RRP - Extension From EPA Until October for Certification

Extension to October
SUBJECT: Further Implementation Guidance for the Renovation Repair and Painting Rule

The purpose of this memorandum is to provide supplemental guidance to the Regions on enforcement of the Renovation, Repair and Painting Rule (RRP Rule) and the Amendment to the Opt-out and Recordkeeping Provisions in the Renovation, Repair, and Painting Program. Since the RRP Rule became effective on April 22, 2010, concerns have been raised by the regulated community regarding difficulties experienced in obtaining the rule required firm certification and renovation worker training.

Acknowledging those concerns and to facilitate the transition to full implementation ofthe RRP Rule, EPA will offer additional and sufficient time for renovation firms and workers to obtain the necessary training and certifications to comply as follows:

• Until October 1, 2010, EPA will not take enforcement action for violations of the RRP Rule's firm certification requirement.
• For violations of the RRP Rule's renovation worker certification requirement, EPA will not enforce against individual renovation workers if the person has applied to enroll in, or has enrolled in, by not later than September 30, 2010, a certified renovator class to train contractors in practices necessary for compliance with the final rules. Renovators must complete the training by December 31, 2010.

In view of the paramount importance of ensuring that all contractors follow the lead-safe work practices in the RRP rule, EPA will continue to enforce the work practice requirements in the rule which protect children and reduce lead exposure. Information concerning lead-safe work practices can be found at:
http://www.epa.gov/lead/pubs/renovation.htm#requirements.

EPA issued the Lead RRP rule because a disturbing number of America's children are still poisoned by lead-based paint in their homes-leading to learning and behavioral disorders. EPA considers the certification and training requirements important to ensure that firms are protecting children and other residents while renovations are on-going. Information about training is easily accessible on EPA's web site at:
http://www.epa.gov/lead/pubs/training.htm.

To date, these training providers have offered more than 15,000 classes and trained 300,000 people. The Agency believes, however, that allowing additional time for firms and individuals to obtain that training and certification will facilitate compliance with the rule. The Agency appreciates the many unique challenges around the country, including numerous disaster declarations, and is committed to encouraging additional training opportunities in every state in order to meet the demand for classes.

Thank you for your continued focus on implementation of this important rule.

EPA Office of Enforcement And Compliance Assurance

Effective July 9, 2010, the Division of Occupational Safety promulgated amendments to 454 CMR 22.00 (Deleading and Lead-Safe Renovation), and, in conjunction with the Executive Office for Administration and Finance, amendments to 801 CMR 4.02 454 (16) and (18) (Licensing Fees for Lead-Safe Renovation Contractors and Lead-Safe Renovator Training Providers).  The amended version of 454 CMR 22.00 can be viewed here.  The amendments to 801 CMR 4.02 454 (16) and (18) change the licensing fee and surcharges for Lead-Safe Renovation Contractors from $575 for a one-year license to $375 for a five-year license, and waive the $1,775 annual fee for Lead-Safe Renovator Training Providers if they are a State, federally recognized Indian Tribe, local government or non-profit organization.

These amendments, which establish safety standards for renovation, repair and painting work that disturbs lead paint in target housing and child-occupied facilities built before 1978, parallel similar federal EPA requirements that became effective on April 22, 2010 under the “Renovation, Repair and Painting Rule” (RRP Rule), 40 CFR 745.80-92. The amendments to 454 CMR 22.00 are designed to be as protective of human health and the environment as the federal standard.  Effective July 9, 2010, DOS received authorization from EPA to administer and enforce the lead safety standards for renovation, repair and painting work set forth in 454 CMR 22.00, in lieu of the federal standard being enforced by EPA in Massachusetts.

• View or print lead license applications by clicking HERE.

• View RRP-related FREQUENTLY ASKED QUESTIONS by clicking HERE.

• View or print one-page bulletin in PDF format:
  "Renovation, Repair and Painting (RRP) Regulations in Massachusetts: Information for Contractors"

• View a comparison of EPA and DOS RRP Rule Requirements by clicking HERE.

Millions of U.S. homes still have lead paint somewhere in them. In Massachusetts it estimated that 90% of the homes were built before 1978 and only 17% of those homes have been inspected for lead paint.

Here are some very important reasons why you should have your home inspected: