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COMPLYING WITH EPAís NEW RENOVATION, REPAIR & PAINTING RULE

National Apartment Association


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What is the EPA’s New Renovation, Repair and Painting Rule?

 The U.S. Environmental Protection Agency (EPA) published its Renovation, Repair and Painting Rule (40 CFR 745.80 through 745.91) in the Federal Register on April 22, 2008. This new Rule is the last major initiative to come out of the Federal Lead-Based Paint Hazard Reduction Act of 1992, also known as Title X.

When Does the Rule Take Effect?

The Rule, which was promulgated under the authority of Section 402(c)(3) of the Toxic Substances Control Act, becomes fully effective on April 22, 2010. It applies to all renovations performed for compensation in pre-1978 target housing and in child-occupied facilities, and requires owners and occupants of these housing units and facilities to receive information on lead-based paint hazards before renovations can begin. 

In the first year alone, EPA estimates that approximately 8.4 million renovation events will be impacted by the Rule's requirements. EPA also estimates that 210,000 organizations nationwide will need to apply to become certified renovation firms and 235,000 individuals will need to become trained and certified as renovators, again in the first year.

All personnel working on pre-1978 target housing and/or in child-occupied facilities, such as daycare centers, will need to implement lead safe work practices and perform a cleaning verification upon completion of the work before the work area or areas can be re-occupied.

The intent of the Rule is to do no harm during renovation, repair and painting projects, not to abate preexisting lead paint hazards.

New! EPA Clarifies Testing Protocols for Lead-Based Paint RRP Regulations

Several member firms have contacted NAA/NMHC to report that regional EPA officials have stated that the federally approved testing protocol that has been in place under the Lead-based Paint Hazard Reduction Act (40 CFR Part 745.227) will not be sufficient to comply with the requirements of the new Renovation, Repair and Painting (RRP) rule.

NAA/NMHC have received an informal, yet definitive, response back from the EPA that this is incorrect. Member firms are advised that that the testing protocols found in the Residential Lead-based Paint Hazard Reduction Act remain appropriate for compliance purposes under the RRP rule. The EPA will be communicating directly with its regional offices to clarify this matter.

Read the letter from the EPA to NAA/NMHC

EPA Resources

EPA is placing ads in various publications and venues to get the word out to contractors and maintenance workers about the new Lead Renovation, Repair and Painting Rule requirement that contractors and maintenance workers must be lead-safe certified by April 22, 2010. To access these resources, visit the EPA Renovation, Repair and Painting Outreach Campaign Web site.

The following materials have been brought to you by NAA Education Institute:
 

How can I comply?

Be sure to contact your local apartment association for the appropriate training. Find your local NAA affiliated association.

 NAA Affiliates, please click here for important training information about EPA's RRP Rule.

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