Q: How will EPA's new lead rule affect remodelers?
A: In April 2008 the Environmental Protection Agency (EPA) released a rule that will have a significant impact on the remodeling industry. The Lead: Renovation, Repair and Painting Rule (RRP) will change how contractors go about working on buildings built before 1978. You'll need to research it more, but here is a quick overview of the rule to get you started:
Scope of the RRP: If you work on a house or building built before 1978 that is occupied by a child under the age of six or a woman that is pregnant this rule could apply. The RRP applies not only to housing, but to schools, hospitals, churches and childcare facilities.
Timeline for Implementation:
April 22, 2008: Rule enacted.
December 22, 2008: Distribution of Renovate Right pamphlet to homeowners and facilities.
April 22, 2009: Certified Renovator training begins.
October 22, 2009: Contractors may apply to be Certified Firms.
April 22, 2010: Full implementation of the RRP.
Certified Firm and Renovator Responsibilities: The RRP has a specific set of responsibilities that companies must follow for their projects that fall under the RRP. Beyond maintaining certification with the EPA, firms must have someone trained as a ‘certified renovator’, distribute the Renovate Right pamphlet, and keep all records of RRP projects for three years. Certified renovators must attend an 8-hour training course, post required signage, supervise dust containment set-up, supervise project clean-up and verify the project is cleaned according to these new standards. Also, they train other workers to use practices described in the standard for these projects.
EPA RRP Website: EPA's website has more information on the rule. The site also has a handbook to help contractors understand the RRP. Called the Small Entity Compliance Guide to Renovate Right, this document guides you through the RRP without having to read the actual regulation.
Implementation on a State Level: The RRP will be the law of the land at a federal level in April of 2010. However, this rule could be implemented at a state level. The means states can choose to adopt this rule or create new rules that could be stricter than the RRP. Currently, 41 states have their own lead abatement programs, separate from the federal lead abatement rules. In addition, the RRP rule has a large potential revenue stream from certification fees, so your state is very likely to implement the RRP. Contact your state agency in charge of lead abatement activity to find out the plans in your state.
-- Brindley Byrd, CGR, CAPS, is a national speaker, author and advocate who has served the construction industry for over 12-years. He established the Responsible Remodeling™ core operating system for dust-safe work practices to protect the health of workers and customers. He has guided hundreds of professional remodelers through the regulations and work practices of managing remodeling air quality. Contact Brindley at [email protected] or visit www.qx2.net for more information.
