Archive for the ‘EPA RRP Rule Updates and Revisions’ Category

Lead RRP Update: Improved RRP Firm Search Tool and Other Web Updates

Posted on: November 12th, 2011 by support@rrphelpforcontractors.com No Comments

EPA has improved and updated its search tool for EPA-certified RRP firms, allowing the public to search by firm name, as well as by location. You can find the search tool at http://cfpub.epa.gov/flpp/searchrrp_firm.htm. EPA-certified firms should encourage their potential customers to use this search tool to check the certification status of firms they are considering hiring.

 

In addition, EPA has updated its database of Frequent Question (FQ) about the RRP Rule to reflect recent regulatory changes that took effect on October 5, 2011. The searchable database is located at http://toxics.supportportal.com/link/portal/23002/23019/ArticleFolder/615/. In addition to the database, you can also find a searchable pdf version of the FQs at http://epa.gov/lead/pubs/rrp-faq.pdf.

 

Finally, EPA has issued a fact sheet describing how provisions of the RRP rule apply to repairs and renovations done in response to natural disasters such as floods and hurricanes. It is posted on EPA’s website at http://epa.gov/lead/pubs/rrp-disaster-fact-sheet.pdf.

 

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


Updated Compliance Assistance and Educational Materials for RRP Rule

Posted on: October 8th, 2011 by support@rrphelpforcontractors.com No Comments

The most recent amendments to the RRP regulation became effective on October 4, 2011. The regulations and associated guidance documents can be found on our webpage at http://epa.gov/lead/pubs/renovation.htm.

As a result of these amendments, EPA has updated compliance assistance and education materials relating to various aspects of the RRP program. These updated materials include:

New Version of Renovate Right Required

Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools

http://epa.gov/lead/pubs/renovaterightbrochure.pdf

Renovators must now begin providing this revised version to owners and occupants. However, you may use the older version if you have printed stock remaining. In that case, please be sure to include the replacement page 10 which can be found at http://epa.gov/lead/pubs/insert.pdf.

Compliance Assistance Tools for Renovators, Firms, and Training Providers:

Steps to a Lead-Safe Renovation Guide

            http://epa.gov/lead/pubs/steps.pdf

Small Entity Compliance Guide to Renovate Right: EPA’s Lead-based Paint Renovation, Repair and Painting Program

http://epa.gov/lead/pubs/sbcomplianceguide.pdf

Paint Chip Sample Collection Guide

http://epa.gov/lead/pubs/paintchip.pdf

Sample Renovation Recordkeeping Checklist

http://epa.gov/lead/pubs/samplechecklist.pdf

Renovation Firm Application for Certification Form and Instructions

http://epa.gov/lead/pubs/firmapp.pdf

Compliance Assistance and Education Materials for Accredited Training Providers Only:

Training Provider Application for Accreditation Form and Instructions

http://epa.gov/lead/pubs/trainapp.pdf

Instructions for Accredited Training Providers

http://epa.gov/lead/pubs/trainerinstructions.htm

Renovator Initial Certification Course Materials (source files) – Student, Instructor

http://epa.gov/lead/pubs/epahudrrmodel.htm

Renovator Refresher Certification Course Materials (source files) – Student, Instructor

http://epa.gov/lead/pubs/epahudrrmodel_refresher.htm

As a reminder, currently 12 states are authorized to have their own RRP program in lieu of the EPA Federal program. These states are Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin. If you are operating in any of these states, be sure you are certified by that state and comply with those regulations. If you do business in more than one state, you may need both EPA and state certification. For more information on EPA and State programs, go to http://www.epa.gov/opptintr/lead/pubs/lscp-renovation_firm.htm.

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

Lead RRP Update: Summary of Revisions to RRP Rule (Part 2: Updates for Training Providers)

Posted on: October 5th, 2011 by support@rrphelpforcontractors.com No Comments

EPA issued the Renovation, Repair, and Painting (RRP) rule in 2008, and has amended it several times, most significantly in May 2010 and in July 2011.  Listed below are changes to the RRP rule that are particularly relevant to training providers.  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.

Documentation of personnel qualifications

• Training programs must submit names and documentation demonstrating qualifications of the education, training, and work experience of the training manager and any principal instructor(s) with their applications for accreditation and re-accreditation. (§745.225(b)(1)(iii) and (iv), §745.225(e)(5)(iii) and (iv), and §745.225(f)(3)(iii) and (iv))

Submission of training course materials

• Unless the training program uses EPA-recommended model training materials, a training provider must submit a copy of its training course materials with its application for accreditation for review by the Agency in order to become accredited. Note that training providers using material from authorized States or Indian Tribes must also submit those materials. (§745.225(b)(1)(vi))

 Accreditation amendments

• Training providers must amend their accreditation application within 90 days of the date a change occurs, by submitting a signed application form, whenever there is a change to the information presented in their most recent accreditation or re-accreditation application. If the training provider does not amend its most recent accreditation application within 90 days of the date the change occurs, it must stop providing training until the accreditation application is amended. (§745.225(j)(1))

• EPA will now have a 30 day period to review accreditation amendment applications that include a new training program manager, new principal instructor, or new permanent training location. (§745.225(j)(3))

• Training providers must not provide training under a new training manager or offer courses taught by any new principal instructor until 30 days after an amendment application is submitted for the change, unless EPA approves the amendment earlier.  However, new training managers or principal instructors already approved under another EPA training program accreditation may be used on an interim basis during the 30 day EPA review period. (§745.225(j)(3))

• Training providers may use new permanent training locations on an interim basis during the 30 day EPA review period. (§745.225(j)(3)(ii))

• No fee will be charged for accreditation amendments. (§745.238(c)(5))

Role of principal instructor

• Principal instructor(s) are primarily responsible for teaching the course materials and must be present to provide instruction (or oversight of portions of the course taught by guest instructors) for the course for which he has been designated the principal instructor. (§745.225(c)(3))

 Training topics

• Renovator instruction must include procedures for collecting a paint chip sample and sending it to a laboratory recognized by EPA under section 405(b) of TSCA. (§745.225(d)(6)(v))

Hands-on training topics

• Renovator instruction must include hands-on training in using test kits, renovation methods that minimize creation of dust and lead-based paint hazards, interior and exterior containment and cleanup methods, and cleaning verification. (§745.225(d)(6))

• Dust sampling technician instruction must include hands-on training in dust sampling methodologies and report preparation. (§745.225(d)(7))

• All refresher courses (except project designer) must include hands-on training. (§745.225(e)(2))

E-learning

• Requirements for electronic learning (“E-learning”) and other alternative course delivery methods are now specifically included.  Details are included in the regulation.  Training providers must assign a unique identifier to each student.  E-learning or other alternative delivery methods cannot be used for the hands-on training, the final course test, or the proficiency test, if one is given. (§745.225(c)(6)(viii))

 Trainee photograph requirements

• Photographs on course completion certificates must be an accurate and recognizable image of the individual and not smaller than one square inch in size when reproduced on the certificate. (§745.225(c)(8)(vii))

Training provider recordkeeping

• For renovator and dust sampling technician refresher courses, training programs must maintain a copy of each trainee’s prior course completion certificate showing that each trainee was eligible to take the refresher course.  (§745.225(i)(1)(viii))

• For all courses delivered in electronic format, training programs must maintain records of each student’s log-ins, launches, progress, and completion, and a copy of the electronic learning completion certificate for each student.  (§745.225(i)(1)(ix))

• The recordkeeping period for records associated with renovator and dust sampling technician courses was increased.  Records for renovator or dust sampling technician courses completed before April 22, 2010 must be kept until July 1, 2015.  Records for renovator and dust sampling technician courses offered on or after April 22, 2010 must be kept for a minimum of 5 years. (§745.225(i)(2))

 

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

Lead RRP Update: Summary of Revisions to RRP Rule (Part 1)

Posted on: October 5th, 2011 by support@rrphelpforcontractors.com No Comments

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

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