June 21, 2010
EPA Delays enforcement of RRP Certification but NOT work practices!
In summary, what the
1) It delays enforcement of the firm certification requirement until Oct
1, 2010. This means that firms have a couple of extra months to pay $300
to EPA to receive their firm certifications. This makes it tougher for
us to hold firms accountable for following the rule's requirements. It
also seems unfair to penalize those who have applied for firm
certification, while leaving those who have not applied (and are
therefore harder to find) off the hook.
2) It delays enforcement against individual renovators, provided they
sign up for training by Sept 30, 2010 and complete that training by
December 31, 2010. This may have a chilling effect on training this
What the action does not do:
1) This memo does NOT delay the enforcement of the rule's work practice requirements. This is important. If someone is using unsafe work
practices or not following the work practice protocols, regardless of
whether they've had training, they are breaking the law and an
enforcement can be brought against them. Tips and complaints can be
reported to EPA's regional offices (see below for the contacts - when
you call - ask for the enforcement officer)
2) This action does not pre-empt the state's who have already adopted
their own programs: OR, NC, MS, RI, IA, WI, UT, KS. We hope that other states will adopt programs and are advocating for more federal funding to incentivize state adoption.
Regional Office Contact Info:
States: IL, IN, MI, MN, OH, WI
Regional Contact: David Turpin
U.S. EPA Region 5 (DT-8J)
77 W. Jackson Blvd.
Chicago, IL 60604
April 23, 2010 IMPORTANT CHANGES TO RRP FINAL RULE
The EPA has published proposed rule changes. Some of the rules are have an immediate impact. Some are proposed rule changes. It is important that you read and understand these changes. They will have a direct effect on your work.
"Post-Renovation Recordkeeping Checklist". On completion of each project the Certified Renovator is required to complete this report. The final rule now requires the Certified Firm to give a copy of this report to the person(s) contracting for the work within 30 days of completing the project. In common areas there needs to be a posting as to where residents may get a copy.
Certified Renovators trained before April 22, 2010. The expiration date of your training has been extended to July 1, 2015. This is to remove the "penalty" of a shorter certification period for those who took the class in advance of the rule implementation.
"Opt-Out Statement". The opt-out has been eliminated. The rule was published in the Federal Register on May 7th, 2010. The OPT-OUT is gone as of July 6, 2010. What does this mean to you? If you took training from us, it doesn't mean much. We have been telling you the opt-out would be gone and recommended that you not use it.
For complete information CLICK HERE.
"Rule change requiring dust wipe sampling for clearance". This proposed rule change will have the most dramatic effect on all covered renovation work. The rule to require dust-wipe testing after most renovations and provide the results of the testing to the owners and occupants of the building. For some of these renovations, the proposal would require that lead dust levels after the renovation be below the regulatory hazard standards. EPA will take comment on the proposal for 60 days. The agency expects to finalize the rule by July 2011. Public comment will be taken on this matter for 60 days. Go to www.regulations.gov and search docket "EPA-HQ-OPPT-2005-0049".
For complete information CLICK HERE.
"Expansion of the Rule". EPA's intention to apply lead-safe work practices to renovations on public and commercial buildings. The advance notice also announces EPA's investigation into lead-based paint hazards that may be created by renovations on the interior of these public and commercial buildings. If EPA determines that lead-based paint hazards are created by interior renovations, EPA will propose regulations to address the hazards.
For complete information CLICK HERE.
April 23, 2010
To Read the entire press release,
To Read the entire press release, CLICK HERE
April 23 Press Release - Rule Effective plus 3 bits of news, as follow:
In addition to the rule becoming effective, EPA has issued three additional actions, including closing the opt-out, 60 days after FR posting (Jun 27?):
- A final rule to apply lead-safe work practices to all pre-1978 homes, effectively closing an exemption that was created in 2008. The rule will become effective 60 days after publication in the Federal Register.
- A notice of proposed rulemaking to require dust-wipe testing after most renovations and provide the results of the testing to the owners and occupants of the building. For some of these renovations, the proposal would require that lead dust levels after the renovation be below the regulatory hazard standards. EPA will take comment on the proposal for 60 days. The agency expects to finalize the rule by July 2011.
- An advance notice of proposed rulemaking to announce EPA’s intention to apply lead-safe work practices to renovations on public and commercial buildings. The advance notice also announces EPA’s investigation into lead-based paint hazards that may be created by renovations on the interior of these public and commercial buildings. If EPA determines that lead-based paint hazards are created by interior renovations, EPA will propose regulations to address the hazards.
http://www.epa.gov/lead/pubs/lead_rrpr_q_and_a.pdf - New Set of FAQs relating to training and effective date for final rule, still April 23; only the Opt-out closure is stalled for 60 days
We are currently reviewing the Federal Register. We will post all changes as soon as possible. To read the 79 page rule CLICK HERE.
April 20, 2010
EPA has authorized four (4) more states (Kansas, Rhode Island, Utah and Mississippi) for a grand total of 7 with Iowa, Wisconsin and North Carolina per EPA's website: http://www.epa.gov/lead/new.htm .
January 22, 2010
Iowa (January 19, 2010) and North Carolina (January 21, 2010) take over the RRP Rule. The US EPA has made it clear it will allow States and Tribal Areas regulate the RRP Rule themselves. Up to now Wisconsin (October 20, 2009) was the only state to be approved to enforce the RRP rule on their own. If you work in one of these states the check with your state's Department of Public Health to find out what is required of you for training and training providers.
Dr. Karole Lakota and Rich Cowgill, CR, GCP gave an interview on "Mighty House" Home Improvement radio show. Dr. Lakota explains the danger of lead to children and Cowgill explains the RRP Rule. To listen to the entire show: Click Here
Nicholas J. Peneff, Dr PH will be participating in the Lead Poisoning Prevention and Healthy Homes Conference on October 22, 2009. The conference is sponsored by the Illinois Dept. of Public Health. It will be held at the Du Page County Administration complex.
IDPH has approved Public Health and Safety, Inc. as a training provider for the RRP Rule using the USEPA accredited curriculum developed by NCHH. Public Health and Safety, Inc. is also an accredited training provider. Training will begin on December 7th, 2009. For dates click on the "Calendar" tab.
- Lead Poisoning Prevention and
Healthy Homes Conference.
The Conference was a great success.
With more than 200 contractors, health professionals and 12 vendors the conference was a great success. Everyone that attended received valuable information. The conference covered the Health effects of Lead as well as, updates to the RRP rule from EPA.