1992 Residential Lead-Based Paint Hazard Reduction
Section 403 – Hazard Standards for Lead in Paint,
Dust, and Soil
Act (Title X)
1997 President’s Task Force on Envir. Health Risks and
Section 402(c)—Renovation, Repair, and Painting
(RRP) Rule
Safety Risks to Children
Section 406(b)– Pre-Renovation Education Rule
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Development of the RRP Rule
Development of the TSCA 402(c)(2) directs EPA to study renovation and
remodeling activities
RRP Rule
EPA consulted with national specialists
Categories of renovation activities which could result in
exposure to lead…
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Development of the RRP Rule Development of the RRP Rule
paint removal
Phase 1: Environmental Field Sampling Study
surface preparation
removal of large structures (demolition)
window replacement Phase II: Worker Characterization and Blood Lead
enclosure of exterior painted surfaces Study
removal of carpet or other floor covering
wallpaper removal
HVAC repair or replacement including duct work Phase III: Wisconsin Childhood Blood Lead Study
repairs or additions resulting in isolated small surface
disruptions
Phase IV: Worker Characterization and Blood Lead
exterior soil disruption
Study of Renovation and Repair Workers Who
major renovation projects involving multiple target
activities Specialize in Renovations of Old or Historic Homes
(continuation of Phase II study)
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Development of the RRP Rule
Where LBP is present, routine renovation and
remodeling activities can create significant amounts
of leaded dust.
The Regulated Universe
Children who live in homes where renovation and
remodeling activities were performed within the past
of RRP Facilities and
year are 30% more likely to have a BLL that equals
or exceeds 10 ug/dL. Activities
Persons performing renovation and remodeling
activities in old historic buildings are more likely to
have elevated blood lead levels than persons in the
general population of renovation and remodeling
workers.
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40 CFR 745.80 RRP Regulated Facilities
“Target Housing” (745.223)
Housing constructed prior to 1978 except
RRP applies to all renovations performed
for compensation in target housing, and -- housing for the elderly or housing for
child occupied facilities (COFs). persons with disabilities unless one or
more children under 6 years old resides or
is expected to reside in such housing
-- and 0-bedroom dwellings
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RRP Regulated Facilities RRP Regulated Activities
“Child-Occupied Facility” (745.83) “Renovation” (745.83)
A building or portion of a building built prior to 1978
The modification of an existing structure that
Visited regularly by the same child under age 6
results in the disturbance of painted surfaces.
At least 3 hours a day
At least 6 hours a week Disturbing more than 6 ft2 per room of painted surface
At least 60 hours a year (interior)
Common areas routinely used by the children under Disturbing more than 20 ft2 of painted surface
age 6 (exterior)
Adjacent exterior areas
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RRP Regulated Activities RRP Regulated Activities
Examples of “Renovations” “Performed for Compensation”
Surface preparation (sanding and scraping) Preamble, Interpretive Guidance
Surface restoration (replastering) Compensation means that the renovator is paid
for the service provided. This payment could
Plumbing, carpentry, and HVAC work
take the form of cash or barter.
Removal, modification, or repair of painted
Wages paid to facility maintenance staff
surfaces
Monies paid to outside contractors
All demolition of painted surfaces
Rent
All window replacements
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What are the Renovation Exemptions? What are the Renovation Exemptions?
1. Confirmation that painted surfaces are lead- 2. Activities performed as part of an abatement
free by certified abatement contractors
- written determination from a certified inspector or
risk assessor
3. Opt-Out Provision—no longer available;
removed July 6, 2010
- certified renovator using an EPA-recognized spot-
test kit and following the manufacturer’s
instructions 4. Emergency renovations (partially exempt)
pamphlet distribution and notification requirements
LeadCheck Kit by Hybrivet warning signs
containing the work area
State of MA Lead Test Kit
waste handling
training and certification
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Any questions about RRP Regulated
Facilities and Activities?
Training Providers,
Target Housing
Individuals,
Child Occupied Facilities
and Firms must be EPA
Renovation
Certified
Performed for Compensation
Exemptions
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RRP Training and Certification Training Provider Accreditation
& Individual Certification
Accreditation of Training Providers EPA accredits training providers who, in turn, certify
individuals upon completion of the Renovator or Dust
Sampling Technician (DST) course.
Renovator and Dust Sampling Technician
certification http://www.epa.gov/lead/pubs/training.htm
Certification is good for 5 years
Firm certification Must have certification while conducting work
Model EPA courses for Renovator and Dust Sampling
Technician are on the Internet
Non-certified Workers
http://cfpub.epa.gov/flpp/searchrrp_training.htm
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Model Renovator Certificate Individuals-Who should be certified?
Real estate owners, lessors, or managers
Engineering and building inspection services
Firms and contractors performing the
following activities:
-- Building construction -- Plumbing
-- Air-conditioning installation -- Heating
-- Painting and wall covering -- Carpentry
-- Electrical work
-- Installation of drywall, insulation, siding, tile, and windows
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Firm Certification Model EPA Renovation Firm Certificate
Certified renovators must be employed by an EPA
Certified Renovation Firm.
EPA has 90 days to approve/ disapprove an application
Application for firm certification:
http://www.epa.gov/lead/pubs/firmapp.pdf
Certification is good for 5 years.
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Non-Certified Workers Responsibilities of the Certified Firm
All individuals performing regulated activities on
Must have a certified renovator assigned to each job. behalf of the firm are either certified renovators or
have been trained by a certified renovator.
Non-certified workers must be trained by a certified
renovator. A certified renovator is assigned to each renovation
and performs the requisite activities.
The certified renovator must keep documentation of
having trained the workers.
All lead safe work practices are followed.
Information distribution requirements are followed.
Recordkeeping requirements are met.
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Responsibilities of the Certified Any questions about Certification
Renovator Requirements?
* Prepare necessary records Training Provider Accreditation
* Use an EPA-approved test kit
* Conduct cleaning verification Individuals—Renovators and Dust Sampling Tech.
Perform, or direct, the lead safe work practices Renovation Firms
Be physically present for site preparation and site
cleaning. Non-certified Workers
Regularly direct work being performed by non-certified
workers. Responsibilities of the Certified Firm
Be available, either on-site or by phone, at all times that and Certified Renovator
renovations are being conducted.
Have proof of certification at all times.
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Information distribution- Target Housing
Information Distribution Target Housing—dwelling unit
and Provide the owner/ occupant(s) with the
Renovate Right pamphlet
Work Practice Requirements
Maintain written acknowledgement
or certificate of mailing to confirm
delivery
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Information distribution- Target Housing Information distribution– COF
Target Housing—common areas Child Occupied Facility
Provide the owner with the Renovate Right Provide the owner / adult rep. with the Renovate
pamphlet and maintain written acknowledgement Right pamphlet and maintain written
acknowledgement or certificate of mailing
or certificate of mailing to confirm delivery
Notify all parents and guardians of
Notify all affected occupants of :
1) the nature of the renovation
1) the nature of the renovation
2) how they can review / obtain the Renovate 2) how they can review / obtain the Renovate
Right pamphlet Right pamphlet
3) how occupants can review/ obtain the records of 3) how the parent and guardians can review/ obtain
the renovation the records of the renovation
Prepare a signed statement describing steps Prepare a signed statement describing steps
performed to notify tenants performed to notify parents and guardians
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Work Practice Requirements Examples of
Containment–
EPA-certified test kit (optional) Compliments of LIUNA
Warning signs Training and Education
Define work area
Fund
Don PPE (recommended)
Build containment
Avoid prohibited or restricted practices -- Two-layer plastic
Clean work area
Waste handling
barrier on doorway
Cleaning verification or dust sampling
Recordkeeping and Reporting -- Warning sign posted
to define work area
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HVAC turned off and covered Cover stationary items
Compliments of LIUNA Training and Education Fund Compliments of LIUNA Training and Education Fund
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Cover floors Cover exterior surfaces
Compliments of LIUNA Training and Education Fund Compliments of LIUNA Training and Education Fund
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Cover exterior surfaces Cover Vegetation
Compliments of LIUNA Training and Education Fund Compliments of LIUNA
Training and Education
Fund
-- All items within 10 feet of
the work area must be
covered to prevent the
spread of dust
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Any questions about Information RRP Cleaning
Distribution or Work Practice Verification Card
Requirements? -- Wipe floors and windowsills
Information distribution in Target Housing with a wet disposable cleaning cloth.
-- Follow instructions on back of card.
Information distribution in Child Occupied Facilities
-- Must be conducted by the Certified
Renovator
Work Practices for Interior and
Exterior renovations -- Dust clearance testing can be
performed in lieu of the cleaning
Waste management verification
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RRP Rule Changes RRP Rule Changes
EPA Settlement EPA Settlement
Aug. 2009 -- EPA Settlement with public interest “Opt-Out Rule”
groups Oct. 2009—Proposed Rule
April 22, 2010—Final Rule
Settlement includes agreement to undertake July 6, 1010—Effective Date
several rulemakings.
“Clearance Rule”
Note: Settlement dictates what will be included
April 22, 2010—Proposed Rule
in the proposals, but does not dictate the
outcomes of the final rules. July 15, 2011—Final Rule due
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RRP Rule Changes Highlights of RRP Frequent Questions
EPA Settlement Document
Public and Commercial Buildings Guidance on…
April 22, 2010—Advanced Notice of Proposed Containment
Target Housing and COF determinations
Rule Making (ANPR) issued
Firm Certification
Aug. 6, 2010—Comments due Demolition of bldgs
Dec. 15, 2011—Proposed Rule due re: Asbestos workers
renovations on the exterior of Public and Shared liability of multiple firms
Commercial Bldgs. “For Compensation”
Surface coatings containing lead
2012-2013—Proposed Rule due re: renovations
Use of lead test kits
on interior of Public and Commercial Bldgs. Personal Protective Equipment
and many more topics….
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EPA’s RRP Enforcement Strategy Contact Information
National readiness EPA Region 2 Lead Team
732-321-6671
State Authorization Region2 LeadCoordinator@epa.gov
Local Leveraging
National Lead Information Hotline
Tips and Complaints 800-424-LEAD (5323)
TSCA Liability EPA Lead Website
Coordination with Local Health Depts. http://www.epa.gov/lead/
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