Renovation, Repair and Painting Rule Presentation for NJ Lead and - - PowerPoint PPT Presentation
U.S. Environmental Protection Agency Renovation, Repair and Painting Rule Presentation for NJ Lead and Beyond Conference, Edison, NJ April 16, 2010 Jeanette Dadusc, US EPA Region 2 1 Residential Lead-Based Paint (LBP) Hazards April 2001
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Presentation for NJ Lead and Beyond Conference, Edison, NJ April 16, 2010 Jeanette Dadusc, US EPA Region 2
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April 2001 HUD’s ―National Survey of Lead
26 million homes in the US (27 percent) have
Residential LBP hazards are more prevalent
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Exposure to lead can cause learning disabilities
In extreme cases, exposure may result in death.
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1978 Consumer Product Safety Commission
1992 Residential Lead-Based Paint Hazard
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Section 1018—Real Estate Disclosure Section 402(a)/404—LBP Activities [Abatement]
Section 405—National Lead Laboratory
Section 403 – Hazard Standards for Lead in Paint,
Section 402(c)—Renovation, Repair, and Painting
Section 406(b)– Pre-Renovation Education Rule
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TSCA 402(c)(2) directs EPA to study
EPA consulted with national specialists Categories of renovation activities which
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paint removal surface preparation removal of large structures (demolition) window replacement enclosure of exterior painted surfaces removal of carpet or other floor covering wallpaper removal HVAC repair or replacement including duct work repairs or additions resulting in isolated small surface
exterior soil disruption major renovation projects involving multiple target
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Phase 1: Environmental Field Sampling Study Phase II: Worker Characterization and Blood Lead
Phase III: Wisconsin Childhood Blood Lead Study Phase IV: Worker Characterization and Blood Lead
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Additional peer-reviewed EPA Study:
Study conducted by the National Association
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April 22, 2008 Final RRP Rule Issued Toxic Substances Control Act (TSCA) Section
Code of Federal Regulations 40 CFR 745
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What RRP Covers RRP Training and Certification Infrastructure RRP Implementation RRP vs. Abatement Cleaning Verification and Clearance Testing RRP Questions
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A building or portion of a building built prior to 1978
Visited regularly by the same child under age 6 At least 3 hours a day At least 6 hours a week At least 60 hours a year
Common areas routinely used by the children under
Adjacent exterior areas
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Disturbing more than 6 ft2 per room of painted surface
Disturbing more than 20 ft2 of painted surface
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Surface preparation (sanding and scraping) Surface restoration (replastering) Plumbing, carpentry, and HVAC work Removal, modification, or repair of painted
All demolition of painted surfaces All window replacements
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Compensation means that the renovator is
Wages paid to facility maintenance staff Monies paid to outside contractors Rent
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1. Confirmation that painted surfaces are lead-
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2. Activities performed as part of an abatement by
3. Opt-Out Provision (may be revoked 4/22/10) 4. Emergency renovations - partially exempt, ―to the
5. Obvious exemptions ..Post ’78, not Target Housing, etc.
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Accreditation of Training Providers Firm certification Renovator and Dust Sampling Technician
Non-certified Workers
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EPA accredits training providers who, in turn, certify
Certification is good for 5 years Must have certification while conducting work Model EPA courses for Renovator and Dust Sampling
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Must have a certified renovator assigned
Non-certified workers must be trained by a certified
The certified renovator must keep documentation of
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Certified renovators must be employed by an EPA
EPA has 90 days to approve/ disapprove an application Application for firm certification:
Certification is good for 5 years.
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June 23, 2008
Information distribution and notification
Oct. 22, 2009
Submit applications for firm certification
April 22, 2010
all work must be conducted/ supervised by
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All individuals performing regulated activities on
A certified renovator is assigned to each renovation
All lead safe work practices are followed. Information distribution requirements are followed. Recordkeeping requirements are met.
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Perform, or direct, the lead safe work practices Be physically present for site preparation and site
Regularly direct work being performed by trained
Be available, either on-site or by phone, at all times that
Have proof of certification at all times. * Prepare necessary records * Use an EPA-approved test kit * Conduct cleaning verification
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Renovation: Modification of any existing
Abatement (745.223): Any set of measures
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Divide the work area into 40 ft2 sections. Wipe floors and windowsills with a wet disposable
Perform cleaning verification
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Cleaning verification is not required if dust
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Conduct a visual inspection for dust, debris or
Eliminate these conditions
When area passes visual
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Provide the owner of the property with the
Provide parents/guardians with the pamphlet OR
Obtain written acknowledgment
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Post signs defining the work area Employ lead safe work practices
Contain the work area Minimize dust Clean up thoroughly
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Remove or cover all objects from the work area. Close and cover all ducts, windows and doors. Cover the floor surface with taped-down plastic
Ensure that all personnel, tools, and other items
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Close all doors and windows within 20 feet of the
Cover the ground with plastic sheeting a
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Open-flame burning or torching Sanding, grinding and the like, unless
Use of a heat gun above 1100°
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Contain waste until it is removed from the
Store collected waste so that dust and debris
Contain the waste during transport from
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Clean the work area until no visible dust, debris or
Collect all paint chips and debris and seal in a
Remove the protective sheeting. Mist the sheeting,
Dispose of the sheeting as waste.
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Clean walls starting at the ceiling and working down to
Vacuum all remaining surfaces and objects in the work
Wipe all remaining surfaces and objects in the work area
Mop uncarpeted floors.
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All records necessary to demonstrate compliance with the
reports certifying that LBP is not present test kits used to evaluate absence/presence of LBP records relating to information distribution
worker training records containment and work practice records waste management records post-renovation cleaning cleaning verification and/or dust sampling results
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732-321-6671 Region2_LeadCoordinator@epamail.epa.gov,
800-424-LEAD (5323)