Several member firms have contacted NAA/NMHC to report that regional EPA officials have stated that the federally approved testing protocol that has been in place under the Lead-based Paint Hazard Reduction Act (40 CFR Part 745.227) will not be sufficient to comply with the requirements of the new Renovation, Repair and Painting (RRP) rule.
NAA/NMHC have received an informal, yet definitive, response back from the EPA that this is incorrect. Member firms are advised that that the testing protocols found in the Residential Lead-based Paint Hazard Reduction Act remain appropriate for compliance purposes under the RRP rule. The EPA will be communicating directly with its regional offices to clarify this matter.
Background: As of April 2010, owners of market‐rate properties built before 1978 will have to comply with EPA lead safety regulations that govern common renovation and repair activities. (Age‐restricted properties, properties with no children occupying them and properties that have been certified to be free of lead‐based paint by a state inspector are exempt from the RRP regulations.)
Under the regulations, if renovation or repair work undertaken on a covered property disturbs more than six square feet of surface area for interior work or 20 square feet for exterior work, the work must be carried out by a trained and certified renovator.
This rule establishes requirements for training renovators, other renovation workers, and dust sampling technicians; for certifying renovators, dust sampling technicians, and renovation firms; for accrediting providers of renovation and dust sampling technician training; for renovation work practices; and for recordkeeping.
Read the letter from the EPA to NAA/NMHC*
*Member login required.