Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children.
On April 22, 2008, EPA issued a rule requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning. Under the rule, beginning in April 2010, contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination. Until that time, HUD and EPA recommend that anyone performing renovation, repair, and painting projects that disturb lead-based paint in pre-1978 homes, child care facilities and schools follow lead-safe work practices.
There are some differences between the EPA RRP Rule and the HUD Lead Safe Housing Rule (LSHR). A major difference is that the LSHR requires clearance examinations. All housing receiving federal assistance must still comply with the LSHR. OHHLHC provides Information on complying with the LSHR and RRP, and Frequently-asked Questions from Grantees. Additional information for renovators is available.
All contractors should follow these three simple procedures:
- Contain the work area.
- Minimize dust.
- Clean up thoroughly.
From December 2008, the rule has required that contractors performing renovation, repair and painting projects that disturb lead-based paint provide to owners and occupants of child care facilities and to parents and guardians of children under age six that attend child care facilities built prior to 1978 the lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF)
Starting on April 22, 2010, the rule will affect paid renovators who work in pre-1978 housing and child-occupied facilities, including:
- Renovation contractors
- Maintenance workers in multi-family housing
- Painters and other specialty trades.
Under the rule, child-occupied facilities are defined as residential, public or commercial buildings where children under age six are present on a regular basis. The requirements apply to renovation, repair or painting activities. The rule does not apply to minor maintenance or repair activities where less than six square feet of lead-based paint is disturbed in a room or where less then 20 square feet of lead-based paint is disturbed on the exterior. Window replacement is not minor maintenance or repair.
Read EPA's Lead Renovation, Repair and Painting Program Rule.
Additional information on becoming an EPA-certified renovator or training provider is available on EPA's Renovator and Trainer Tool Box site.
Effective Dates of the Rule
|June 23, 2008
Unaccredited renovator or dust sampling technician training programs may not advertise or provide training leading to EPA certification
States, Tribes, and Territories may begin to apply for authorization
Persons performing renovations for compensation in pre-1978 child-occupied facilities (e.g., child care facilities, kindergarten and pre-kindergarten classrooms) must provide either Protect Your Family or Renovate Right to the owners and occupants before beginning renovations
Modifications/exemptions to Pre-renovation Education Rule take effect:
(1) Minor repair and maintenance exception changes to < 6 ft2 per room for interiors, 20 ft2 for exteriors. To qualify, the project cannot involve the use of high dust generating (?prohibited?) practices or window replacement.
(2) Emergency renovations specifically include interim controls performed in response to an elevated blood lead level in a child.
(3) Persons performing renovations for compensation in pre-1978 housing may use either Protect Your Family or Renovate Right to comply with the existing requirement to provide a lead hazard information pamphlet to the owners and occupants of target (pre-1978) housing before beginning renovations
|December 22, 2008
||Persons performing renovations for compensation in target (pre-1978) housing or child-occupied facilities must provide Renovate Right to the owners and occupants before beginning renovations|
|April 22, 2009
Training providers may begin applying to EPA for accreditation to provide renovator or dust sampling technician training
Persons seeking certification as renovators or dust sampling technicians may take accredited training as soon as it is available
|October 22, 2009
||Firms may begin applying to EPA for certification to conduct renovations|
|April 22, 2010
||Renovations in target (pre-1978) housing and child-occupied facilities must be conducted by certified renovation firms, using renovators with accredited training, and following the work practice requirements of the rule|