Post on 30-Mar-2015
Understanding EPA’sLRRP Program
www.oregonhba.com
Why the new Rule? Lead is especially dangerous to children under six years of age Reduced IQ and learning disabilities Behavior problems
Even children who appear healthy can have dangerous levels of lead in their system
Lead is also harmful to adults. High blood pressure and
hypertension Transfer to fetus in pregnant women
What’s the problem?Dust is the main problem.
Lead in dust is the most common way people are exposed to lead.
Home renovation creates dust. Proper work practices protect you from the dust.
Lead Paint History Lead paint was used in more than 38
million homes until it was banned in 1978.
Lead was also used in varnishes and shellacs When you hear the word “paint”, it
includes all of these finishes. Homes likely to contain lead
87% built before 1940 69% built between 1940-1960 24% built between 1960-1978
Implementation Timeline April 2008
Final rule published December 2008
Start distributing new pamphlet April 2009
Certified Renovator Training begins October 2009
Firms can apply for certification April 2010
Full compliance
What is LRRP? Lead Based Renovation, Repair and Paint Program A federal regulatory program affecting
anyone who disturbs painted surfaces Applies to houses, apartments and child
occupied facilities built before 1978 Includes pre-renovation education
requirement Includes Renovator training and
certification
Who must follow the rule? In general, anyone who is paid to perform work that disturbs paint in housing and child occupied facilities built before 1978, such as: Residential rental property owners General contractors Special trade contractors
What activities are subject? Any activities that disturb paint in an area larger than 6 square feet inside or 20 square feet outside. Remodeling and repair work Electrical work Plumbing Painting Carpentry All window replacements
Any exclusions?Housing or components declared lead-free by certified renovator
Housing built after 1978Housing for the elderly unless children reside there
Zero bedroom dwellingsMinor repair that disturbs less than 6 square feet
Owner Opt-out ProvisionProvides the owner the opportunity to opt out of Lead Safe Work Practices This opt out lead to a law suit against
EPA EPA has agreed to remove this
sometime summer 2010 Other parts of the rule also may
change because of this law suit but no other changes in the near future
Education RequirementPre-renovation education for all pre-1978 housing Distribute new pamphlet
Renovate Right Distribute no more than 60 days prior
workTo ownerTo all occupants in multi-family settingPost on signs in common areas
Signature of receipt or certification of attempt
Lead Save Work Practices Contain the work area
Post warning signs Cover floors and furniture, seal doors and
ducts Minimize the dust
No open flame burning or torching No sanding etc with power tools No heat guns greater than 750 degrees
Clean up thoroughly Use a HEPA vacuum Wet mop with plenty of rinse water
RecordkeepingRecords must be kept for 3 years
Verification of owner/occupant receipt of pamphlet or verification of attempt to inform.
Verification of lead check test Documentation of the use of Lead
Safe Work Practices Certified Renovator certification Certified Renovator tasks Proof of worker training
Firm and RenovatorTwo different Certifications under the rule:
Firm Certification The company that is responsible for doing
the renovation. The company must apply to become a Certified Renovation Firm.
Renovator Certification The person on site that is responsible for
the renovation. The Renovator must attend an 8 hour training course.
Firm CertificationUnder CCB
Called a Contractor’s License not a Firm Certification
All CCB licensed contractors that plan to do work on pre-1978 housesApply to CCB for “Certified Lead Based Paint Renovation Contractors License”
$50 per year application fee
Firm CertificationUnder DHS
Any entity not licensed with CCB that will do work on pre-1978 housesApply to DHS for Firm Certification $250 application fee good for five years
Firm Responsibilities Certified Firms must ensure that
All individuals performing work are certified renovators or trained by the certified renovator
A certified renovator is assigned to each renovation and performs all of the renovator responsibilities
All renovations performed are in accordance with work practice standards of the LRRP rule
Pre-renovation education requirements are met
Recordkeeping requirements are met
Renovator CertificationRenovators must be trained and certified Individual must complete an 8 hour
training course Certification comes from the
Training InstructorCertification good for 5 years
Renovator Responsibilities Use EPA approved lead test kit Provide on the job training for other workers Be physically present when signs are posted,
during work area containment & during clean up
Direct work being preformed by others Be available by phone when not required on
site Have a copy of their Renovator Certification
on hand at the work site Prepare required records Use lead safe work practices
OHBA ResponseTrain and certify qualified instructors to teach: the entire 8 hour course; 5 hours
lecture, 3 hours hands-on the 3 hour hands-on course that
accompanies the online lecture course
Create an online course to meet the lecture requirement of the Renovator training course
For More InformationVisit www.oregonhba.com To order Renovate Right call
1-800-424-5323For more information on the EPA rulewww.epa.gov/lead