National Restoration Industry Association (RIA)
EPA RRP Rule – 3 Simple Steps for full compliance.
EPA’s Renovation, Repair & Painting Rule (EPA RRP Rule) is back in full swing due to the EPA RRP Rule’s requirements for refresher training, coupled with the fact that EPA publicly announced at a meeting in Washington DC back in June that, “enforcement,” was the agenda for 2016.
Beginning this January 2016 approximately 750,000 contractors and trades will begin to refresh and recertify, as well as assure as a condition of their EPA RRP Rule’s Lead Safe Renovator Certification, that they will comply with the federal law’s requirements of Lead Safe Work Practices.
All trades who disturb pre-1978 painted surfaces for compensation, in residential & child-occupied facilities, must be an EPA certified firm according to the EPA RRP rule. In addition, they must employ an EPA Certified Lead Safe Renovator (Supervisor), according to the federal EPA RRP rule.
Accordingly, the National Restoration Industry Association (RIA) felt the EPA RRP rule was important enough of an issue that they invited a nationally recognized lead-based paint subject expert to their annual conference in Las Vegas.
Mr. Lee E. Wasserman, President of LEW Corporation, presented 3 Simple Steps for Full Compliance of EPA’s RRP Rule. This was done to educate the members of RIA on how easy it really is to comply with the rule, and the importance of the 80/20 rule, (Pareto principle).
The Pareto principle is used in occupational health and safety to underline the importance of hazard prioritization (Lead (Pb) & EPA RRP rule compliance). Assuming 20% of the lead hazards will account for 80% of the injuries, safety professionals can target those 20% of the hazards that cause 80% of the lead poisoning injuries or accidents.
At the same time, by performing 3 Simple Steps for Compliance of EPA’s RRP Rule, the contractors/trades can also protect themselves; it’s a win-win!
If you do the 3 Simple Steps consistently (20%) you will substantially minimize (80%) of the risk associated with lead-based paint & lead paint disturbances.
- Step 1. What it REALLY means to be “Certified!”
- Step 2. How to do the work the, “KISS,” (Keep It Simple Silly) way!
- Step 3. If an, “Action,” occurs, it’s all in the “Records” – Document, Document….!
Step 1. Being properly, “CERTIFIED” in accordance with the EPA RRP Rule. If you don’t have the proper federally required certifications, firm and renovator, you are negligent and liable from inception!
So, the simple first step is get your firm and supervisors properly certified on time by a qualified training provider who will be a lead EPA RRP rule resource for you into the future.
Step 2. How to do the work the, “KISS,” way. First create a checklist packet (EPA RRP rule requires one to be completed for each project).
The basic EPA RRP Rule KISS Lead Safe Work Practices (Efficient & effective) checklist for accountability & documentation of compliance should incorporate:
|1. Paper Compliance Packet||2. Checklist with Initials of Item|
|3. Renovate Right Pamphlet Distribution||4. Assess Paint (Chemical Test, Inspector/Risk Assessor, Lab Sample OR Presume Lead Paint)|
|5. Post Signs||6. Use 6ml Plastic containment|
|7. Have a HEPA Vacuum, Pre & Post||8. Remove or Cover Belongings|
|9. Contain area of Paint Disturbance||10. Turn off HVAC (if forced air)|
|11. Eliminate access to work area(s)||12. Avoid high risk activities (dry sanding/scraping)|
|13. Fold plastic dirty side in & dispose of properly||14. HEAP vacuum, Wash, HEPA Vacuum|
|15. Cleaning Verification or Dust Wipe Clearance sampling||16. Verify all completed checklist|
Step 3. It’s all in the records! If or when an enforcement action or litigation claim arise, it is going to be decided and violations and penalties assessed based on what the records and legally required documentation supports.
EPA RRP rule recordkeeping and reporting requirements can be found at 40 CFR Part 745.86. Firms performing renovations must retain and, if requested, make available to EPA, all records necessary to demonstrate compliance with this subpart for a period of 3 years, following completion of the renovation.
For a more complete list see the actual RIA 3 Simple Steps to EPA RRP Rule Compliance power point presentation: http://www.restorationindustry.org/?PastPresentations
If lead based paint is present or is presumed present, the EPA’s RRP rule requirements must be followed and documented. However, if it is determined via chemical paint test kit, laboratory paint chip sample analysis, or XRF technology that lead-based paint is not present, then the EPA RRP rule requirements do not apply!
If it is a small paint disturbance project and no children under the age of six are present, then presuming might be the most practical and economical choice. If however the paint disturbance project is more than just a door or one room, it begins to make a lot of sense to test the painted surfaces for actual lead in paint content.
The most practical, legally defensible and currently non-disputable way is either paint chip sample laboratory analysis or XRF. Do-it- yourself, very simple to use, and very affordable lab certified kits are available, “The Environmental Professional In-A-Box” series of Do-It-Yourself certified lab testing kits for lead, asbestos, mold, IAQ… can be found at www.certifiedkit.com and meet all the law’s requirements.
So, follow the 3 simple steps, be properly certified, use a checklist to document lead safe work practice compliance and make sure you record and maintain for three years the EPA RRP Rules required documentation.
If young kids are present, or the project is more than a day’s worth of work, test the painted surfaces prior to disturbing them so you know what you are dealing with and then are in the strongest position to decide how to deal with!
Written by: Lee E. Wasserman
President of LEW Corporation
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