Understanding EPA’s LRRP Program

1. Understanding EPA’sLRRP Program www.oregonhba.com

2. Why the new Rule? • Lead is especially dangerous to children under six years of age • Reduced IQ and learning disabilities • Behavior problems • Even children who appear healthy can have dangerous levels of lead in their system • Lead is also harmful to adults. • High blood pressure and hypertension • Transfer to fetus in pregnant women

3. What’s the problem? • Dust is the main problem. • Lead in dust is the most common way people are exposed to lead. • Home renovation creates dust. • Proper work practices protect you from the dust.

4. Lead Paint History • Lead paint was used in more than 38 million homes until it was banned in 1978. • Lead was also used in varnishes and shellacs • When you hear the word “paint”, it includes all of these finishes. • Homes likely to contain lead • 87% built before 1940 • 69% built between 1940-1960 • 24% built between 1960-1978

5. Implementation Timeline • April 2008 • Final rule published • December 2008 • Start distributing new pamphlet • April 2009 • Certified Renovator Training begins • October 2009 • Firms can apply for certification • April 2010 • Full compliance

6. What is LRRP? • Lead Based Renovation, Repair and Paint Program • A federal regulatory program affecting anyone who disturbs painted surfaces • Applies to houses, apartments and child occupied facilities built before 1978 • Includes pre-renovation education requirement • Includes Renovator training and certification

7. Who must follow the rule? • In general, anyone who is paid to perform work that disturbs paint in housing and child occupied facilities built before 1978, such as: • Residential rental property owners • General contractors • Special trade contractors

8. What activities are subject? • Any activities that disturb paint in an area larger than 6 square feet inside or 20 square feet outside. • Remodeling and repair work • Electrical work • Plumbing • Painting • Carpentry • All window replacements

9. Any exclusions? • Housing or components declared lead-free by certified renovator • Housing built after 1978 • Housing for the elderly unless children reside there • Zero bedroom dwellings • Minor repair that disturbs less than 6 square feet

10. Owner Opt-out Provision • Provides the owner the opportunity to opt out of Lead Safe Work Practices • This opt out lead to a law suit against EPA • EPA has agreed to remove this sometime summer 2010 • Other parts of the rule also may change because of this law suit but no other changes in the near future

11. Education Requirement • Pre-renovation education for all pre-1978 housing • Distribute new pamphlet • Renovate Right • Distribute no more than 60 days prior work • To owner • To all occupants in multi-family setting • Post on signs in common areas • Signature of receipt or certification of attempt

12. Lead Save Work Practices • Contain the work area • Post warning signs • Cover floors and furniture, seal doors and ducts • Minimize the dust • No open flame burning or torching • No sanding etc with power tools • No heat guns greater than 750 degrees • Clean up thoroughly • Use a HEPA vacuum • Wet mop with plenty of rinse water

13. Recordkeeping • Records must be kept for 3 years • Verification of owner/occupant receipt of pamphlet or verification of attempt to inform. • Verification of lead check test • Documentation of the use of Lead Safe Work Practices • Certified Renovator certification • Certified Renovator tasks • Proof of worker training

14. Firm and Renovator Two different Certifications under the rule: • Firm Certification • The company that is responsible for doing the renovation. The company must apply to become a Certified Renovation Firm. • Renovator Certification • The person on site that is responsible for the renovation. The Renovator must attend an 8 hour training course.

15. Firm Certification • Under CCB • Called a Contractor’s License not a Firm Certification • All CCB licensed contractors that plan to do work on pre-1978 houses • Apply to CCB for “Certified Lead Based Paint Renovation Contractors License” • $50 per year application fee

16. Firm Certification • Under DHS • Any entity not licensed with CCB that will do work on pre-1978 houses • Apply to DHS for Firm Certification • $250 application fee good for five years

17. Firm Responsibilities • Certified Firms must ensure that • All individuals performing work are certified renovators or trained by the certified renovator • A certified renovator is assigned to each renovation and performs all of the renovator responsibilities • All renovations performed are in accordance with work practice standards of the LRRP rule • Pre-renovation education requirements are met • Recordkeeping requirements are met

18. Renovator Certification • Renovators must be trained and certified • Individual must complete an 8 hour training course • Certification comes from the Training Instructor • Certification good for 5 years

19. Renovator Responsibilities • Use EPA approved lead test kit • Provide on the job training for other workers • Be physically present when signs are posted, during work area containment & during clean up • Direct work being preformed by others • Be available by phone when not required on site • Have a copy of their Renovator Certification on hand at the work site • Prepare required records • Use lead safe work practices

20. OHBA Response Train and certify qualified instructors to teach: • the entire 8 hour course; 5 hours lecture, 3 hours hands-on • the 3 hour hands-on course that accompanies the online lecture course Create an online course to meet the lecture requirement of the Renovator training course

21. For More Information • Visit www.oregonhba.com • To order Renovate Right call • 1-800-424-5323 • For more information on the EPA rule • www.epa.gov/lead