LEAD RENOVATION, REPAIR AND PAINTING (RRP) RULE

The The United States Environmental Protection Agency’s (“EPA”) Lead Renovation, Repair and Painting (RRP) Rule requires each firm to be certified, to have at least one certified renovator and for the remainder of employees involved in renovation activities to either also be certified renovators or be trained on the job by a certified renovator.

FEDERAL LAW

Federal law requires that a “certified renovator” be assigned to each job, and that all involved
individuals are trained in the use of lead-safe work practices.

  • To become a certified renovator, a person must complete a renovator training course
    accredited by EPA or an EPA-authorized program.
  • All remaining individuals must also be trained. They can either be certified renovators
    (meaning they successfully completed the accredited training) or they can have been
    trained on the job by a certified renovator.

CERTIFIED RENOVATOR RESPONSIBILITIES

Certified renovators are responsible for ensuring overall compliance with the RRP Program’s
requirements for lead-safe work practices at renovations they are assigned.

A certified renovator:

  • Must provide on-the-job training to other workers (who have not taken the certified
    renovator training course) on the lead-safe work practices to be used in performing their
    assigned tasks.
  • Must be physically present at the worksite when warning signs are posted, while the
    work-area containment is being established and while the work-area cleaning is
    performed.
  • Must regularly direct work being performed by other individuals to ensure that lead-safe
    work practices are being followed, including maintaining the integrity of the containment
    barriers and ensuring that dust or debris does not spread beyond the work area.
  • When requested by the party contracting for renovation services, must use an EPA-
    recognized test kit or must collect paint chip samples, submit them to an EPA-recognized
    laboratory, and obtain test results from the laboratory to determine whether components
    affected by the renovation contain lead-based paint. Note: you must assume lead-based
    paint is present for housing and buildings covered by the RRP Rule, unless testing is done
    that determines the components affected are lead-free.
  • Must be available, either on-site or by telephone, at all times renovations are being
    conducted.
  • Must perform project cleaning verification.
  • Must have with them at the worksite copies of their initial course completion certificate
    and their most recent refresher course completion certificate.
  • Must prepare required records.