EPA's Renovate, Repair and Painting (RRP) Rule is back

EPA's lead based paint, Renovate, Repair and Painting (RRP) Rule requires all contractors who disturb painted surfaces or act as a general contractor in pre-1978 residential and child-occupied property to be EPA firm certified and those supervising the work be, "Certified Lead Safe Renovators." Five years ago EPA was in regulation take off mode and Compliance assistance was the theme. After 5 years to comply and NOW at the Lead Paint RRP's first anniversary renewal cycle, EPA is publicly stating they are in enforcement/compliance mode! Beginning this fall and in full speed by first quarter of 2015, all contractors who had previously completed their EPA RRP Certified Renovator courses and the certified firm will have to renew their certification. EPA's RRP Program is a five year certification with a four hour refresher course required prior to the Certified Lead Safe Renovator Supervisors current certification's expiration date. Check your RRP certification expiration date now! There are numerous lead-based paint regulations sprinkled throughout our country, each associated with violations, fines, and penalties if not properly addressed. EPA's RRP rule is the framework for many of them. Lead paint and lead poisoning has been, still is, and most likely will continue to be highly litigious, as will our society, into the immediate future. During the last five (5) years since you first had to comply, several major lead-based paint related developments have occurred. CDC lowered the Reference Value of a child being at risk to 5ug/dl. HUD released their long overdue 2012 Guidelines for the Evaluation and Control of Lead and Lead Hazards. And Lowe's Hardware was hit with a major violation, inclusive of financial penalties, mandatory compliance deadlines, and subcontractor enforcement in all 1,700+ stores. All other vendors will have to do the same if not already complying. How to comply with EPA's RRP and avoid violations, penalties, litigation, guilt, time & money; re-fresh prior to your current expiration date and Keep accurate and clear records documenting your compliance. EPA's enforcement is based on tips, complaints and a few other sources. The only things they can review to document proof of compliance, or lack thereof, other than physically seeing the work with their own eyes, are the paper records required to be completed, such as owner/resident notification, check list, lead test, cleaning verification, etc., by the certified renovator. Keep good records inclusive of your current RRP compliant Lead Safe Renovator Certification and you will be in a very proactive and defendable position, isn't that who we want to be? Whether you believe lead paint is important, whether you want to believe any of the above or not, ask yourself for a day (initial course) or a half-day (refresher) is the risk worth not complying. Protect yourself and your company, by not letting your occupants, your employees, or the government catch you off guard.