The Environmental Protection Agency’s Renovation, Repair and Painting (RRP) rule is widely considered a “game changer” for the residential remodeling industry. The rule took effect April 22, 2010. On or before that date, any company working in a home or child-occupied facility built prior to 1978 must pay to be registered with EPA as a renovation firm. In addition, at least one employee from that company must receive eight hours of training from an EPA-accredited provider, and then pass a test, in order to be a Certified Renovator. A Certified Renovator will assume responsibility for on-site job supervision, training of other employees, and overseeing work practices, cleaning, and cleaning verification of all work in pre-1978 properties. The rules apply, with some exceptions, to interior work that disturbs 6 square feet or more of lead-painted surfaces, and 20 square feet or more for exterior surfaces. Consequences for not complying with the RRP can include penalties of up to $37,500 per violation, per day. In addition, EPA may suspend, revoke, or modify a company’s certification.
Although the RRP’s implementation is new, its history dates back to 1992, when Congress passed the Residential Lead-Based Paint Hazard Reduction Act (Title X). Section 1018 of this law directed EPA and the Department of Housing and Urban Development (HUD) to require the disclosure of “known information on lead-based paint and lead-based paint hazards” before the sale or lease of most housing built before 1978. EPA estimates that approximately three-quarters of the nation’s housing stock built before 1978 (64 million dwellings) contain some lead-based paint.
Since December 2008, remodelers have been required to distribute EPA’s “Renovate Right” pamphlet when working in pre-1978 homes.
EPA has estimated that more than 236,000 remodelers, window installers, painters, heating and air-conditioning specialists and other trade contractors must be trained to ensure compliance with the RRP rule. Based on internal Hanley Wood research, however, the EPA estimate is quite low; our surveys indicate that there are probably closer to 800,000 contractors who must comply with the rule, and that their schedules, costs, and conversations with clients will be affected accordingly.
The articles and links collected at this site provide remodelers and other contractors affected by the RRP with tools and information to help them understand how the new rules affect their companies, and what they must do to comply.
Note: This information does not constitute legal advice. You should consult a professional with any questions regarding this or any legislation.