Bituminous Insurance Companies
Release Date: February 5, 2010
The deadline is approaching for contractors that perform painting, renovations, or repairs in residential houses, apartments, and child-occupied facilities, such as schools and day care centers built before 1978. After April 22, firms working in these buildings must be certified by the U.S. Environmental Protection Agency (EPA), or an EPA-authorized state, territory, or Indian tribe, if their work will disturb lead-painted surfaces.
The certification requirements were promulgated as part of the EPA's Lead Renovation, Repair, and Painting (RRP) Rule, which was issued in April 2008. This rule also established pre-renovation notification and client education requirements, mandatory lead-safe work practices, and mandatory recordkeeping requirements. The complete rules may be found in Title 40 of the Code of Federal Regulations Part 745.
The requirements affect a wide variety of businesses, including residential property owners/managers, general contractors, and specialty trade contractors including painters, plumbers, carpenters, and electricians. EPA estimates that approximately 210,000 businesses will be covered by the rule.
Two types of certification are required: Certified Firm and Certified Renovator. The firm certification applies to businesses performing renovations for compensation in covered facilities. To become certified, a firm must complete and send in an application to EPA or state-authorized program and pay a fee. Currently, three states, Iowa, North Carolina, and Wisconsin, are the only states authorized to administer their own certification programs. If approved, the certification is good for five years.
Individuals may become Certified Renovators by completing an EPA-approved training course in lead-safe work practices taught by an EPA-accredited training provider. Successful completion of that course will result in a 5-year certification as a Certified Renovator. No application or fee is required; the individual’s course completion certification will serve to document their credentials. Copies of these credentials must be posted at the job site where the individual works.
All renovation jobs in covered buildings must be overseen by a Certified Renovator, regardless of the level of training of other persons working on the job. This person must train all non-certified workers in lead-safe work practices; remain on-site during sign posting, work area set up, and cleanup; and be available by phone or pager when not on-site. They must conduct the cleaning verification procedure to make sure that the work is complete and the work area is ready to reoccupy. Also, they must certify that the work was done in a lead-safe manner.
Contractors or individuals that perform work in buildings and structures not covered by the rule do not have to be certified. Examples of such buildings include zero-bedroom dwellings (such as hotels and dormitories), commercial and public buildings where children under 6 are not likely to be present for significant periods of time, and housing built in 1978 or later. In addition, certification is not required if the components affected by the renovation do not contain lead-based paint, the repairs and maintenance activities are minor, or there is no child under 6 years old residing in the home and the homeowner signs a statement opting out of the requirements.
The EPA has established a Web-site explaining the requirements of the Lead RRP rule and how it affects building owners, contractors, tenants and families with children under 6, training providers, realtors, and property management firms. It includes copies of the regulations and guidance written for the various audiences. The main URL for this Web-site is http://www.epa.gov/lead/pubs/renovation.htm.
COPYRIGHT ©2009, ISO Services Properties, Inc.
The information contained in this publication was obtained from sources believed to be reliable. ISO Services Properties, Inc., its companies and employees make no guarantee of results and assume no liability in connection with either the information herein contained or the safety suggestions herein made. Moreover, it cannot be assumed that every acceptable safety procedure is contained herein or that abnormal or unusual circumstances may not warrant or require further or additional procedure.