The U.S. Environmental Protection Agency (EPA) set new rules for certain contractors who renovate or repair housing, child-care facilities or schools built before 1978. Workers must follow lead-safe work practice standards to reduce potential exposure to dangerous levels of lead during renovation and repair activities.
EPA's "Lead Renovation, Repair and Painting Program" (RRP) rule takes full effect on April 22, 2010. Specifically, the requirements apply to renovation, repair or painting activities where more than six square feet of lead-based paint is disturbed in a room or where 20 square feet of lead-based paint is disturbed on the exterior. The affected workers include builders, painters, plumbers and electricians, for example.
Requirements
The current RRP requirements require paid contractors and maintenance professionals to be trained and certified on certain mandated lead-safe work practices before renovating or repairing housing
and facilities for children built before 1978. AGC contractors need to be focused on the following compliance dates:
- December 2008 - Pre-renovation education requirements took effect on December 22, 2008, and require workers to distribute an EPA educational pamphlet called Renovate Right to occupants, post signs and retain records for three years; and
- April 2010 - Training, certification, and work practice requirements take effect on/after April 22, 2010.
As of April 22, 2010, the rule will be fully implemented.
The
Federal Register cite is 73 FR 21691-21769, April 22, 2008 - online at
http://www.epa.gov/fedrgstr/EPA-TOX/2008/April/Day-22/t8141.htm and
http://edocket.access.gpo.gov/2008/pdf/E8-8141.pdf. The final rule (codified at 40 CFR Part 745, Subpart E) became effective on June 23, 2008; however, within the regulatory text you will the compliance/effective dates listed above (see "Section 745.81 - Effective Dates").
Compliance Assistance
AGC has distributed news articles (as in previous Building Material
articles) to chapters and members explaining the legal requirements and contractor responsibilities, and we've encouraged AGC Chapters to consider becoming
accredited training providers (
http://newsmanager.commpartners.com/agcmmq/issues/2010-01-11/7.html).
An EPA compliance guide is available at
http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf. EPA also issued an Enforcement Alert in January 2010, available
here. For copies of the educational brochures on this new program, call 1-800-424-LEAD.
Expansion of Lead Paint Requirements?
A recent article run in the March issue of
Building Material explains that EPA is currently considering whether or not to expand and strengthen requirements of the 2008 Lead
RRP rule to cover renovations of both the exteriors and the interiors of
all public and commercial buildings. Please click
here for the article.
For more information on EPA's lead program, visit
http://www.epa.gov/lead.
