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