EPA Reducing Lead Exposure with RRP Rule

THURSDAY, OCTOBER 27, 2022


The U.S. Environmental Protection Agency is working to reduce childhood lead exposure through improved compliance with the lead-based paint Renovation, Repair and Painting (RRP) Rule.

As part of the Agency’s efforts, this week it’s hosting a National Lead Poisoning Prevention Week (NLPPW), which officially kicked off on Oct. 23 and will last until Oct. 29.

Throughout the week, EPA Region 8 shares that it is summarizing compliance activity related to the RRP Rule and reminding residents and owners of pre-1978 homes about the risks of lead-based paint and the importance of following lead-safe practices to keep families safe.

“Protecting children’s health is a central part of EPA’s mission and lead exposure in older homes remains a significant risk for families in many communities,” said Suzanne Bohan, Director of EPA Region 8’s enforcement program. “EPA expects all renovation companies to ensure their contractors are trained and follow lead-safe work practices.” 

EPA Lead Paint Standard, Safety Measures

Back in 2008, the EPA released the Lead-Based RRP Rule. The RRP (amended in 2010 and 2011) aimed to protect the public from any and all lead-based coating hazards associated with renovation, various repairs and activity.

The RRP rule protects residents of pre-1978 homes from lead-based paint disturbed during renovation, repair or painting activities. The rule requires that firms that perform or offer to perform renovations in pre-1978 houses need to be certified by the EPA and assign individuals who have been trained to use lead-safe work practices; disclose important safety information to residents prior to the work; and document their compliance with the rule.

The rule officially went into effect on April 22, 2010.

In 2009, petitioners requested that the EPA provide more adequate protection for children by providing more stringent lead paint standards. By 2011, the EPA acknowledged this need but failed to provide a timetable or made any moves to propose a new rule.

By June 2018, the EPA released another proposal to the dust-lead hazard standards; the action was stemmed from a December 2017 ruling by the U.S. Court of Appeals for the Ninth Circuit, which ruled that the agency must reevaluate the risks from lead paint.

According to the EPA, lead-contaminated dust from chipped or peeling lead-based paint in homes built prior to 1978 presents one of the most common causes of elevated blood lead levels in children. Infants and children are especially vulnerable to lead paint exposure because their growing bodies absorb more lead than adults do, and their brains and nervous systems are more sensitive to the damaging effects of lead.

The June proposal was reportedly in response to a lawsuit filed in August 2016 against the EPA by a coalition of environmental and community-led organizations, who charged that the EPA had duties to uphold the TSCA and its amendments contained in the Paint Hazard Act.

In June 2019, former EPA Administrator Andrew Wheeler and then-U.S. Housing and Urban Development Secretary Ben Carson announced new standards for lead, specifically found in dust on floors, windowsills and miscellaneous surfaces to protect children from its harmful effects.

To continue to protect children’s health and make progress on the dust-lead issue, the EPA lowered the dust-lead hazard standards from 40 micrograms of lead per square foot to 10 micrograms per square foot on floors and from 250 micrograms to 100 micrograms on windowsills.

The new standard applies to all inspections, risk assessments and abatement activities in various hospitals, childcare facilities, certain schools and housing built before 1978.

In January 2021, the final rule to lower the clearance levels for the amount of lead that can remain in dust on floors and windowsills after lead abatement was approved and the new standards were incorporated into the Section 402/404 lead-based paint activity regulations as well as the Section 1018 real estate disclosure regulations.

By October, the EPA announced that it had launched a new training initiative, Enhancing Lead-Safe Work Practices through Education and Outreach, in Southern California communities.

The new program aims to raise awareness about childhood lead exposure and protect environmentally overburdened and underserved communities across the nation from lead exposure. The initiative arrives in accordance with the Biden-Harris Administration’s commitment to advancing environmental justice.

The two-pronged approach to reducing lead exposure includes the following initiatives:

  • Lead Renovation, Repair and Painting (RRP) training for contractors: EPA will provide free trainings, in both English and Spanish depending on the location, for contractors working in selected communities, offering an opportunity for them to become RRP certified. Anyone who is paid to perform work that disturbs paint in housing and child-occupied facilities built before 1978 per the Lead RRP Rule must be certified, and this training is designed to equip contractors and firms with the tools they need to serve their communities and adhere to the Lead RRP Rule.
  • Lead Awareness Curriculum Train-the-Trainer sessions for community leaders: EPA will offer free Lead Awareness Curriculum Train-the-Trainer sessions, in English with simultaneous Spanish interpretation, designed to equip community leaders with tools and resources needed to educate their communities about lead, lead exposure and actions that can be taken to reduce and prevent childhood lead exposure, including hiring RRP certified contractors. The Lead Awareness Curriculum is a series of four modules which include lesson plans, worksheets, key messages, presentation slides and kids’ activity sheets that community leaders and other instructors can use to improve public awareness of the dangers associated with lead exposure and promote preventative actions.

Latest Lead Exposure Initiative

At the beginning of the month, the EPA announced the official launch of a nationwide training and outreach initiative focused on reducing childhood lead exposure.

Taking place for a second year, the Enhancing Lead-Safe Work Practices through Education and Outreach (ELSWPEO) program is part of the Biden-Harris Administration’s commitment to advance environmental justice.

“This initiative demonstrates how collaboration between national, state, local and Tribal governments and organizations can protect underserved communities from exposure to toxic chemicals like lead,” said Michal Freedhoff, Assistant Administrator for the Office of Chemical Safety and Pollution Prevention, at the time. “Many communities across the U.S. are still at risk for lead exposure, and we are committed to lowering and preventing it.”

According to an Agency-issued news release, the EPA will offer free training on lead-safe work practices, which include RRP lead-safe certification training and Lead Awareness Curriculum sessions to contractors in 10 communities across the nation and its territories.

As part of the program, two sessions will be offered. These include a Lead Awareness Curriculum Train-the-Trainer session, which is designed to equip community leaders to educate their communities about lead and lead exposure, as well as actions to reduce and prevent childhood exposure. An Understanding Lead session will educate community members interested in learning more about lead, lead exposure and actions to reduce their exposure.

The communities chosen for involvement due to having known lead exposure issues and a demonstrated need for RRP-certified contractors include: Stratford, Connecticut; Loíza, Puerto Rico; Arecibo, Puerto Rico; Newark, New Jersey; Portsmouth, Virginia; Miami, Florida; Toledo, Ohio; St. Louis, Missouri; Billings, Montana (with a focus on tribal members); and Sacramento, California.

Last year, the program was reported to complete ELSWPEO outreach in 11 communities. In total, the EPA helped to certify 282 contractors in lead-safe work practices and educated 245 community leaders and 170 community members.

The initiative will complement the historic investment of $4 billion to reduce lead exposure from President Joe Biden’s bipartisan infrastructure law and support the Biden-Harris Administration’s commitment to ensuring all Americans can live in healthy homes.

What Now

According to the EPA, this year the Agency conducted 81 compliance monitoring activities, including providing educational materials to commercial renovators to promote compliance with the RRP Rule, and issued 13 Notices of Noncompliance to contractors.

The EPA also reached agreements with eight contractors in Colorado and Montana to settle violations of the Rule resulting in over $30,000 in penalties.

Contractors settling RRP Rule violations in Colorado include Larsen Development Company, Colorado Quality Painting, A+ Handyman Home Improvement, Specialty Construction, Nehemiah General Contractors, and Capital Roofing and Restoration. Contractors settling RRP violations in Montana include Pella Windows and Doors and Paramount Construction and Remodeling.

In its news release, the EPA shared that these contractors’ violations varied, but included failures to obtain EPA lead-safe firm certifications, failures to maintain records documenting compliance and failures to employ lead-safe work practices when working on pre-1978 homes.

All cases have since resolved certification and training deficiencies and made commitments to future compliance.

More on NLPPW can be found here.

   

Tagged categories: Coating Materials - Commercial; Environmental Protection Agency (EPA); EPA; Good Technical Practice; Government; Health & Safety; Health and safety; Lead; Lead; Lead Disclosure Rule; Lead paint abatement; Lead Renovation, Repair and Painting Rule (LRRP); Lead rule; Lead test kits; NA; North America; Residential; Safety; Workers

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