The EPA will delay enforcement of parts of its lead-based paint Renovation, Repair and Painting (RRP) rule.
Specifically, EPA has extended the deadline for workers to sign up for a lead-safe training class to September 30, 2010. Training must be completed by December 31.
EPA will also not take enforcement actions for violations of the rule's firm certification requirement until October 1. NAA/NMHC had earlier asked EPA for an enforcement delay and an extension of the compliance assistance period, citing issues with the required training material among other things.
Importantly, EPA is not delaying enforcement actions for those found to be in non-compliance with the rule's lead-safe work practice requirements. EPA says it "will continue to enforce the work practice requirements in the rule which protect children and reduce lead exposure."
The EPA’s letter on enforcement is available at http://www.epa.gov/oppt/lead/pubs/giles_RRP_memo.pdf.
A question-and-answer document from EPA is available at http://www.epa.gov/oppt/lead/pubs/rrp-ques-answer.pdf.
In September EPA announced that it had approved a chemical spot test kit for use on a variety of surfaces including drywall and plaster. These kits may be used by state-certified renovators in pre-1978 to determine whether lead is present in specific surfaces under the RRP rule.
These kits are not approved for determining whether or not a property meets the test of lead-free under Title X, the Residential Lead-based Paint Hazard Reduction Act. See the EPA’s announcement at http://www.epa.gov/lead/pubs/testkit.htm#recognized.