Renovation Repair Painting Renovation Repair Painting Program Rule Program Rule

40 CFR Part 74540 CFR Part 745Subpart ESubpart E

(Residential Property Renovation)(Residential Property Renovation)(epa.gov/lead)(epa.gov/lead)

WHY NOW?WHY NOW? Studies show that typical renovations create substantial amounts of Studies show that typical renovations create substantial amounts of

dust. In pre-1978 homes this creates occupant exposure to lead dust. In pre-1978 homes this creates occupant exposure to lead based paint. based paint. Approximately 41% of children under the age of 6 who Approximately 41% of children under the age of 6 who have EBL’s, live in homes that were renovated within the previous have EBL’s, live in homes that were renovated within the previous year.year.

Studies show that typical clean-up methods i.e. dust pan and broom Studies show that typical clean-up methods i.e. dust pan and broom and vacuuming are ineffective at removing existing lead dust and lead and vacuuming are ineffective at removing existing lead dust and lead dust created during construction activity. dust created during construction activity.

In 1992 Congress passed the "Residential Lead-Based Paint Hazard Reduction Act (“Title X”) and expected EPA to promulgate rules within 4 years (1996) that would govern renovation and remodeling activities to minimize the creation of lead dust. These rules were completed in 2008!

WHAT IS RRP?WHAT IS RRP? SCOPE Amends Title 40 of the Code of Federal Regulations Part 745 (40 CFR 745)

– A federal regulatory program affecting contractors, rental property owners and managers and anyone else that disturbs painted surfaces in pre-1978 units; this rule primarily impacts remodeling/home improvement contractors and rental property owners

– It applies to housing, apartments and child occupied facilities – This law presumes the presence of lead in paint unless proven otherwise

The Rule is made up of four basic parts:– Requires education of owners and occupants of “Target Housing” before work

begins– Requires firms conducting renovations on target housing to be certified and to use a

certified renovator– Requires lead safe work standards and practices be performed in order to pass

clearance– Requires adequate enforcement

When is RRP Required?When is RRP Required?

For all renovations that disturb painted For all renovations that disturb painted surfaces. Renovations include; removal, surfaces. Renovations include; removal, modification or repair including surface modification or repair including surface preparation. Renovation does not include preparation. Renovation does not include minor repair and maintenance activities that minor repair and maintenance activities that disturb 6 square feet or less of painted disturb 6 square feet or less of painted surface per room for interior activities or 20 surface per room for interior activities or 20 square feet or less for exterior activities.square feet or less for exterior activities.

Renovations for compensationRenovations for compensation

WHO IS IN CHARGE?WHO IS IN CHARGE?

Right now the EPA is administering and Right now the EPA is administering and enforcing the Ruleenforcing the Rule

EPA wants States to Administer this RuleEPA wants States to Administer this Rule Michigan is in the process of amending the Michigan is in the process of amending the

current Lead Abatement Act to include Lead current Lead Abatement Act to include Lead Abatement and Renovation. When Abatement and Renovation. When approved the Healthy Homes Section will approved the Healthy Homes Section will administer the RRP Rule.administer the RRP Rule.

““I AM A CONTRACTOR, WHAT I AM A CONTRACTOR, WHAT SHOULD I BE DOING NOW”SHOULD I BE DOING NOW”

DISTRIBUTE THE DISTRIBUTE THE CORRECT PAMPHLET!!CORRECT PAMPHLET!!

The old blue pamphlet no The old blue pamphlet no longer applies to longer applies to renovationsrenovations

Maintain a record proving Maintain a record proving that you provided the that you provided the pamphlet pamphlet

Get training – become Get training – become Certified Renovator Certified Renovator

After Oct 22, 2009 apply to After Oct 22, 2009 apply to become certified firmbecome certified firm

IMPORTANT DATESIMPORTANT DATES

After October 22, 2009 firms can start applying for EPA After October 22, 2009 firms can start applying for EPA certification to conduct renovations in Target Housingcertification to conduct renovations in Target Housing

Our website will list names of training providersOur website will list names of training providers Effective April 22, 2010 the entire rule becomes effective – Effective April 22, 2010 the entire rule becomes effective –

training, certification and work practice requirementstraining, certification and work practice requirements– Must be a certified firmMust be a certified firm– Must employ a certified renovator to oversee and manage the Must employ a certified renovator to oversee and manage the

projectproject– Must employ lead safe work practicesMust employ lead safe work practices– Must properly clean and clear the work areaMust properly clean and clear the work area– Must maintain recordsMust maintain records

““WHEN WILL THE STATE TAKE OVER?”WHEN WILL THE STATE TAKE OVER?”

Changes to the Act will take about 18 monthsChanges to the Act will take about 18 months EPA will be in charge until thenEPA will be in charge until then Once the State takes over…..Once the State takes over…..

– You will need to obtain Firm Certification You will need to obtain Firm Certification Note: the renovator firm Certification fee is waived if you are Note: the renovator firm Certification fee is waived if you are

already a Certified Lead Abatement firmalready a Certified Lead Abatement firm

– You will need to become a Certified RenovatorYou will need to become a Certified Renovator– Enforcement will be conducted by the StateEnforcement will be conducted by the State

Note: EPA wants strict enforcement of this Rule Note: EPA wants strict enforcement of this Rule

– Training and education will be conducted during Training and education will be conducted during implementation of this Rule implementation of this Rule

WORK PRACTICE STANDARDSWORK PRACTICE STANDARDS

POST SIGNS TO DEFINE THE WORK AREAPOST SIGNS TO DEFINE THE WORK AREA CONTAIN THE WORK AREA SO NO DUST OR DEBRIS CONTAIN THE WORK AREA SO NO DUST OR DEBRIS

LEAVES THE WORK AREALEAVES THE WORK AREA REMOVE OBJECTS FROM THE WORK AREA OR REMOVE OBJECTS FROM THE WORK AREA OR

COVERCOVER CLOSE WINDOWS AND DOORSCLOSE WINDOWS AND DOORS COVER THE FLOORCOVER THE FLOOR USE PRECAUSTIONS TO ENSURE THAT PERSONNEL, USE PRECAUSTIONS TO ENSURE THAT PERSONNEL,

TOOLS AND OTHER ITEMS ARE FREE OF DUST AND TOOLS AND OTHER ITEMS ARE FREE OF DUST AND DEBRIS BEFORE LEAVING THE WORK AREA. DEBRIS BEFORE LEAVING THE WORK AREA.

POST RENOVATION CLEANING AND CLEARANCEPOST RENOVATION CLEANING AND CLEARANCE

CONTACT INFOCONTACT INFO

STEVE M SMITHSTEVE M SMITH (616) 240-3926(616) 240-3926

STEVEMSMITH@PEOPLEPC.COMSTEVEMSMITH@PEOPLEPC.COM