The Lead Based-Paint Renovation, Repair, and Painting (RR&P) rule became effective June 23, 2008 and will be fully implemented on July 22, 2010. This rule is a federal regulatory program that applies to all renovations performed for compensation in target housing and child occupied facilities constructed before 1978. The RR&P rule includes pre-renovation requirements, as well as training, certification, work practice guidelines and recordkeeping.
The purpose of the rule is to ensure that owners and occupants receive information on lead-based paint (LBP) hazards before renovation begins. It also ensures that individuals performing renovations are properly trained, certified, and that safe work practices are followed.
The rule will affect contractors and property managers who disturb painted surfaces during renovation and repair activities. Affected trade groups are anticipated to include carpenters, painters, electricians, drywallers, plumbers, HVAC, and handymen. The rule broadly defines renovation as any activity that disturbs painted surfaces greater than six square feet per interior room or greater than 20 square feet of an exterior surface. Projects smaller in size are generally considered minor repair and maintenance activities and are not included in the definition of renovation. Demolition of painted surfaces and window replacement are considered renovation, regardless of size.
In addition to minimum size, there are other exceptions to the rule, such as housing built in 1978 or later, housing for elderly and disabled, studio apartments and dormitories, and housing or components determined to contain lead at less than 1.0 milligram per centimeter square. Certified Renovators will be able to use EPA recognized Lead Test Kits to make determination that affected components do not contain LBP or coatings.
Starting April 22, 2010, renovation in target housing or child occupied facilities must be conducted by certified renovation firms, using appropriately trained workers following the required work practices. Firms may begin applying for EPA certification on October 22, 2009 to conduct certified renovations.
Certified firms must utilize workers who are Certified Renovators. To become certified, workers must take an EPA accredited one-day class and a refresher every five years.
The EI Group, Inc. has applied to become an accredited training provider and expects to begin offering Certified Renovator training soon.