PRE and RRP Frequently Asked Questions (FAQ'S)
EPA Renovation, Repair, and Painting Rule
The Environmental Protection Agency (EPA) issued a final rule on April 22, 2008 under the authority of § 402(c)(3) of the Toxic Substances Control Act (TSCA) to address lead-based paint hazards created by renovation, repair, and painting (RRP) activities that disturb lead-based paint in “target housing” and “child-occupied facilities.” According to this rule, contractors conducting RRP activities on any pre-1978 residential property, apartment or child occupied facility with children less than six years of age will need to be trained as renovators and certified as firms through EPA. The final rule goes into effect on April 22, 2010.
At least 66% of the homes built between 1940 and 1960 contain lead-based paint. For those built before 1940, around 90% contain lead-based paint. Lead exposure can cause damage to nearly every organ in the body, and is especially dangerous for children, whose bodies are still developing. Children who are exposed to even low levels of lead are more likely to experience learning delays, developmental problems, and behavioral problems. Adults who are exposed to lead through their work can also experience health problems, and they can accidentally bring lead residue home to their families.
What is renovation?
Renovation is defined as modification of any existing structure that results in the disturbance of painted surfaces. The RRP rule covers all activities done for compensation that disturb painted surfaces including most repair, remodeling and maintenance activities, such as window replacement, weatherization and demolition.
Who is affected by this rule?
All firms performing RRP work for compensation must become EPA-certified as a renovator and firm in order to work on pre-1978 properties. This includes contractors, carpenters, painters, HVAC, plumbers, electricians, property managers and others who disturb known or presumed lead-based paint during renovation. Rental property owners are considered to have been compensated for their work through the payment of rent, so they are included in this rule. Renovation activities are excluded from this rule if painted components are determined to be lead-free via a lead inspection or lead risk assessment or by use of chemical test kits approved for use by the EPA.
How do I become a Certified Renovator?
There are two ways to become a certified renovator:
- The first way is to take the one-day (8-hour) initial training course from an EPA accredited training provider. Upon successful completion of the course, students are issued their EPA certificate that is valid for five years. To maintain certification, a student must take a refresher course PRIOR to their expiration date.
- The other way a person could get certified is by taking a refresher course based on being “grandfathered” in to the system because they have successfully completed training in EPA approved courses. The refresher course is shorter (four hours) than the initial course but the student is required to provide proof of eligibility prior to enrolling in this course. A copy of the successful completion certificate from the eligible course is required.
For a complete list of EPA authorized RRP trainers go to the EPA-Accredited Renovation, Repair, and Painting Program (RRP) Training Providers website.How do I become a Certified Firm?
To become certified as a firm, a contractor must submit an application and fee to EPA. The certification is valid of five years and allows the firm to work in any non-authorized state or Indian tribal area. For additional information, including firm application information, go to the EPA Renovation, Repair and Painting (RRP) Information for Contractors website.