On April 22, 2010, the U.S Environmental Protection Agency’s ("EPA") new Renovation, Repair and Painting regulations ("RRPR") will become effective. The RRPR apply whenever remodeling and renovation projects disturb more than six square feet of potentially contaminated interior surface area or twenty square feet of potentially contaminated exterior surface area (the "Applicable Work") in residential and multi-family structures, child-care facilities, schools and other public and commercial buildings where children under the age of six are present or are expected to be present on a regular basis and that were built before 1978 ("Target Structures"). In general, the term Target Structures excludes housing for the elderly or disabled, unless children under six reside or are expected to reside there, "zero-bedroom" dwellings (such as studio apartments and dormitories), and structures that have been declared lead-free by a certified inspector.
Under the RRPR, all contractors who perform Applicable Work must be trained and certified in the use of lead-safe work practices. The RRPR requires that all Applicable Work be completed by such trained and certified contractors, utilizing lead-safe work practices that minimize occupants’ exposure to lead hazards.
In addition, under the RRPR, landlords, property managers and contractors are required to distribute the EPA’s pamphlet, Renovate Right. This pamphlet describes the hazards of lead paint exposure and lead-safe work practices. Importantly, Renovate Right is not the same as the EPA’s Protect Your Family pamphlet that owners of residential properties are currently required to distribute to their residents at the time a lease is signed. Finally, the RRPR contain record keeping requirements for property owners and the contractors they hire to perform Applicable Work.
The EPA has created a website that provides the text of the RRPR, commentary on the requirements of the RRPR, and additional resources relating to lead paint hazards, lead-safe work practices and the obligations of contractors and property owners under the RRPR. The website can be accessed here.
Please contact Steve Williams at (717) 234-5530 or firstname.lastname@example.org if you have any questions regarding the RRPR.