Poisonings from Housing Renovations Containing Lead Paint: e o at o - - PowerPoint PPT Presentation
Poisonings from Housing Renovations Containing Lead Paint: e o at o s Co ta g ead a t A Regulatory Update Delaware Healthy Homes Summit March 12, 2014 Presented by: Demian P. Ellis, USEPA Region 3 What will be covered What will be
Poisonings from Housing Renovations Containing Lead Paint: e o at o s Co ta g ead a t A Regulatory Update
Delaware Healthy Homes Summit March 12, 2014 Presented by: Demian P. Ellis, USEPA Region 3
(RRP) Rule Requirements
BACKGROUND
Approximately 34 Million Homes in the U.S. Contain Lead
Renovation Studies (2000)
disturb lead-based paint produce d s u b ead based pa p oduce hazardous quantities of lead dust.
Typical clean up methods (broom and shop vacuum) do not eliminate lead dust hazards.
renovations and elevations in children’s blood lead levels children s blood lead levels.
The Renovation, Repair, and Painting Rule: What is it?
authority of §402(c)(3) of the Toxic Substances Control Act (TSCA) to addressed lead-based paint hazards t d b ti i d i ti ti iti created by renovation, repair, and painting activities that disturb lead-based paint.
Applies in target housing and child occupied facilities
Where doesn’t the RRP Rule Apply? Excludes: Excludes:
free of lead-based paint. A ti iti th t di t b l th l t 6 ft2 i t i
20 ft2 exterior (this excludes window replacement, demolition, and projects involving prohibited practices).
Firms performing maintenance, repairs or renovations
What does RRP require?
Firms performing maintenance, repairs or renovations that disturb Lead Based Paint (LBP) in homes or Child Occupied Facilities (COFs) built before 1978 must:
y approved training providers
Keep records
Contractors performing renovations
Have their firm certified by EPA
Contractors performing renovations that disturb paint must be EPA certified.
Contractors performing renovations that disturb paint must be EPA certified. that disturb paint must be EPA certified.
CERTIFICATION - ACCREDITATION
Certification of Firms
If you or your employees conduct renovation or repair activities in a pre- 1978 residential building or child occupied facility: 1978 residential building or child-occupied facility: STEP 1: Submit an application and fee to EPA STEP 2: Make sure your employees are trained in Lead Safe Work Practices STEP 2: Make sure your employees are trained in Lead-Safe Work Practices. STEP 3: Once you receive your EPA Lead-Safe Firm Certification in the mail and logo instructions in your e-mail, update any desired outreach materials.
RRP Final Rule - Overview 10
training by taking an 8-hour course. training by taking an 8 hour course.
Once training completed, renovator certified for 5 years.
Workers must receive on-the-job training from a certified Renovator
RRP RRP RRP
from a certified Renovator.
RRP RRP RRP RRP RRP RRP
worker is trained to perform.
checklists.
Renovator who conducted the training.
Renovators must provide building owners and
p p
Renovations in common areas
FIRM gives owner pamphlet and gets written
acknowledgement OR gets certificate of mailing 7 days >start AND FIRM Notifies each affected unit
Written notice to each unit OR post informational signs Post pamphlet (or how to obtain a copy)
Post pamphlet (or how to obtain a copy)
FIRM prepares written statement describing steps taken Notify if revisions to scope, location and/or dates
e s o s to scope, ocat o a d/o dates
followed.
Wh i i t d hil t i t i – When warning signs are posted, while containment is established, and during final work area cleaning. – Be available, either on-site or by telephone, at all other times.
Provide on the job training to uncertified workers.
present.
Perform cleaning verification.
Work Practice Standards
General
Work Practice Standards
g dust and debris when leaving the work area.
plastic sheeting. Dispose of waste in accordance with Federal, State, and Local requirements.
Work Practice Standards
Prohibitive
Prohibited work practices
Open flame burning or torching of lead-based paint Using heat gun >1100 oF Using machines without HEPA Using machines without HEPA attachment (sanding, grinding, power planning, needle gun, abrasive blasting or sandblasting) abrasive blasting, or sandblasting)
Work Practice Standards
Interior
Work Practice Standards
Cl d ll d t i th k
area.
sheeting.
Work Practice Standards
Exterior
Work Practice Standards
renovation.
distance to collect falling paint debris.
Exterior - Vertical Containment
Work Practice Standards
sheeting over a rigid frame.
close to property lines. close to property lines.
Exterior –Ground Cover
Cover the ground with protective Exterior Ground Cover
Work Practice Standards
sheeting.
– If space permits, extend a minimum of 10 feet from the work area. P i l tt ti d – Pay special attention and cover nearby vegetable gardens and children's play areas.
– Establish a 20 foot perimeter around the work area if space permits.
– Vertical containment must be erected if renovations occur within 10 feet of the property line
Cleaning
Work Practice Standards
work area.
– Clean walls with a HEPA-equipped vacuum or with a damp cloth. – HEPA vacuum all remaining surfaces d bj t i th k and objects in the work area. – Wipe all remaining surfaces in the work area with a damp cloth. Mop uncarpeted floors – Mop uncarpeted floors.
Work Practice Standards
Cleaning Verification
Work Practice Standards
cleaning cloth. g
clean that surface and then re-wipe with a wet cleaning cloth cleaning cloth.
card, allow the surface to dry completely and wipe with a dry cleaning cloth with a dry cleaning cloth.
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Wh t h ld I d ith t ?
Disposal
Work Practice Standards
Place waste in heavy duty plastic bag – Place waste in heavy duty plastic bag. – “Gooseneck seal” the bag. – HEPA vacuum the exterior of the waste bag before removing it from the work area. – Store waste in a secure area. Carefully dispose of waste in accordance – Carefully dispose of waste in accordance with Federal, State and Local regulations. – Always check local waste requirements
– Certifications for the Certified Firm and Certified Certifications for the Certified Firm and Certified Renovators.
renovation.
– Training and certifications for all renovation personnel, and for certification of the firm. – Distribution of required information. – Communications with and certifications from owners and residents. – Work activities in compliance to the Rule. – Post-renovation reports.
EPA may suspend, revoke, or modify a firm’s certification if firm is found to be in non certification if firm is found to be in non- compliance. Non-compliant contractors may be subject to civil and criminal penalties up to $37,500 per day for each violation imprisonment or both day for each violation, imprisonment, or both.
Typical procedure for a case
First, a tip/complaint comes into the Region:
Tip is entered into Report A Violation (RAV) system Please use www.epa.gov/tips
Typical procedure for a case Typical procedure for a case
Tip is forwarded through the RAV system to an inspector, then:
Inspector contacts the tipster. Gathers as much information as possible (including declaration) Schedules and performs the inspections Creates case file
Typical procedure for a case Typical procedure for a case
Case file is forwarded to a compliance officer Compliance officer reviews case and prepares case recommendation
Ad i i t ti P lt O d
Tiering
Types of Inspections Types of Inspections
Office/Record Inspections
Typically involve:
g g p g compliance with the Rule
Worksite Inspections
Triggered by tip/complaint or drive-bys and usually involve:
Taking pictures Could be interior or exterior work Attempting to talk to owner or workers p g Can not enter property without owner permission Returning to office f Attempting to contact property owner to perform inspection Go back out for inspection Then, perform office inspection of contractor
Worksite Inspections – Problems Encountered Problems Encountered
Finding work sites Tips/complaints from disgruntled employees or rival contractors from home owner who is not satisfied with the work done – trying to get refund, etc Contacting permitting offices Contacting permitting offices Working with local inspectors On-line databases On line databases
Worksite Inspections – Problems Encountered Problems Encountered (continued)
Turnaround time for getting into field Turnaround time for getting into field Contacting homeowner Homeowners are sometimes reluctant Logistics (drive-bys) Return to office to obtain permission to do the inspection
FY-13 Region 3 Inspection Numbers
31 1018 3 74 Training Provider RRP
Known Regulated RRP Community Region 3 Known Regulated RRP Community Region 3 as of October-November 2013
Number of EPA Certified Firms: 113,000
Common Violations
Failure to Obtain Firm Certification. The United States alleges that Company X violated the Renovation, Repair, and Painting Rule by failing to obtain firm certification from EPA prior to performing or offering to to obtain firm certification from EPA prior to performing, or offering to perform, renovation activities in housing constructed prior to 1978.
Failure to Establish and Maintain Records. The Unites States alleges that Compan X iolated the Reno ation Repair and Painting R le b that Company X violated the Renovation, Repair, and Painting Rule by failing to establish and maintain records certifying that a certified renovator was assigned to the project, provided on-the-job training to individuals used on the project, and directed these individuals p j performing the renovation to comply with the work practice standards required by the RRP rule.
Common Violations
Failure to Document Delivery of the Lead Hazard Information Pamphlet to the Property Owner The United States alleges that Pamphlet to the Property Owner. The United States alleges that Company X violated the Renovation, Repair, and Painting Rule by failing to document that it provided a copy of the “Renovate Right” pamphlet to the property owner prior to commencing renovation activities y g
Failure to Ensure All Individuals Performing the Renovation Were Certified or Trained. The United States alleges that Company X violated the Renovation, Repair, and Painting Rule by failing to ensure that all of the individuals performing the renovation were certified by EPA or had been trained by a certified renovator.
Common Violations
Failure to Comply with Work Practice Standards. The United States alleges that Company X violated the Renovation, Repair, and Painting Rule by: p y , p , g y (1) failing to post signs clearly defining the work area and warning occupants and
area; area; (2) failing to using prohibit the use of machines designed to remove paint or other surface coatings through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting without HEPA vacuum attachments, and; (3) failing to contain waste from renovation activities to prevent releases of dust (3) failing to contain waste from renovation activities to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal.
EPA Tips and Complaints.
136 150 116 105 18858
456 605 150
298 150 605
2268 TIPS & COMPLAINTS NATIONALLY BY REGION 2268 TIPS & COMPLAINTS NATIONALLY BY REGION 4/1/2010 - 3/30/13
Increase consumer demand for trained and certified renovator services
Pl d i 488 i – Placed in 488 magazines
Spanish)
– 1740 (English) & 432 (Spanish) airings in Dec’10 & Jan ‘11
– Home Depot Distribution
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Focus outreach to contractors not already certified
B k Sli
– Distribution to the Distribution to the Regions
Spanish)
– Home Depot distribution Home Depot distribution
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Information Resources
Test Kits
RRP Final Rule - Overview 48
S d T ib l P A h i i State and Tribal Program Authorization
RRP is a delegable program.
EPA requirements and have “adequate EPA requirements, and have adequate enforcement.”
Demian P. Ellis Regional Lead Coordinator USEPA Region 3 g ellis.demian@epa.gov 215-814-2088 www.epa.gov/lead
National Lead Hot Line 1-800-424-5323 (LEAD)