The EPA has delayed enforcement of Certification Requirements for the EPA's Renovation, Repair and Painting Rule (RRP Rule). As a result of contractor outcry, the EPA announced that it will delay enforcement of the RRP Rule's firm certification requirement and of the worker certification requirement to allow contractors more time to come into compliance.
This "delay" does not rescind, revoke or change the basic RRP Rule. EPA will continue to enforce the work-practice requirements in the rule. What is being delayed is enforcement of penalties to firms (until October 1, 2010) and to individual contractors .
Background: The RRP Rule went into effect in April. In brief, the Rule has required all contractors who work in pre-1978 housing and schools who might disturb more than 6 square feet of painted surfaces to:
- Educate owners. Contractors must give the owner a pamphlet called "Renovate Right" and get a signed receipt before beginning a job.
- Get Individual Certification as an RRP Certified Renovator. At least one RRP Certified Renovator is required at each job site. Certification involves taking a 1-day class from an EPA Accredited Training Provider. (Enforcement delayed to allow for enrollment in a certified renovator class by September 30, 2010 and completed by December 31, 2010).
- Get Firm Certification. Each firm or agency must also become RRP certified. (Note: This includes city agencies and school districts as well as contractors and maintenance firms.) Firms or "entities" must submit an application and pay the EPA a fee ($300), which is good for 5 years. Firm certification is not the same as the individual certification. There is no training requirement for Firm Certification - just pay the $300 and assure all RRP rules are being followed. (Enforcement and penalties delayed until October 1, 2010)
- Provide on-the-Job Training. RRP Certified Renovators (Individuals) are required to train all non-certified people at the job site. Exception: all workers for agencies doing housing rehab with Federal dollars must be RRP Certified Renovators.
- In California, assume all paint in pre-1978 structures is lead-based.
- Use Lead-Safe Work Practices. California already requires this. The CSLB, Cal/OSHA and California Dept of Public Health have a ton of info on Lead-Safe Work Practices.
- Verify. At the end of each job, contractors are required to do a "cleaning verification" to make sure they cleaned up properly.
Cost of training for the RRP Certified Renovator is about $200 per person. The Builders Exchange is actively seeking a training provider and the best pricing options for the membership. If you need this certification please let Scott Leary or Julie Kennedy know at the Exchange by emailing us at spleary@beac.com or calling 510-483-8880.