From: U.S. EPA <usaepa@govdelivery.com>
Date: Fri, 9 Sep 2011 10:00:00 -0500 (CDT)
Subject: Lead RRP Update: Summary of Revisions to RRP rule (Part 1)
In 2008, EPA issued the Renovation, Repair, and Painting (RRP)
rule. Since then, the rule has been
amended several times, most significantly in May 2010 and in July 2011. This message provides a summary of the
most significant changes to the RRP rule.
The changes listed below are those most relevant to certified renovators
and renovation firms (and, by extension, to the training providers who instruct
them). Our next message will include
changes most relevant to the training providers themselves. For more detailed information and a
more complete set of changes, please refer to the rule and amendments at
http://epa.gov/lead/pubs/rrp.htm.
Changes from the 2010 revision are effective now. Changes from the 2011 revision will be
effective as of October 5, 2011.
No “opt-out” provision (2010 revision)
• The opt-out provision (which allowed a renovation
firm to “opt out” of the some of the RRP requirements where the firm obtained a
certification from the owner-occupant of a residence that no child under age 6
or pregnant woman resides in the home and the home is not a child-occupied
facility) has been removed and is no longer in effect.
Required information for owners and occupants
(2010
revision)
• Renovation firms must provide a copy of records demonstrating
compliance with the training and work practice requirements of the RRP rile to
the owner and occupant of the housing, and operator of the child-occupied
facility, in a short, easily-read checklist or other form. A sample checklist for these items can
be found at
http://epa.gov/lead/pubs/samplechecklist.pdf, but firms may develop their
own forms or checklists as long as all of the required information is included.
Paint chip sample collection and related records (for purposes of
determining whether components are free of lead-based paint (as defined by
statute)) (2011 revision)
• Starting on October 5, 2011, certified renovators may collect
paint chip samples from components to be affected by a renovation as an
alternative to using EPA-recognized test kits to test the paint, as previously
allowed. If paint chip samples are taken, they must be sent to a laboratory
recognized by NLLAP for analysis (see
http://epa.gov/lead/pubs/nllaplist.pdf).
Prior to the effective date of the rule, EPA will be making information
available to certified renovators on how to take paint chip samples.
• If paint chip samples are collected, those records (description of the components that were tested including
their locations, name and address of the NLLAP-recognized entity performing the
analysis, and results for each sample) must be
prepared by a certified renovator and maintained for three years, as already
required for other records.
Vertical containment (2011 revision)
• Vertical containment means a vertical barrier consisting of
plastic sheeting or other impermeable material over scaffolding or a rigid
frame, or an equivalent system of containing the work area. Vertical containment
is required for some exterior renovations but it may be used
on any renovation.
Interior renovations
•
Renovation firms may erect vertical containment for interior renovations. This allows renovation firms to erect
vertical containment closer to the renovation activity than the minimum floor
containment distance specified in the RRP rule, to give renovation firms more
flexibility in designing effective containment strategies for particular work
sites.
• Interior floor containment measures may stop at the edge of the
vertical barrier when using a vertical containment system consisting of
impermeable barriers that extend from the floor to the ceiling and are tightly
sealed at joints with the floor, ceiling and walls.
Exterior renovations
•
If the renovation will affect surfaces within 10 feet of the property line, the
renovation firm must erect vertical containment or equivalent extra precautions
in containing the work area to
ensure that dust and debris from the renovation does not contaminate adjacent
buildings or migrate to adjacent properties. Vertical containment or equivalent
extra precautions in containing the work area may also be necessary in other
situations in order to prevent contamination of other buildings, other areas of
the property, or adjacent buildings or properties.
• In
addition, renovation firms may erect vertical containment for other exterior
renovations. This allows renovation
firms to erect vertical containment closer to the renovation activity than the
minimum ground containment distance specified in the RRP rule, to give
renovation firms more flexibility in designing effective containment strategies
for particular work sites.
• Exterior ground containment measures may stop at the edge of the
vertical barrier when using a vertical containment system.
HEPA
vacuums
(2011 revision)
• HEPA vacuum cleaners must be designed so that all
the air drawn into the machine is expelled through the HEPA filter with none of
the air leaking past it. HEPA
vacuums must be operated and maintained in accordance with manufacturer’s
instructions.
• The use of machines designed to remove paint or other surface coatings
through high speed operation such as sanding, grinding, power planing, using a
needle gun, abrasive blasting, or sandblasting, is prohibited on painted
surfaces unless such machines have shrouds or containment systems and are
equipped with a HEPA vacuum attachment to collect dust and debris at the point
of generation. Machines must be operated
so that no visible
dust or release of air occurs outside the shroud or containment system.
Doreen Cantor Paster
Associate Chief, Lead, Heavy Metals, & Inorganics Branch
Office of Chemical Safety and Pollution Prevention
U.S. Environmental Protection Agency (7404T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Phone: 202-566-0486
Email: cantor.doreen@epa.gov