The What, The Why and the How to Comply with EPA’s Renovation, Repair and Painting Rule (RRP).
The what. Beginning this fall and in full speed by first quarter 2015, ALL contractors in the United States who disturb painted surfaces in pre-1978 residential and child occupied properties, will begin to be required to Re-Certify their 2010 RRP Firm Certification AND their Initial Lead Safe Renovator certification, both firm and supervisors! TIP #1: Per EPA regulation 40 CFR Part 745, if an individual DOES NOT recertify prior to their current expiration date, they will have to start the process all over. This means an initial class will have to be taken versus a refresher only. Why waste extra time and money?
Why? For several key critical reasons:
First, I truly don’t believe any contractor or maintenance worker, or other regulated entity or individual honestly wants to be responsible for poisoning a child with toxic lead. What if it was your child? Lead is a highly toxic material and whether you want to believe it or not, can have some very serious health impact if inhaled or ingested and most susceptible are young children, whose well-being is our future. So, it is part of our social, professional, and regulatory responsibilities to act in a prudent and safe fashion around lead paint and its byproducts. Secondly, there are NUMEROUS lead-based paint regulations sprinkled throughout our country. Each associated with violations, fines & penalties if not properly addressed. EPA’s RRP rule is the framework for many of them; the eighty (80)-twenty (20) rule. By being compliant with EPA’s RRP rule, you are by default approximately 80%-100% compliant with all other state and local lead-based paint laws based on my experience. But most important is the final why: CYOA, Cover Your Own Assets! Lead Paint and Lead Poisoning has been, is, and most likely will continue to be highly litigious, as will our society into the immediate future! During the last Five (5) years since you first had to comply, several major lead-based paint related developments have occurred. CDC lowered the Reference Value of a child being at risk to 5ug/dl. VERY LOW! HUD released their long overdue 2012 Guidelines for the Evaluation and Control of Lead and Lead Hazards. And Lowes Hardware was hit with a major violation inclusive of BIG monetary penalties, mandatory compliance deadlines, and subcontractor enforcement in all 1700+ stores. All other vendors will have to do the same if not already complying. So, “WHY,” is real.
How to comply with EPA’s RRP and avoid violations, penalties, litigation, guilt, time & money? Re-Fresh PRIOR to your current expiration date!! Keep accurate and clear records documenting your compliance? EPA’s enforcement is based on tips, complaints, and a few other sources. The only things they can review to document proof of compliance, or lack thereof, other than physically seeing the work with their own eyes, are the paper records required to be completed, (Owner/resident notification, check list, lead test, cleaning verification…) by the Certified Renovator. Keep good records inclusive of your CURRENT RRP compliant Lead Safe Renovator Certification and you will be in a very proactive and defendable position, isn’t that who we want to be?
By: Lee Wasserman
President/CEO LEW Corp.
Recognized in 2012 HUD Guidelines as subject reviewer, nationally respected Lead-Based Paint and Mold subject expert. …. 24 years LEW Corp.,
What concerns me the most about EPA’s Lead-Based Paint Renovation, Repair and Painting Rule, is it’s highly litigious nature and how not being properly certified. If and when the stuff hits the fan, is an instant Problem!!
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