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Latest Update to the RRP Rule


Renovation Repair and Painting Rule Changes Effective July 6, 2010


Lead Safe Certified Firms need to be aware of the many changes that will take place in the Renovation, Repair and Painting Rule on July 6, 2010.


The first proposed change is the addition of clearance testing. As the rule stands now, Lead Safe Certified Firms have the option of letting their Certified Renovator perform the cleaning verification (commonly referred to as the white glove test) or of having a clearance test.


In the proposed change is approved, a clearance test will be a requirement in certain situations.  A Clearance Test is where a third party person, usually a lead inspector or risk assessor, comes in and wipes an area with a moist wipe. That wipe is sent to an EPA approved laboratory to verify the amount (if any) of lead dust. You can learn more about this here.


The second proposed change is where they are considering including public and commercial buildings in the RRP. To learn more, go here.


Rule Changes


Also on July 6, 2010, changes to the Renovation, Repair and Painting Rule go into effect.


The Opt-Out provision finally disappears. It is the general consensus that you need to be through with disturbing painted surfaces in the project before July 6. A safer threshold would be if you are not going to be completed with the entire project before July 6, you should plan on following the RRP.


There will be 2 record requirement changes. The first is that a copy of the sample checklist should be given to the homeowner/tenant along with the final invoice or 30 days after the end of the project, whichever comes first. You can use your own forms, but it must include all items listed in the sample checklist. A copy of the sample checklist can be found here.


The second record requirement change is if you decide to use clearance test, instead of verification. If you do, a copy of the lab report should be given to the homeowner/tenant within the same time frame as mentioned above.


Once a rule is implemented, it is difficult to change it.


­          Dean Lovvorn



© 2010 Criterion Environmental, Inc.


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