january 29, 2014 community development. overview of the epa renovation, repair and painting rule...
TRANSCRIPT
January 29, 2014
Community Development
Overview of the EPA Renovation, Repair and Painting Rule (RRP Rule)
as it relates to the HUD Lead Safe Housing Rule and
Renovations/Repairs
EPA Renovation, Repair and Painting Rule (RRP Rule)
Authorization
For a State to become authorized, it must be at least as protective as EPA
CT is not authorized to administeror enforce RRP rule
CT DPH Provides:Compliance assistance Education/outreach Awareness training
Who Must Follow the Lead Rule’s Requirements?
Examples:
Residential rental property owners
PaintersHome Improvement
ContractorsRenovators &
RemodelersCarpentersSchool Administrators
Daycare Owners/Operators
Finishing WorkersProperty ManagersMaintenance StaffElectricians and PlumbersWindow Replacement
FirmsAnd Many Others……
What Activities Are Subject to the RRP Rule?
Remodeling and repair/maintenance, electrical work, plumbing, carpentry, etc., (for payment) that disturbs:
> 6 square feet of interior painted surfaces (per room) during projects on housing and child occupied facilities built pre-1978
> 20 square feet of painted exterior surfaces during projects on housing and child occupied facilities built pre-1978
Any window replacement (also pre-1978)
ExclusionsHousing built after 1977Certified lead free housingLead abatement projectsFull demolitionsHousing for the elderly or disabled unless a
child under 6 resides or is expected to reside there.
Zero-bedroom dwellings (studio apts., dorms).Minor repair/maintenanceEmergency renovations
HUD’s Lead Safe Housing RuleHUD’s Lead Safe Housing Rule (LSHR) is
found in HUD’s regulations at 24 CFR Part 35, Subparts B through M
Generally applies to work performed in target housing units receiving:HUD housing assistanceRehabilitation assistanceAcquisition assistance
Under LSHR, the program participant (person accepting funding) becomes responsible for compliance with federal laws
HUD’s Lead Safe Housing Rule
Stages of the JobPlanning and Set-upDuring the JobEnd of Job
HUD’s Lead Safe Housing Rule
Planning and Set-upRenovators/renovation firms must be certifiedRenovators/renovation firms must complete
curriculum in lead safe work practicesRRP course is HUD-approved
All workers and supervisors must complete a HUD approved lead safe work practice course
Renovators must hand out “Protect Your Family from Lead in Your Home” brochureRenovators should hand out “Renovate Right”
brochure
Protect Your Family brochure
EPA Renovate Right brochure
HUD’s Lead Safe Housing Rule
During the JobHUD requires lead hazards be treated using interim
controls or ongoing lead-based paint maintenanceProhibited practices
EPA Prohibited PracticesOpen flame burning or torchingHeat guns above 1100 degrees F (in CT 700
degrees F)Machine removal without HEPA vacuum attachment
HUD Prohibited PracticesDry scraping or sanding farther than 1 foot of
electrical outletVolatile stripper in poorly ventilated space
** MUST FOLLOW ALL PROHIBITED PRACTICES **
HUD’s Lead Safe Housing RuleDuring the Job
Threshold minimum amount of interior paint disturbanceHUD has a lower “de minimus” than EPAHUD’s interior
Threshold is 2 square feet per room 10% of small components
HUD’s exteriorThreshold is 20 square feet for total
exterior10% of small components
HUD’s Lead Safe Housing RuleEnd of Job
HUD requires a clearance examinationMust be done by independent partyClearance examination includes a
Visual assessment at the end of the work for deteriorated paint, dust, debris, paint chips or other residue
Clearance dust wipe tests of interior floors, window sills and window wells
Independent party must a be a licensed lead inspector/risk assessorLicensed by the State of CT Department of
Public Health
When is a DPH Licensed/Certified Professional Required?
Sampling:Paint (XRF)Paint ChipsDustSoilWater
DPH Licensed Contractors/Consultants
Lead Abatement Consultant Contractor
Lead Abatement ContractorLead Consultant ContractorLead InspectorLead Risk AssessorLead Planner/Project Designer
How to Find a Lead Inspector/Risk Assessor
Paint Chip Sampling
Sample RRP Certificate
How to Find an RRP Certified Renovator
Checklist for Lead Safe Work Practices
When is Abatement Required?
When do the HUD/DPH Requirements Trigger Abatement?
DPHChild under the age of 6 in residence
Elevated Blood Lead Level (poisoned child)A licensed professional has tested and
identified defective lead-based paintA code enforcement official has identified
defective lead-based paintAdditional dwellings in same unit with
defective lead-based paint
HUDProjects costing more than $25,000When a contract specifies lead abatement
Sample DPH License
Checklist for Lead Abatement Projects
Question and Answer