Please find below answers to some of the more common questions regarding Lead Paint Laws and RRP. Please click a question to open up the answer.
A “Lead License” is required of ALL contractors performing RRP work. The application, fee & instructions can be state specific. If you live in New England, visit our Lead Paint Classes page for upcoming classes in your area.
These are lead projects that exceed the limitations of RRP, and require substantial additional training. If you live in New England, visit our Lead Paint Moderate Risk Deleading page for upcoming classes in your area.
Personal Protective Equipment is required when employees are exposed to hazardous amounts of airborne lead. The exact equipment needed can vary depending upon level of worker exposure to lead.
According to OSHA 1910.134, respirator training must include: 1) Proper Use, 2) Cleaning, storing, inspecting and repairing, 3) Emergency situations, 4) Limitations and 5) Signs of failures. If you live in New England, visit our Respirator Protection Training and Fit Testing page to schedule a private class in your area.
Recordkeeping requirements can be state specific. All projects will have some records that must be kept on site, while others may be kept at the office. Failure to comply is a fineable offense.
Pre-Renovation Education refers to the contractor’s obligation to educate the client on the dangers of RRP work using potentially state specific booklets.
There are specific signs mandated for RRP projects. The requirements for wording and placement can be state specific but must always meet OSHA 1916.62 (m).
The expiration date of an initial RRP certificate is 5 years from course completion date. Refresher certificates expiration periods depend if it was acquired in a live (in person) class, or an online class. If you live in New England, visit our Lead Paint Classes page for upcoming classes in your area.
YES! YOU MAY NEED MORE THAN ONE!
You may sub-contract your RRP work to another contractor, but as the “GC” you would still have to get a “Lead License” for your company… and you would be subject to fines & penalties if your sub-contractor violated the lead law.
Do you create dust or paint chips when you work in old homes built before 1978?
Your training certificate will be valid… but will you know the rules in that state that may differ from where you were trained?
Employers MUST provide a workplace free of hazards likely to cause harm. A respirator PROGRAM is often the only way to achieve compliance. Prior to a worker wearing a tight fitting respirator, the worker must undergo: 1) medical approval 2) educational training and 3) fit testing. Many of these steps must be repeated at least annually. If you live in New England, visit our Respirator Protection Training and Fit Testing page to schedule a private class in your area.
ANY work practice that releases lead particles back into the air is prohibited.
Can you ensure that the mess you make is confined to your work area? Does the state / town that you’re working in require you to capture, collect, filter & properly dispose of your waste water? These restrictions can be state specific.
Enforcement agents have the authority to attach a fine based on the gravity of the violation. The bigger the mistake… the more painful the fine! The fines can vary by state.
It will vary depending if your state accepted the EPA RRP or have passed their more stringent law. If your state accepted the EPA RRP law, then EPA would be the main enforcer. However, the towns health officer also has the authority to enforce any action that threatens public health.
Solid RRP waste is secured and disposed of in a manner that prevents the spread of dust. If the waste is generated from a non-residential project, or if the waste isn’t solid… the rules may change substantially. These rules can be state or town specific.
In most states, the certified supervisor is allowed to make this determination based on a combination of personal experience & specific site conditions. Some states have minimum thickness requirements.
At a minimum, occupants will need to be notified. Depending on which part of the structure is renovated, pre-renovation education may be necessary.
It has to do with intention of job. Are you removing a lead hazard – abatement course are required. Are you renovating/repairing/painting a home built before 1978 in which the components you handle happen to contain lead? – RRP is the course most likely you would need. If you live in New England, visit our Lead Paint Classes page for upcoming classes in your area.
You can renew your certification by attending a refresher course. In some states, there might be a “grace period” after your expiration, however EPA does not offer any grace period to be eligible for a refresher course. Should you find yourself outside of any grace or expiration period, you must retake the initial 8 hour course. If you live in New England, visit our RRP Refresher Classes page for upcoming classes in your area.
A “notice” is most likely a court order to abate discovered lead hazards. You could ask the client for a signed document stating there is none or contact the state lead department to inquire.
A legitimate RRP course would cover this in detail. You could also seek the information on EPA’s website for the Renovate, Repair and Paint Program.