If you thought adapting to the ever changing VOC laws was a challenge to your business, welcome to a new regulation covering lead-based paints and other lead-based coatings. The EPA’s Lead Renovation, Repair, and Painting Program will take effect later this month, on April 22.

This program is a federal regulation that affects a wide range of professionals who disturb painted surfaces during remodeling/repair maintenance, electrical work, plumbing, painting, carpentry, window replacement and other activities. It affects people including contractors, property managers, carpenters, painters, plumbers and electricians.

The regulation applies to residential houses, apartments, and child occupied facilities such as schools and day care centers built before 1978, and includes pre-renovation requirements as well as training, certification, and work practice requirements.

In general, the new regulation will affect anyone who is paid to perform work that disturbs paint in housing and child occupied facilities built before 1978. This may include but is not limited to: Residential rental property owners/managers; general contractors; special trade contractors, including: painters, plumbers, carpenters, and electricians.

Therefore, any activity that disturbs paint in pre-1978 housing and child occupied facilities, including: remodeling/repair/maintenance; electrical work; plumbing; painting; carpentry; and window replacement.

Here’s what you need to do to prepare yourself for the April 22 implementation: Your firm must be certified and renovators must be trained; and your renovators (crews) must be either certified renovators or trained by a certified renovator. The program requires companies to keep records of their activity and retain these records for three years.

This article is only a brief review of the Lead Renovation, Repair and Painting Program and is not intended to be your only source for compliance of this new program. For more information, visitwww.epa.gov/lead/pubs/renovation.htm.


REGULATORY ALERT

Concerning Implementation of
U.S. EPA’S 2008 LEAD RENOVATION,
REPAIR AND PAINTING PROGRAM

A federal regulation designed to protect against the risk of exposure to lead dust and chips from lead-based paint and other lead-based coatings disturbed by renovation activities will take effect beginning on April 22, 2010.

Contractors performing renovation, repair and painting projects that disturb lead-based paint or other lead-based coatings in homes, child care facilities and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination. This includes wood flooring contractors.

In order to understand your potential obligations under this new rule, refer towww.epa.gov/lead/pubs/renovation.htm.


NOTE:The EPA has the authority to authorize states, tribes and territories to administer their own RRP program that would operate in lieu of the EPA regulations. Contractors, training providers and consumers in these areas should contact the appropriate state, tribal or territorial program office. Currently the following states have been authorized by the EPA: Wisconsin, Iowa, North Carolina, Mississippi, Kansas, Rhode Island and Utah. For more information, visitwww.epa.gov/lead/pubs/renovation.htm#authorized.