Breaking Down the RRP Rule

May 19, 2010
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The Environmental Protection Agency’s Renovation, Repair and Painting (RRP) rule is comprised of eight “modules,” as the EPA labels them. Within the modules there are 11 different hands-on exercises the EPA calls “skill sets.” The good news for restorers is that these are skills that field technicians use daily; it’s the areas in which the EPA now mandates we use them that are new.

Just how big is this new rule? It’s a federal law that encompasses everyone from maintenance personnel doing routine repairs to a water mitigation technician responding to a six-story flood in the middle of the night. That’s pretty big.

Lead poisoning is a completely preventable disease. Dust is the problem, and contractors make the dust. An average packet of sweetener contains 1 gram of sweetener. If instead of sweetener it contained crushed lead-based paint, it would be enough dust to contaminate 125 square feet. The paint dust settles on surfaces that are easily and readily available to children. Through normal hand-to-mouth contact, children ingest the dust from their toys, the piece of candy that fell onto the floor, as well as unknowingly being exposed by the particles emitting from your work clothes as you strap them in the car seat.

Today we’ll take a quick look at the eight modules that make up the RRP rule, and look at the how and why of each.

Module No. 1

The first module continues to describe the health problems related to lead.

Module No. 2

Here come the federal regulations. This is the start of your standard operating procedure, and it changes our initial contact with the costumer. When we receive a lead and start with our normal round of questions, one of the first things we need to find out is if the home or building falls under target housing: “Was the home built prior to 1978?” “Are there any children under the age of six who live in the building?” “Does a child under six visit the residence twice a week?”

If the answer to any of these questions is “yes,” you must now follow the EPA protocol for lead-based paint activities as follows:
  1. Comply with the pre-renovation education requirement.
  2. All covered renovations, repairs, and painting activities must be performed by a Certified Firm using certified workers.
  3. Keep appropriate records.
  4. Certified Firms must ensure that workers trained on lead safe practices perform all work (note: if you have subcontractors, outside labor, etc., on the jobsite, they must be trained). The person responsible for jobsite activities (supervisor, foreman, project manager) must be a Certified Renovator. This person can train other workers through on-the-job training. These workers are non-certified workers, meaning they have on-the-job training but have not completed an EPA-approved certification class. The Certified Renovator must be designated by employer to conduct set-up activities, ensure work is done according to standards, confirm cleanup and give cleaning verification.
  5. Certified Renovators:
    • Must take a EPA-approved 8 hour training course from an EPA accredited provider (the list is available on the EPA website).
    • Responsibilities of the certified renovator include performing the work and directing the work of non certified workers, maintain copies of initial and/or refresher training certificates onsite at all times, remain onsite during sign posting, work area set up, and cleanup phases of work. If using an EPA approved test kit they would be the person conducting the test. Skill set 1 is performing a test with approved test kit.
    • If not on-site, contact info must be available and the Renovator must be accessible by phone at all times work is being performed.
    • Ensure that containment is maintained, and determine which work practices are best used to minimize dust.
    • Conduct the cleaning verification procedure.
    • Must compile a written report of the work.
  6. HUD covers federally owned or assisted target housing. The requirements are very similar to the EPA’s. In some areas they are more stringent: prohibited practices, de minims levels, and occupant notification.
  7. Please note that some states have different regulations than the EPA. Check with your state, go to the EPA website www.epa.gov/lead, and know the HUD regulations (you can find them at www.hud.gov/offices/lead.)


Module No. 3

This one is all about The Pre-Renovation Education rule. After we have completed the call with our potential costumer, completed the lead sheet and determined that the job falls into the target housing, we must provide the owners/residents a copy of the “Renovate Right” pamphlet. The pamphlet may be copied for distribution as needed to comply with the standard.

For work done in homes, no more than 60 days prior to start of work firms must either obtain owners’ written acknowledgement or mail the pamphlet via certified mail at least 7 days prior to work. For situations involving tenants, either written acknowledgement or proof delivery was attempted and was unable to obtain signature must be obtained. All proof must be documented for 3 years.

If the work is being done in common areas, you must notify affected residents about where information about the work is posted, if work in nearby common areas will affect them. The following information should be posted about work in common areas: describing the nature and location of the work, listing the work start and end dates, and a copy of the “Renovate Right” pamphlet.

For work in child-occupied facilities, distribute the “Renovate Right” pamphlet to the owner of the building and to an adult representative of the child-occupied facility, following the same documentation requirements as for homes. Firms must also provide notification to parents and guardians of children using the child-occupied facility, following the same requirements as for tenants affected by renovations in common areas. (More details on the required documentation are covered in Module No. 7.)

The module also describes how to determine if there is lead-based paint. As restorers we have some options, e.g. some states allow the use of an EPA-approved test kit. Basically swab the surface and if lead is present in the paint it will change color. If lead is indicated, follow the protocol.

If your state does not allow the test kits, then what? Hire a lead inspector to test for lead? This can be pricey. Better to assume that all target housing has lead-based paint and follow the protocol accordingly.

Module No. 4

The emphasis here is on the need and purpose of containment. For restorers it is very similar to the work practices and engineering controls of a mold job: post signs; remove furniture; cover what can’t be moved; close and seal the doors (here they want to utilize the “s” cut and a flap, 6 mil), and cover HVAC and other mechanicals.

Exterior work is case by case. Most cases require a 20-foot work zone on all sides, two layers of plastic, vertical containment, etc. Skill sets 3-5 cover the above-mentioned tasks.

Take a house fire that fits under the definition of targeted housing, with exterior damage to the wood siding and peeling paint. There’s a high probability that the paint has lead in it. How do you repaint the exterior without disturbing the peeling paint?

You don’t. The question we need to ask ourselves is how to prevent the dust we will ultimately create from drifting to the neighbors yard, the playground down the street, or the small pond. This is what the RRP rule wants us to ask ourselves.

Module No. 5

Module No. 5 takes us to the work itself. It lists prohibited practices such as open flame burning, heat gun above 110F, etc. It details the need for HEPA and HEPA attachments. As with a mold job again cross contamination is an issue when leaving contained zone. Periodic cleaning in the work site is recommended.

Skill set 6 involves putting on and taking off personal protective equipment. As always, follow OSHA standards for all PPE.

Module No. 6

We’re at the cleaning process. Interior cleaning requirements again resemble a mold job. Collect all paint chips and loose debris, remove plastic sheeting from walls and windows, leaving only the floor and sheeting separating non-contaminated rooms in place, HEPA vac from high to low, cleaning at least 2 feet beyond the containment zone, and use wet wipes.

The next step is to perform a visual inspection. The Certified Renovator performs this procedure. Check all horizontal surfaces; if visual dust or debris is present, you must re-clean the area.

Once the visual inspection process is complete, go on to the cleaning verification. This consists of wiping each windowsill with a separate cloth. Wipe uncarpeted floors and countertops. Compare the cloth with the Cleaning Verification Card. If the cloth matches or is lighter than the CV card, you have passed the test. If it is darker or dirtier, re-clean the area and repeat the procedure.

Once a CV is obtained, remove all sheeting and HEPA vacuum again.

The debris may be handled as normal construction debris. Skill sets 7-8 are the hands-on cleaning process; set 9 is bagging waste (here a goose-neck is recommend), and sets 10-11 are the cleaning visual inspection and verification hands-on demonstration.

Module No. 7

Here we find the guidelines for the documentation needed:
  1. Records to be kept on-site
    • Copy of certified firm
    • Copy certified renovator(s) certifications
    • Non- certified worker training documentation
  2. Records to document the job
    • Copy of certified firm and certified renovator(s) certifications
    • Non-certified worker training documentation
    • Designation of a certified renovator to the job
    • Information on and results of use of EPA-recognized test kits.
  3. Pre-Renovation Education Records
    • In target housing-Individual Units:
      1. When contacts with the owner and occupants were attempted
      2. Written proof of when contacts were made
    • In target housing- Common Areas:
      1. Documentation of when and to whom written notification was delivered for each unit affected
      2. What notices were posted, and when and where they were posted
    • In Child-Occupied Facilities:
      1. When contacts with the owner and occupants were attempted
      2. Written proof of when contacts were made
      3. Whether and when contact was made with the owner or adult representative of the child-occupied facility
      4. What notices were posted, and when and where they were posted.
  4. Non-Certified Worker Training
    • Worker’s name
    • Description of lead safe work practices the worker is training to perform
    • Completed and signed skills evaluation checklists
    • Date(s) of training
    • Name and signature of the Certified Renovator who conducted the training
  5. Test Kit Reporting
    • Submit a report to the person contracting for the work within 30 days after the end of the renovation, containing:
      1. Manufacturer and model of the EPA-recognized test kit.
      2. A description of the components tested
      3. The location of components tested
      4. Results of the testing
  6. Post-Renovation Reporting
The end of the renovation report should describe the whole project from posting signs to cleaning verification or clearance. The report should name the Certified Renovator designated by the Certified Firm as responsible for lead-safe work practices on that project. Also include proof of certification for the designated Certified Renovator. The report also must have a signed statement from the Certified Renovator that covers the following areas:
  • Proof of non-certified worker training
  • Proof of posting warning signs;
  • Description of results from used of EPA-recognized chemical spot test kits
  • Description of work area containment
  • Description of on-site waste containment and transport
  • Proof of proper post-renovation work area cleaning
  • Records of inspections and/or risk assessments conducted by Certified Lead Inspectors or Risk Assessors, if applicable
  • Proof of successful cleaning verification.


Module No. 8

Module No. 8 gives the instructions for training non-certified workers. For teaching lead safe work practices use the EPA’s “Steps to LEAD SAFE Renovation, Repair, and Painting.” For copies and more details, visit the EPA website.

The rule has two core aspects that, in my opinion, directly correlate with heart of our industry. The duty to prevent the damage from getting any worse from the moment we arrive as restorers ties in with the importance the rule places on containment. Ironically, one of the exclusions is that emergency renovations only require the cleaning and cleaning verification processes. But do yourself a favor here and spend a few more hours upfront setting up containment, rather than spending many more later cleaning surfaces, duct work, etc.

By far the most demanding aspect of this rule is recordkeeping and documentation. Sound familiar? Our industry is demanding more and more documentation. It is a checks-and-balances system to ensure we did what we say we did. Take pictures and as a certain wise man tells me everyday, “If it’s not in writing, it didn’t happen.”

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