Does EPA's announcement of June 18, 2010, modify the Lead Renovation Repair and Painting Rule's requirements that contractors use lead-safe work practices when working in pre-1978 housing or child-occupied facilities?
This announcement does not change the requirement that all contractors take steps to protect children and families from the dangers of lead poisoning by becoming certified and following the work practice standards and the associated recordkeeping requirements. As of April 22, all contractors have been required to be certified and follow the work practice standards described on EPA's website. The effect of the June 18 memorandum only provides firms more time to apply for and obtain certification as a lead-based paint renovation firm before active enforcement of the firm certification requirements begins. EPA is also providing individual workers additional time to enroll in and take the required training course to become certified lead-based paint renovators before active enforcement of the individual renovator training requirements begins. EPA will use its enforcement authority to ensure compliance by enforcing work practice standards and their associated recordkeeping requirements against all renovators and firms. Therefore, renovators who have not been able to complete the training requirements are advised to review EPA’s model training materials available at http://epa.gov/lead/training.html. Additional information on lead-safe work practices can be found at http://epa.gov/lead/rrp/contractors.html#work or obtained from the National Lead Information Center at 1-800-424-LEAD (5323).
All renovation firms, even those not yet certified under the RRP rule, are also reminded of their continuing obligations to comply with Lead Renovation, Repair and Painting Rule’s pre-renovation information distribution requirements, which require that before firms begin each renovation on pre-1978 housing or child-occupied facilities and to comply with the associated recordkeeping requirements. These requirements are explained in EPA’s Small Entity Compliance Guide to Renovate Right.