Training Requirement Deadline Extended For Lead Renovation, Repair & Painting Rule

In April 2008, EPA issued the Lead Renovation, Repair and Painting (RRP) Rule, which required the use of lead-safe work practices in pre-1978 homes but included the opt-out provision. Subsequently, EPA issued a new rule that removes a provision from existing regulations that allowed owner-occupants of pre-1978 homes to “opt-out” of having their contractors follow lead-safe work practices if there were no children under six years of age in the home.

The RRP rule requires certification of training providers and lead-safe work practice certification for individuals involved in the construction and remodeling industry. Because of concern that contractors in some areas may be having difficulty accessing training classes, EPA recently announced that it is providing renovation firms and workers additional time to obtain training and certifications to comply with the new lead rules. EPA will not take enforcement action for violations of the rule’s firm certification requirement until October 1, 2010, and will not enforce certification requirements against individual renovation workers if they apply to enroll in certified renovator classes by September 30, 2010 and complete the training by December 31, 2010.

The agency has indicated that it will continue to take enforcement actions against renovation firms and individuals who do not comply with the RRP work practices and associated recordkeeping requirements. The lead-safe work practices include dust control, site clean up and work area containment.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.

For further information contact Caltha LLP at

info@calthacompany.com

or

Caltha LLP Website