The record keeping requirements have been changed.Copies of records must be given within 30 days of the final invoice or completion of the project to the home owner or resident. The records that are turned over must demonstrate compliance with the training and work practices of the RRP rule, basically the checklist and the results of any testing.
The Opt-Out provision has been eliminatedand lead-safe work practices will apply to all pre-1978 houses.
Both amendments will take effect 60 days after publication in the Federal Register. TheRenovate Right brochurewill be amended accordingly by the EPA.
The EPA also published two proposed amendments to the RRP that are now open for comment:
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Lead: Clearance and Clearance Testing Requirements for RRP will require dust
wipe testing after completing the existing cleaning verification procedures for
some/most renovations. The EPA will be accepting comments on this
proposal for 60 days and expects to finalize the amendment by July 2011.
- Lead: RRP for Public and Commercial Buildings will apply lead-safe work practices and training requirements to public and commercial buildings. The EPA has set deadlines to issue a proposal by December 15, 2011, and take final action by July 15, 2013.
Although the rule has been effective since April 22, 2010, the EPA will not take any enforcement action against firms who have applied for firm certification before April 22 and are just waiting for their paperwork, they expect these applications to be processed by June. EPA will still enforce rules about work practices and training requirements for these firms. If a firm is not certified and does not have trained renovators on staff - you will be breaking the law!
For more information, visithttp://www.epa.gov/lead/new.htm.
