In order to comply with the RRP rule, renovators will incur costs for EPA certification and costs to take a training course from an EPA-accredited training provider, as well as for supplies needed in order to carry out the required lead-safe work practices designed to reduce exposure to lead dust from renovations.
Firm Certification and Training Costs: The rule requires renovation firms to become certified by EPA or an EPA-approved state RRP program in order to perform renovation, repair or painting activities for compensation in target housing or child-occupied facilities. EPA is required by law to charge firms a fee that covers the government’s cost of administering the program. Firm certification is valid for 5 years. The fee for most firms is $300, which is equivalent to a cost of $60 per year.
The Renovation, Repair, and Painting Rule (RRP) does not impose requirements on homeowners, unless they are performing renovations in rental space. However, the hired firm would be in violation of the RRP Rule if it was uncertified and performing a covered renovation.
Question: Under the RRP Rule, can the required records and documentation be stored electronically rather than as paper copies?
Answer: Yes. The renovation firm is responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of 3 years following completion of the renovation. The RRP Rule does not specify the format in which records must be kept.
Question: As a general contractor, we subcontract the entire renovation job to other companies rather than using our own employees. Under the Renovation, Repair, and Painting (RRP) Rule, does my firm need to have a certified renovator at the site?
Answer: Not necessarily. All firms performing renovations, including general contractors, must ensure that all individuals performing renovation activities on behalf of the firm are either certified renovators or have been trained by a certified renovator.
A firm acting as a general contractor may satisfy this requirement by hiring another certified firm that also takes responsibility for ensuring that all individuals performing the renovation activities are either certified renovators or have been trained by a certified renovator.
With respect to assigning a certified renovator who is responsible for any OJT and regularly directing other workers, a firm acting as a general contractor my satisfy this requirement by hiring another certified firm that in turn assigns a certified renovator to the job. However, this does not discharge the general contractor's liability to ensure compliance with the RRP Rule.
Question: I hear so many rumors about the EPA's RRP Rule. Some say compliance will put me out of business. Some say compliance will cost thousands of dollars extra to replace one window. Where do I find out the facts?
Answer: That's a great question. Yes, you'll see a lot of rumors about the new lead-safe rule that are not based in fact. Your first line of defense against confusion will be to take an RRP class and become a Certified Renovator.
Of course, an 8-hour class cannot answer every single question or confusion that arises. To do your research, and not rely on third parties that may have motives other than educating you, I suggest you turn to the EPA's own Frequently Answered Questions.
Here are some questions and answers from the list:
Question:I thought lead-based paint had been phased out. How many homes still contain lead-based paint?
Answer: HUD’s National Survey of lead and Allergens in Housing estimated that 38 million permanently occupied housing units (40% of all housing units) in the United States contain some lead-based paint that was applied before the residential use of lead-based paint was banned in 1978. “Housing units” include single-family homes, manufactured housing, and multi-unit dwellings like apartments. Vacant housing, group quarters (e.g., prisons, hospitals, and dormitories), hotels, motels, and other short-term housing, military bases, and housing where children are not permitted to live (e.g., housing designated exclusively for the elderly and those with zero-bedroom units) are not included in this number. More information on these statistics is available from HUD.
Question: When testing a work area, does one spot-test kit suffice for any single component? What if a component's surface area is extensive (i.e. a large wall)?
Answer: The certified renovator is only required to use one spot test kit for each component, even if the surface of the component is extensive (e.g., a large wall).
Q: Can I teach my crew how to do RRP lead-safe practices?
A: From Bill Robinson, an EPA Certified Renovator and EPA-accredited trainer (certified through NCHH):
Yes, you can train your own crew how to do RRP lead-safe practices but only if you are a Certified Renovator yourself and you provide hands-on practice. That means you have taken an 8-hour RRP certification class, done the hands-on activities, and passed the test.
Indeed, the firm or contractor must be a Certified Renovator in order for the company to work on homes built before 1978 and other applications, including day care centers. (See the RRP rule explained here)
For a fuller answer to this question, consider this direct quote from the EPA-HUD publication titled: "Lead Safety for Renovation, Repair, and Painting":
A Certified Renovator must provide lead-safe work practices training to non-certified workers so those workers can perform assigned tasks safely. This training can be provided by the Certified Renovator on-the-job or in the classroom, provided adequate hands-on practice is available. This training could also be conducted by a third party, although the instructor must be a Certified Renovator.
So you can either provide the training yourself or have a third party instructor do the training, provided they are a Certified Renovator and you provide some hands-on practice.
If you find that training your crew is too difficult or too time-consuming, I have produced a DVD RRP training program specifically designed for on-the-job workers that you can play to your crew, and then follow it up with hands-on practice. As I am both a Certified Renovator and an EPA-accredited (certified through the National Center for Healthy Homes), I am a qualified instructor for your crew.
Q.Does the size of a rain-screen gap matter? Rain-screen wall assemblies seem like a good idea for protecting wood siding and paint, but they can create headaches when it comes to resolving door, window, and other trim details. Wider gaps mean that doors and windows would need jamb extensions, as well as screening to keep bugs out. But would a 1/4-inch or 1/8-inch gap — which might not require any additional detailing, or even screening — be equally effective?
A.Bill Robinson, a long-time general contractor and moderator of the JLC Online exterior-details forum, responds: To avoid the possibility of capillary action, researchers like John Straube of Building Science Corp. generally agree that rain-screen drainage gaps should be at least 1/4 inch wide. To provide ventilation so that wet siding can dry to the back, the size of this gap should increase as the average annual rainfall increases. Rain screens are probably unnecessary in mild climates with less than 20 inches of rain per year, while in an extreme coastal climate with more than 60 inches of rain annually and a lot of wind, the gap should be as large as possible and pressure-equalized, with ventilation at both the top and the bottom of the wall. In an average climate where 20 to 60 inches of rain falls annually, a 3/8-inch gap is typically recommended, though I'd think that a 1/4-inch gap would be acceptable in most cases.