RRP News and Notes

RRP Fast Facts

The More You Know

Practical Answers to Key Questions about the RRP Rule

Q: What is the purpose of the Renovation, Repair & Painting (RRP) Rule?

A: The purpose of the RRP Rule is to minimize exposure from lead-based paint dust during renovation, repair, or painting activities. This is a key effort in reducing the prevalence of childhood lead poisoning, particularly lead poisoning caused by housing contaminated by renovation activities. This will also minimize exposure to older children and adults who are also adversely impacted by lead-based paint dust exposure. Lead paint was used in more than 38 million homes prior to its ban for residential use in 1978. This paint can form toxic dust when it is disturbed during normal home repair work. The EPA RRP program is designed to reduce lead contamination by training contractors in relatively simple lead-safe work practices. The EPA also encourages consumers to choose firms that are certified. Since lead poisoning can cause a wide range of physical, intellectual, emotional, and behavioral issues with societal and financial impacts, the RRP program is prevention-based, cost-effective, and a long-term bargain.

Q: Who must comply with the RRP Rule?

A: The RRP rule applies to any company and any person who receives compensation for work which might disturb painted surfaces in pre-1978 housing, schools, or child-occupied facilities (such as day-care centers). This includes firms, sole proprietorships, and individuals such as:

• General contractors.
• Demolition workers.
• Remodeling and renovation contractors.
• Maintenance workers in multi-family housing.
• Painters, plumbers, carpenters, electricians, HVAC professionals, roofers, siders, window installers, and most specialty trades.
• Persons working for rental property owners, schools, day-care providers, non-profits, and governmental agencies.

Q: Is it a violation of the RRP Rule for a homeowner to hire a firm that is not certified?

A: The RRP Rule does not impose requirements on homeowners unless they are performing renovations on rental space. However, the hired firm would be in violation of the RRP Rule if it was uncertified and performing a covered renovation. Without certification and by not following approved practices, firms found to be in violation of the RRP rule may be subject to civil penalties of up to $37,500 per offense per day.

Q: What does the RRP Rule require?

A:

• Individual Certification
  At least one RRP Certified Renovator is required at each RRP job site. Certification involves taking a 8-hour RRP class from an EPA-accredited training provider like CRAFTWORK TRAINING CENTER. Each student must successfully complete the hands-on skills and pass an end-of-class written exam to receive a Certified Renovator certificate which is valid for 5 years.
• Firm Certification
  In addition to individual RRP certification, each firm, agency, or non-profit receiving compensation for work performed on pre-1978 houses, schools, or child-occupied facilities, must also become RRP certified. This includes city agencies and school districts as well as sole proprietors and owners of rental property. Firm certification is not the same as individual certification. To become a RRP Certified Firm, there are no training requirements; firms or entities simply submit an application to the EPA along with the required fee. This certification is valid for 5 years.
• On-the-Job-Training
  RRP Certified Renovators are required to provide lead-safe work practices training to all non-certified workers on the RRP job. However, contractors who do business with agencies receiving Federal (HUD) money for housing rehabilitation, must utilize only workers who are Certified Renovators for projects that require lead-safe work practices. Non-certified workers receiving on-the-job training may not work on HUD jobs where lead-safe work practices must be followed.
• Paint Testing
  Before beginning a job, the RRP Rule requires Certified Renovators to either test the paint that will be disturbed or assume that the paint is lead-based. Paint testing must be done using EPA-approved test kits. Paint chip samples may also be collected and sent to an EPA-approved laboratory for analysis.
• Lead-Safe Work Practices
  The RRP Rule requires that lead-safe work practices be used when disturbing more than 6-square-feet of interior painted surfaces per room within a 30-day period, or more than 20-square-feet of total exterior painted surfaces. Lead-safe work practices include posting warning signs, setting up the work area to contain dust and debris, use of personal protective equipment, cleaning the work area, and containing and transporting waste.
• Cleaning Verification
  At the end of each job, Certified Renovators are required to perform a Cleaning Verification to ensure that the work area is cleaned up properly.
• Pamphlet Distribution
  Contractors must satisfy the lead safety customer education requirements by providing customers with the Renovate Right pamphlet and obtain a signed receipt of delivery before beginning a RRP job.
• Recordkeeping
  Certified Firms must retain, and make available to the EPA, all records necessary to demonstrate compliance with the RRP Rule for a period of 3 years following completion of a RRP renovation including:
  • Prior reports (if any) certifying that lead-based paint is not present.
  • Results of lead-based paint test kits (if used).
  • Laboratory results of lead-based paint chip collections (if used).
  • Records relating to the distribution of the Renovate Right pamphlet.
  • Name of the Certified Renovator supervising the work.
  • Copies of training certificates for all Certified Renovators working on the job.
  • Documentation of non-certified workers receiving on-the-job training in RRP skills.
  • Documentation of compliance with the requirements of the RRP Rule (posting signs, containing the work area, waste containment and transportation, work site cleanup, cleaning verification of work site).

Q: What about RRP certification renewal?

A: Individuals and firms must regularly renew their RRP certifications to maintain compliance with the RRP Rule.

• Individual Certification Renewal (Certified Renovator)
  • Your initial individual RRP Renovator certification is good for 5 years. After that, renewal is easy as long as you complete an RRP Refresher class before the expiration of your current certification. Renovators who take the RRP Refresher class (without hands-on skills training) before their current certification expires are recertified for 3 years. The 3-year recertification option cannot be selected for back-to-back training. If you don’t complete an RRP Refresher class before the expiration of your current certificate, you must retake the initial 8-hour RRP course to be certified again.
• Firm Certification Renewal (Certified Firm)
  • Firm certifications are good for 5 years. Firms should submit renewal applications to the EPA at least 90 days before the expiration date to ensure continuous certification coverage for an additional 5 years.

Q: Where does the RRP Rule apply?

A: The RRP rule applies to target housing and child-occupied facilities.

• The EPA defines target housing as any house or apartment (including mobile homes) built before 1978 except for:
  • Zero-bedroom units (like dorm rooms or studio apartments).
  • Housing that is officially designated for the elderly or persons with disabilities.
  • Housing that has been tested by a Certified Lead Inspector and found to be free of lead-based paint.
• The EPA defines child-occupied facilities as any building (or portion of a building) constructed prior to 1978 and visited by the same child (6 years of age or under) on at least 2 different days within any week—provided that each day’s visit lasts at least 3 hours, the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours. Such facilities may include, but are not limited to, day-care centers, preschools, and kindergarten classrooms.

Q: I thought lead-based paint had been phased out. How many homes still contain lead-based paint?

A: HUD’s National Survey of Lead and Allergens in Housing estimated that 38 million permanently occupied housing units (40% of all housing units) in the United States contain some lead-based paint that was applied before the residential use of lead-based paint was banned in 1978. Housing units include single-family homes, manufactured housing, and multi-unit dwellings like apartments. Vacant housing, group quarters (such as prisons, hospitals, and dormitories), hotels, motels, and other short-term housing, military bases, and housing where children are not permitted to live (such as housing designated exclusively for the elderly and zero-bedroom units) are not included in this number. More information on these statistics is available from HUD.

Q: What is lead and where is it found?

A: Lead is a toxic metal that was used for many years in products found in and around our homes. Lead also can be emitted into the air from motor vehicles and industrial sources and may enter drinking water from plumbing materials. Many homes built before 1978 have lead-based paint. In general, the older your home, the more likely it has lead-based paint. Soil around a home may contain lead from sources like deteriorated exterior paint, past use of leaded gas in cars, or from past renovation activities. Household dust can pick up lead from deteriorating lead-based paint, from past renovation projects, or from soil tracked into a home. If you work with lead, you could bring it home on your hands or clothes, therefore, it is important to shower and change clothes before going home and launder your work clothes separately.

Q: What is the most significant source of childhood lead exposure in a residence?

A: The scientific literature suggests that, nationally, lead-contaminated paint dust is the most significant source of childhood lead exposure. Lead dust comes from deteriorating lead-based paint and lead-contaminated soil that gets tracked into your home. This dust may accumulate to unsafe levels. Common renovation activities like sanding, cutting, and demolition can also create hazardous lead dust. People, especially children, can swallow lead dust as they eat, play, and do other normal hand-to-mouth activities.

Q: What are some of the health effects of lead?

A: Lead is known to cause a range of health effects, from behavioral problems and learning disabilities, to seizures and death. Children under 6-years-old are most at risk from exposure to lead-based paint and, because their bodies are still growing, children tend to absorb more lead than adults.

• Children exposed to lead can suffer from:
  • Lowered IQ.
  • Damage to the brain and nervous system.
  • Learning and behavioral difficulties.
  • Slowed growth.
  • Hearing problems.
  • Headaches.
• Adults exposed to lead can suffer from:
  • Reproductive problems in both men and women.
  • High blood pressure and hypertension.
  • Nerve disorders.
  • Memory and concentration problems.
  • Muscle and joint pain.

Ready to become a lead-safe Certified Renovator? CLICK HERE to enroll in a Certified Renovator–Initial RRP Course and receive the training you need to perform lead-safe work practices.