What does it all mean in real life?
Any contractor who works in a home built before 1978, and whose work disturbs more than 6 square feet of painted surface in a room, or 20 square feet on the home’s exterior, has to follow the RRP rules.
For windows the rule specifies that if a single component of the window is disturbed, the whole square footage of the window counts towards calculating the square footage area. Meaning any window over 2’ x 3’ falls under the RRP rule. This means that the contractor has to either test surfaces that will be disturbed for lead, or assume that lead is present. If lead is present, or no testing is performed, safeguards as prescribed by the RRP Rule have to be implemented. The contractor has to inform the homeowner by providing them with a copy (printed or in electronic format) of the brochure Renovate Right. Before the work starts, the homeowner should sign a receipt stating they received the brochure before the work started. The contractor has to keep this receipt on file for three years. Sample receipt HERE. An informative publication is the Small entity compliance guide to Renovate Right, the EPA’s Lead-based paint Renovation, Repair, and Painting Program; A handbook for contractors, property managers and maintenance personnel working in homes, child care facilities and schools built before 1978. You can find it HERE . If you want even more (specific) information you will find the Lead Renovator Manual (the course material certified contractors studied during their 8-hour initial certification class) HERE. |
Checking on the status of your contractor.
Nationwide you can verify that a contractor is EPA certified by going to the EPA’s Contractor Locator site and search for a specific contractor or search for all certified contractors within a specified area. You will find it HERE. Several states administer their own program, including the State of Washington. The program is administered by the Department of Commerce. For a listing of certified contractors please look HERE. Ask to see your contractor's certification. The Lead Renovator can show you a photo identification card that has an expiration date on it (mine is shown to the right). Initially companies had to apply to the Federal EPA to become a Lead Safe Firm. After signing a promissory note stating the company would follow the EPA RRP rules, and paying a fee, the EPA would issue a certificate, and assign the company a unique identification number (shown to the right). The Federal EPA certificate comes with the EPA's Lead Safe Certified Firm logo accompanied by a company's unique registration number. This logo is intended for firms to advertise their certified lead safe status. Lead Safe Firm certification in Washington State has been taken over by the Department of Commerce. Now, firms should be able to show you a certificate stating the company has fulfilled the certification requirements of Washington Administrative Code (WAC) 365-230. Shown to the right. |
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The difference between RRP and Abatement.
• Lead abatement is defined as any measure or set of measures designed to permanently remove or cover lead-based paint or lead-based paint hazards. Abatement includes, but is not limited to: (1) The removal of paint and dust, the permanent enclosure or encapsulation of lead-based paint, the replacement of painted surfaces or fixtures, or the removal or permanent covering of soil, when lead- based paint hazards are present in such paint, dust or soil; and (2) All preparation, cleanup, disposal, and post-abatement clearance testing activities associated with such measures. (40 CFR 745.223).
• Abatement does not include renovation, remodeling, landscaping or other activities, when such activities are not designed to permanently eliminate lead-based paint hazards, but are designed to repair, restore, or remodel a given structure or dwelling, even though these activities may incidentally result in a reduction or elimination of lead-based paint hazards. Furthermore, abatement does not include interim controls, operations and maintenance activities, or other measures and activities designed to temporarily, but not permanently, reduce lead-based paint hazards. (40 CFR 745.223). |
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