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Message from the Technical Chief
New Federal Lead Paint Program
It is time to prepare for a new EPA rule which will go fully into effect on April 22, 2010. The Lead-based paint Renovation Repair and Painting Program (RRP, 40 CFR Part 745) significantly alters the compliance landscape for owners, managers and contractors. State, tribal and local programs will also have to adapt to meet or exceed the rule.
Following is a brief summary of key requirements:
Who is required to comply? Owners, managers and contractors who disturb painted surfaces in homes, apartments, schools, day-care and other child-occupied facilities built before 1978.
What must be done pre-renovation? Managers must educate occupants (effective now), and contractors must be trained, their firms must apply to the EPA for certification and workers must be trained (before April 22, 2010).
What about during renovation? The RRP rule requires that lead-based paint be identified, lead-safe work practices be used to minimize occupant and worker exposures, signage, work area preparation, dust and debris control, visual inspections, clearance activities and proper disposal of waste.
The new RRP training program supersedes previous EPA/HUD renovation training. If your workforce or your clients have been trained in previous versions of EPA/HUD renovation programs they will have to take a program to meet the requirements of the new rule.
The Environmental institute has been federally accredited for lead-based paint training for more than 10 years. We will be pursuing EPA approval to offer RRP training as soon as the process becomes available. We anticipate that the approval process will take us into late spring. Please check with us on the status of our certification, we’ll be glad to arrange a program for you or your clients as soon as we are able!
The EPA recently published an RRP Small Entity Compliance Guide. This would be a good start to understanding the new requirements. It would also be advised for those that will have to comply with this program to read the federal Register notice of the RRP rules. As always we are your source for technical assistance; please email us for links to these documents.
We look forward to seeing you in the near future!
Tom Laubenthal
March 2009
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