EPA Lead Rule Goes Into Effect April 22, 2010
EPA's new "Lead Rule" takes effect April 22,
2010 requiring contractors, property managers
and others paid to renovate structures built
before 1978 to be certified by the U.S.
Environmental Protection Agency. The rule could
have a significant impact on dealers with
installed sales operations and/or their
Our NLBMDA staff recently met again with EPA
officials regarding the "Lead: Renovation,
Repair and Painting" (RRP) rule expressing
concerns over the lack of certified firms,
trained renovators, and approved test kits that
will be necessary to effectively implement the
rule without significant disruption of home
renovations throughout the U.S. According to the
EPA, their objective is to have 1,000 accredited
trainers in place before the deadline.
Currently, EPA has only 123 accredited trainers
and 6,501 certified renovators nationwide,
numbers far too insufficient for the millions of
renovations carried out annually.
Requirements for Renovation Contractors:
Certification and Training Requirements
All firms performing renovation, repair or
painting work on homes constructed prior to 1978
must become certified by the EPA. This can be
accomplished by applying to EPA or to the State,
if it has an EPA-authorized renovation program,
and paying a fee.
Firms must have one or more "Certified
Renovators" assigned to jobs where lead-based
paint is disturbed. To become certified, a
renovator must successfully complete an EPA or
State-approved training course conducted by an
EPA or State-accredited training provider.
All renovation workers must be trained.
Renovation workers can be trained on-the-job by
a Certified Renovator to use lead safe work
practices, or they can become Certified
Exemption from the RRP Rule; "Opt-out" provision
The training, certification and work practice
requirements currently do not apply where the
firm obtains a signed statement from the owner
that all of the following conditions are met:
The renovation will occur in the owner's
No child under age 6 resides there;
No woman who is pregnant resides there;
The housing is not a child-occupied
The owner acknowledges that the renovation
firm will not be required to use the work
practices contained in the rule.
Firms Engaged in Renovation Work
Firms engaged in renovation work on homes
constructed prior to 1978 that are not yet
certified and do not have certified renovators
are encouraged to start the process for securing
both as soon as possible. Certification of firms
currently takes EPA six weeks or more to process
Firm Certification/Renovator Training
Firms/contractors seeking certification
please click here for more information.
Firms/contractors seeking Certified Renovator
click here for a list of EPA-approved trainers.
to view the full EPA brochure,
Lead Safe Renovation, Repair and Painting."
Below are more websites that will
give you addition information:
Small Entity Compliance Guide. A handbook for
Page 3 is like a
checklist of what a company has to do.
EPA Facts About Lead (links to many resources)
Information for contractors
SAMPLE RENOVATION RECORDKEEPING CHECKLIST
(effective April 2010)
OSHA General Industry Lead Advisor 1.0
Are You Insured for Lead?
Don't assume that your general-liability policy
covers you in the event of a lead poisoning suit
CONTRACTOR Magazine, February 3, 2010
By Jim Cory
Imagine that your company is
suddenly hit with a civil suit. The suit is
filed under the Consumer Protection Act for
Environmental Protection Agency (EPA)
lead-paint-removal regulations. It alleges that
unsafe work practices by those in your employ
left a child severely learning-impaired. The
client seeks punitive damages and medical costs
totaling $1 million.
Unlikely? Don't bet on it. Up to
this point, lawsuits filed on behalf of those
injured by lead poisoning have had two targets:
paint and pigment manufacturers, and landlords.
Since 1987, scores of suits have been filed
against manufacturers or former manufacturers of
lead-based paint or pigment. More recently, many
suits accuse landlords of being responsible for
the effects of lead paint in the older
properties they own. For this full article go