What You Need to Know about the LRRP RuleOctober 30th, 2015 by Casey Flores
A violation from the Environmental Protection Agency (EPA) is never a good thing for a company. Luckily, their representatives know that and hosted a webinar on how to avoid one —particularly regarding the Lead Renovation, Repair and Painting Rule (LRRP).
Cindy Cook of the EPA laid out exactly who is affected by the rule and how remodelers should handle lead-based paint structures in accordance with the guidelines.
Any home built prior to 1978 (aka target housing) has lead-based paint on it. Specifically, the rule, which requires renovators to be certified by the EPA to handle such structures, applies to firms or individuals working on target housing.
How to Comply
There are various ways to comply with the rule.
All firms doing such renovations need to be certified, with at least one individual who’s certified on site during key parts of the job. The other workers must have been trained by the individual certified, and that training must be documented.
To comply as a certified firm:
- Firms must submit an application and fee to the EPA ($300, epa.gov/getleadsafe);
- Their certifications are good for five years; and
- This allows the firm to perform renovations in any non-authorized state or Indian tribal area.
To comply as an individual:
- They must take 8-hour accredited training course;
- The certificate is the certification (there is no application necessary);
- They must do refresher training required every five years; and
- Other workers do not need certification, just on-the-job training, which needs to be documented.
In order to become a trainer, you must:
- Submit an application and fee to the EPA;
- Be re-accredited every four years;
- Courses taught must be eight hours, with two hours of hands-on; and
- Training providers must notify EPA of individuals who complete the training and maintain the records for five years.
Firm responsibilities for renovations:
- All workers must be certified renovators or trained by one;
- One certified worker is assigned to each renovation and performs all responsibilities; and
- Make sure that record-keeping requirements are met.
- Perform project cleaning verification and directing workers;
- Provide training to workers on the work practices they will be using;
- Certified individual needs to be physically present at the work site:
- When warning signs are posted;
- While containment is being established; and
- While the work area cleaning is performed.
- Be available on-site or by phone at all times while renovations are being conducted;
- Use an EPA-approved test kit if lead-based paint is present;
- Carry copies of their initial course completion certificate; and
- Prepare required records.
General work practice standards:
- Post signs defining the work area;
- Isolate the work area so no visible dust or debris can leave the area; and
- Exterior may require vertical containment if the renovation surfaces will affect within 10 feet of property line.
- Remove or cover all objects in the work area;
- Close and cover all ducts in work area;
- Close or cover all doors and windows in work area;
- Cover the floor surface with plastic sheeting at least six feet in all directions; and
- Ensure all personnel, tools and other items are free of dust and debris when leaving the work area.
- Wipe with wet cloth until it’s clean
- Retain them for three years after renovation;
- Include reports certifying lead-based paint is not present; and
- Get records required by pre-renovation education rule:
If these guidelines aren’t followed, EPA enforcement can crack down on firms—which can come at a tremendous cost.
EPA can “suspend, revoke or modify a firm’s certification if the firm is found to be in non-compliance,” Cook said.
Companies can face civil and criminal penalties up to $37,500 each.
Since 2010, the EPA received 600 tips in the mid-Atlantic region alone, did 310 inspections and 56 did formal enforcement actions, as well as numerous informal ones such as warnings.
The agency tends to see people not employing the right work practices, keeping records or training correctly.
To learn more about how to comply with the LRRP Rule, see the EPA’s website devoted to the topic here.