The National Association of Home Builders has developed two new documents to help members comply with the Environmental Protection Agency Lead; Renovation, Repair and Painting (RRP) Rule. The first document addresses inspections and the second tackles recertification.
RRP Inspections – What to Expect is based on a guidance document released in May for inspectors who conduct inspections or audits to monitor compliance with the RRP rule.
RRP Certification/Recertification Q&A is an updated resource compiling information on firm and individual renovator certification and training requirements, including recent Environmental Protection Agency action that modified the requirements of the refresher training which certified renovators must take to maintain their certifications.
Remodelers who are certified by the Environmental Protection Agency (EPA) to work on homes that may contain lead paint under the Lead: Renovation, Repair and Painting (RRP) rule now have the option to complete refresher training online, according to an EPA announcement.
However, EPA re-certifications obtained via an online refresher course will be valid for only three years – versus five years for hands-on training courses – and can only be exercised every other re-certification cycle.
“As a longtime advocate for a simplified re-certification process, National Association of Home Builders Remodelers Council appreciates that EPA’s changes provide some flexibility, but the limited and convoluted parameters of the online training option are unnecessarily complicated and could affect the number of renovators who opt to become re-certified,” said NAHB Remodelers Chair Tim Shigley, CGR, CAPS, CGP, GMB, GMR, a remodeler from Wichita, Kan.
“Whether they choose to refresh their training online or in person, with the March 31 re-certification deadline looming for over 100,000 remodelers, and thousands more later in 2016 and 2017, remodelers are left with precious little time to meet their re-certification obligations.”
Additionally, certified renovators who were grandfathered in under a HUD or EPA lead-based paint training course before the RRP rule was adopted must attend a refresher course with a hands-on component. The rule also made several streamlining and clarifying changes to RRP provisions that apply to training providers.
EPA’s changes only apply to those states where EPA administers the program. The 14 states that administer their own programs will have to take legislative or regulatory action to adopt the online refresher course option.
The White House Office of Management and Budget released the final rule to EPA on Jan. 21.
For online or in-person refresher training, remodelers should contact their Home Builders Association of Greenville, or they can find a course on EPA’s website. More information on how to determine specific deadlines can be found using “What You Need to Know about EPA Lead-Safe Re-certification.”
If you are a builder or remodeler, this information from NAHB regarding the EPA’s crackdown on lead paint is crucial for your business.
Some regional offices of the Environmental Protection Agency (EPA) are changing the way they approach lead-safe work practice inspections, which could be a factor in the rising number of companies fined for violating EPA regulations.
EPA’s approach to lead-safe work practice inspections varies by region. Region 7 (Midwest) is the latest to employ a more targeted approach, having recently increased its focus on the St. Louis, Mo., area.
The strategy mirrors what was done during the summer of 2014 in EPA Region 1 (New England), which concentrated its efforts primarily in New Haven, Conn. EPA says the strategy led to improved compliance and awareness of the Lead-based Paint Renovation, Repair, and Painting (RRP) regulations. Out of the 65 inspections conducted in New Haven during that period, EPA issued enforcement actions against six companies.
“After seeing what was done in Region 1, we saw an opportunity for us to not only educate the remodeler community, but also the general public to help drive demand for the remodelers who are certified to do the job the right way,” said Jamie Green, chief of the toxics and pesticides branch for Region 7.
EPA issued a press release and conducted radio interviews when the initiative kicked off last August. Since then, 26 inspections have been conducted in St. Louis to evaluate lead-safe work practices.
Inspectors also began conducting “compliance assistance visits,” reaching approximately 200 remodelers throughout the city. The visits were done at times when regulated work was not being done, so rather than carry out an inspection, the inspectors would explain the RRP regulations, deliver information packets and answer questions.
Projects that receive full inspections are identified in a variety of ways, but primarily as a result of tips and complaints submitted by the general public, as well as from EPA-lead searches of publicly available information.
Still, many are conducted on an ad-hoc basis, according to Green, who says inspectors will often drop in on a project while traveling to and from predetermined inspections.
Next month, Region 7 will launch an advertising campaign to raise awareness among St. Louis-area consumers about the risks of lead exposure.
“The ultimate goal here is to protect children’s health,” Green said. “There are a lot of remodelers out there who are doing it right, so a large piece of this is to make sure we’re reaching out to consumers about the value of hiring those certified renovators.”
Green says it’s too early to determine the impact of the new, targeted approach. However, the focus on St. Louis will continue through the end of the year, when Green will assess the initiative’s effectiveness and decide if similar measures would be worthwhile in other parts of the region.
Nationwide, the number of enforcement actions against businesses that violated the RRP regulation increased in 2015. Seventy-five companies received fines of $2,000 to more than $50,000, mostly for violating work practice standards and/or failing to obtain proper training and certification regarding lead-safe work practices.
For more information about how to comply with the RRP rule, visit nahb.org or visit the HBA of Greenville at hbaofgreenville.com.
The Environmental Protection Agency (EPA) Administrator has signed a final rule extending certain renovator certifications under the Lead Renovation, Repair and Painting (RRP) program.
EPA estimates that the rule, which went into effect the same day it was published in the Federal Register (April 16), will affect up to 380,000 certified renovators.
Under the final rule:
- Remodelers and other contractors who got their EPA Lead-Safe Certified Renovator certifications on or before March 31, 2010, now have until March 31, 2016, to get recertified.
- Remodelers who got their certifications between April 1, 2010 and March 31, 2011, will have one year added to their five-year certification.
- Once they get re-certified, remodelers will have another five years before they have to re-up.
At your HBA’s urging, EPA extended these certifications because they would otherwise have expired before planned improvements to the RRP rule could be made. EPA proposed anamendment to remove the hands-on training requirement for the RRP refresher training course in January, but is unlikely to be finalized before November.
Without the certainty provided by the extension, almost half of all certified renovators would have been shut out of the opportunity to take advantage of the savings offered by this proposal.
- The EPA extension of certifications will not affect all certified renovators:
- The 5-year certification remains in effect for renovators who received their original certification after March 31, 2011.
- The extension does not apply to renovators operating under one of the 14 state authorized programs regardless of when they originally received certification. (See map)
Also, the rule only applies to individual, not firm certifications.
For more information, visit A Remodeler’s Guide to EPA Lead-Safe Certified Renovator Recertification. Learn more about the EPA Lead Paint rule at nahb.org/leadpaint
The National Association of Home Builders recently submitted comments supporting EPA’s plan to revise the Lead Renovation, Repair and Painting Rule (RRP) to eliminate a requirement that the EPA LeadSafe Certified Renovator re-certification course have a hands-on component.
The change would allow remodelers and other contractors to re-certify online, saving time and money for individuals and firms who have been certified for years. However, contractors obtaining certification for the first time would still need to complete the hands-on portion of the training course.
Given that a large number of certified renovators must complete a refresher training course by July 1, EPA has proposed providing a six-month extension for renovator certifications that expire by that date. Extending the deadline is a good first step in mitigating the concerns regarding the timing of this proposal and help ensure that as many renovators as possible can take advantage of the savings provided by the streamlined requirements of the proposed rule.
In its comments filed Feb. 13, your Home Builders Association supported EPA’s efforts to increase affordable access to the renovator refresher training courses, and to extend the completion deadline to ensure that those renovators who came into the RRP program when it launched in 2010 have access to online-only training options.
NAHB also urged EPA to expedite consideration of the extension to provide the industry with needed certainty.
To find out when your EPA LeadSafe Certified Renovator certification expires, visit the EPA firm locator page. Learn more about the EPA lead paint rule recertification process, get additional details on the EPA lead paint rule at nahb.org/leadpaint