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EPA Requirements

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.
To protect against this risk, 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 April 22, 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.
EPA requires that firms performing renovation, repair, and painting projects that disturb lead-based paint in pre-1978 homes, child care facilities and schools be certified by EPA and that they use certified renovators who are trained by EPA-approved training providers to follow lead-safe work practices. Individuals can become certified renovators by taking an eight-hour training course from an EPA-approved training provider. Learn how to become an EPA certified firm and where to take a training course near you.

Beginning in December 2008, the rule requires 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) (11 pp, 1.1MB). | en español (PDF) (11 pp, 2.4MB)
The rule affects 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.
Previously, owner-occupants of homes built before 1978 could certify that no child six years of age or younger or pregnant woman was living in the home and "opt-out" of having their contractors follow lead-safe work practices in their homes. On April 23, 2010, to better prevent against lead paint poisoning, EPA issued a final rule to apply lead-safe work practices (PDF) (18 pp, 121K) to most pre-1978 homes, effectively closing the exemption. The rule eliminating the opt-out provision became effective July 6, 2010.
Read EPA's Lead Renovation, Repair and Painting rule.
View the implementation deadlines associated with the Lead Renovation, Repair and Painting rule.
EPA Authorized State Programs
EPA has the authority to authorize states, tribes and territories to administer their own RRP program that would operate in lieu of the EPA regulations. When a state, tribe or territory becomes authorized, contractors and training providers working in these areas and consumers living there should contact the appropriate state, tribal or territorial program office. Currently the following states have been authorized by EPA (note: in following these links you will be leaving the EPA Web site Exit EPA Disclaimer): Wisconsin, Iowa, North Carolina, Mississippi, Kansas, Rhode Island, Utah, Oregon and Massachusetts.
Information for States and Tribes
EPA headquarters has developed guidance documents to assist states and tribes that are applying to EPA for authorization to manage their own lead renovation, repair and painting programs (PDF) (122 pp, 257K).
Information for Property Owners of Rental Housing, Child-Occupied Facilities
Property owners who renovate, repair, or prepare surfaces for painting in pre-1978 rental housing or space rented by child-care facilities must, before beginning work, provide tenants with a copy of EPA's lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF) (11 pp, 1.1MB) | en español (PDF) (11 pp, 2.4MB). Owners of these rental properties must document compliance with this requirement; EPA's sample pre-renovation disclosure form (PDF) (1 pp, 53K) may be used for this purpose.
After April 22, 2010, property owners who perform these projects in pre-1978 rental housing or space rented by child-care facilities must be certified and must follow the lead-safe work practices required by EPA's Renovation, Repair and Remodeling rule. To become certified, property owners must submit an application for firm certification (PDF) (9 pp, 642K) and fee payment to EPA. EPA began processing applications on October 22, 2009. The Agency has up to 90 days after receiving a complete request for certification to approve or disapprove the application.
Property owners who perform renovation, repairs, and painting jobs in rental property should also:

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Information for Homeowners Working at Home
If you are a homeowner performing renovation, repair, or painting work in your own home, EPA's RRP rule does not cover your project. However, you have the ultimate responsibility for the safety of your family or children in your care. If you are living in a pre-1978 home and planning to do painting or repairs, please read a copy of EPA's Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF) lead hazard information pamphlet (11 pp, 1.1MB). | en español (PDF) (11 pp, 2.4MB). You may also want to call the National Lead Information Center at 1-800-424-LEAD (5323) and ask for more information on how to work safely in a home with lead-based paint.
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Information for Tenants and Families of Children under Age 6 in Child Care Facilities and Schools
As a tenant or a parent or guardian of children in a child care facility or school, you should know your rights when a renovation job is performed in your home, or in the child care facility or school that your child attends.

  • Before starting a renovation in residential buildings built before 1978, the contractor or property owner is required to have tenants sign a pre-renovation disclosure form (PDF) (1 pp, 53K), which indicates that the tenant received the Renovate Right lead hazard information pamphlet.
  • Beginning in December 2008, the contractor must also make renovation information available to the parents or guardians of children under age six that attend child care facilities and schools, and to provide to owners and administrators of pre-1978 child care facilities and schools to be renovated a copy of EPA's Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF) lead hazard information pamphlet (11 pp, 1.1MB) | en español (PDF) (11 pp, 2.4MB).

Information for Contractors
As a contractor, you play an important role in helping to prevent lead exposure. Ordinary renovation and maintenance activities can create dust that contains lead. By following the lead-safe work practices, you can prevent lead hazards.
Contractors who perform renovation, repairs, and painting jobs in pre-1978 housing and child-occupied facilities must, before beginning work, provide owners, tenants, and child-care facilities with a copy of EPA's lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF) (11 pp, 1.1MB) | en español (PDF) (11 pp, 2.4MB). Contractors must document compliance with this requirement; EPA's pre-renovation disclosure form (PDF) (1 pp, 53K) may be used for this purpose.
Understand that after April 22, 2010, federal law requires you to be certified and to use lead-safe work practices. To become certified, renovation contractors must submit an application and fee payment to EPA.

EPA began processing applications on October 22, 2009. The Agency has up to 90 days after receiving a complete request for certification to approve or disapprove the application.
Contractors who perform renovation, repairs, and painting jobs should also:

  • Take training to learn how to perform lead-safe work practices.
    • Find a training provider that has been accredited by EPA to provide training for renovators under EPA's Renovation, Repair, and Painting (RRP) Program.
    • Please note that if you previously completed an eligible renovation training course you may take the 4-hour refresher course instead of the 8-hour initial course from an accredited training provider to become a certified renovator. Click here for a list of eligible courses.
  • Provide a copy of your EPA or state lead training certificate to your client.
  • Tell your client what lead-safe methods you will use to perform the job.
  • Learn the lead laws that apply to you regarding certification and lead-safe work practices beginning April 22, 2010.
  • Ask your client to share the results of any previously conducted lead tests.
  • Provide your client with references from at least three recent jobs involving homes built before 1978.
  • Keep records to demonstrate that you and your workers have been trained in lead-safe work practices and that you follow lead-safe work practices on the job. To make recordkeeping easier, you may use the sample recordkeeping checklist (PDF) (1 pg, 83K) that EPA has developed to help contractors comply with the renovation recordkeeping requirements that took effect April 22, 2010.
  • Read about how to comply with EPA's rule in the EPA Small Entity Compliance Guide to Renovate Right (PDF) (32 pp, 5.5MB) | en español (PDF) (34 pp, 1.3MB).
  • Read about how to use lead-safe work practices in EPA's Steps to Lead Safe Renovation, Repair and Painting (PDF) (36 pp, 878K) | en español (PDF) (36 pp, 1.5MB).

NOTE: Contractors and training providers working in Wisconsin, Iowa, North Carolina, Mississippi, Kansas, Rhode Island, Utah, Oregon and Massachusetts must contact the state to find out more about its training and certification requirements. These states are authorized to administer their own RRP programs in lieu of the federal program. In following the above links you will leave the EPA Web site. Exit EPA Disclaimer
Contractors should also read the EPA Enforcement Alert newsletter titled Compliance with New Federal Lead-Based Paint Requirements (PDF) (4 pp, 120K).
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Fee Rule
On March 20, 2009, EPA issued a final rule to establish fees for the new Lead Renovation, Repair and Painting rule. The rule establishes fees that are charged for training programs seeking accreditation, for firms engaged in renovations seeking certification, and for individuals (for example, risk assessors) or firms engaged in lead-based paint activities seeking certification. The rule applies only in those states and tribes without their own authorized lead programs. The rule also modifies and lowers fees for the Lead-based Paint Activities regulations. The fees were developed as required by section 402 of the Toxic Substances Control Act (TSCA) to recover the cost of administering and enforcing the law's requirements. Read EPA's fact sheet on the final rule.
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Information for Training Providers
Training Provider Application and Instructions (PDF) (13 pp, 1.1M) - Training providers applying for accreditation must submit a completed application and fee payment as described in the application instructions. The following list contains key information required in the application:

  • Training program's name, address, and telephone number;
  • A list of courses that the training program is applying for accreditation;
  • Statement certifying that the training program meets the requirements established by 40 CFR 745.225(c);
  • Statement certifying the basis of the training curriculum (EPA approved or non-approved - if non-approved then include a course agenda and copies of the student and instructor manuals;
  • A description of the training facilities and hands-on equipment used during training;
  • A copy of the course test;
  • A description of the activities and procedures that will be used to assess the skills associated with the hand-on component of the course;
  • A copy of the quality control plan as required by 40 CFR 745.225(c)(9).

Instructions for Accredited Training Providers - This document provides EPA accredited renovator and dust sampling technician training providers instructions regarding:

  • Certificate requirements and numbering protocol
  • How to notify EPA of training activities
  • Eligibility requirements for refresher training
  • Instructions for digital photograph submission
  • Recordkeeping requirements
  • Cleaning verification cards

Renovation, Repair and Painting Rule Courses - These courses were developed by the U.S. EPA, in collaboration with the U.S. Department of Housing and Urban Development (HUD), to train renovation, repair, and painting contractors and dust sampling technicians on how to comply with EPA's Renovation, Repair, and Painting (RRP) rule, and HUD's Lead Safe Housing rule. The Agency will not be developing a model Dust Sampling Technician refresher training at this time.
Cleaning Verification Cards. Trainers can obtain copies of the Cleaning Verification Cards by contacting the National Lead Information Center at 1-800-424-LEAD (5323).
NOTE: Contractors and training providers working in Wisconsin, Iowa, North Carolina, Mississippi, Kansas, Rhode Island, Utah, Oregon and Massachusetts must contact the state to find out more about its training and certification requirements. These states are authorized to administer their own RRP programs in lieu of the federal program. In following the above links you will leave the EPA Web site. Exit EPA Disclaimer
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Information for Lead Test Kit Vendors
Lead Test Kits - Read about EPA-recognized lead test kits and the Agency's effort to evaluate the effectiveness of lead test kits.
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Information for Realtors and Property Management Firms
Realtors and property managers should make themselves aware of the requirements in the Lead Renovation, Repair and Painting (RRP) Rule. EPA is working closely with the National Association of Realtors to make realtors and property managers aware of the hazards of lead paint poisoning and ways to prevent it, and the association has developed a series of guidance videos aimed at realtors and property managers:

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Related Notices, Final and Proposed Rules, and Background Information on EPA's Lead Renovation, Repair and Painting Program Rule
Read EPA's July 15, 2009, Federal Register notice announcing a final rule to make minor revisions to the Renovation, Repair and Painting Program Rule. Read summary information on the final rule relating to requirements for training providers to submit photos of trainees.




   
   

 

 


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