EPA's Lead Renovation, Repair, and Painting (RRP) Rule Information

EPA's Lead Renovation, Repair and Painting Rule (RRP Rule) requires that firms performing renovation, repair, and painting projects that disturb lead-based paint in homes, child care facilities and pre-schools built before 1978 have their firm certified by the Department of Commerce, use certified renovators who are trained by EPA-approved training providers, and follow Lead-safe work practices.

The resources in this area are designed to keep our member companies compliant, while avoiding potential fines and penalties that can be as high as $37,500 per day, per incident. The EPA and the Department of Commerce both oversee compliance of the RRP rule. Please, do not hesitate to contact BNCW for more information!

Key Points:

1. A contractor cannot bid on or begin work on a renovation project that involves a structure built prior to 1978, unless properly certified and registered.
2. Regardless of what you may have heard, hiring a third-party renovator or abatement firm does not relieve a general contractor from the certification and registration requirements!
3. The General Contractor is responsible for ensuring that every sub-contractor firm used on the project is also properly certified and registered. Both the General Contractor and the sub-contractor will be fined in the event that a sub-contractor is not compliant.
4. There is a two-step process that each contractor, property manager and maintenance personnel must follow in order to insure compliance with the RRP certification rules. First, at least one individual within the firm must become certified by completing an approved eight-hour training course. Second, the firm must become certified by sending an application to the Department of Commerce, along with the requisite $25 fee.
5. There are four required record-keeping forms that each contractor must maintain for three-years for each pre-1978 RRP project. 

Getting Certified -- The initial individual certification training is provided by an EPA-approved trainer and involves an eight-hour class, resulting in a certification that is good for a five-year period. Renewing your certification requires a four-hour refresher course. In addition to at least one individual in the firm being certified, the firm itself must be certified, too. The following are helpful links to meeting the two-step certification requirements:

• Do the RRP Requirements Apply to Me?
• Contractor, Property Manager & Maintenance Personnel RRP Compliance
  Guide
• Individual Student Training Manual
• Next Certified Lead Renovator Class Offered by BNCW
• Now That You've Taken the Certified Lead Renovator Class, You Must Register Your
  Firm, Too!

Four Forms Required for Recordkeeping -- The following four forms are required to be maintained by the contractor, property manager and maintenance personnel for every project. If a compliance officer visits the project site, these completed forms will be included in the documentation they ask you to produce:

1. Pre-Renovation Form (You are required to provide the homeowner THIS PAMPHLET prior to beginning work!)
2. Renovation Recordkeeping Checklist
3. Staff Training Form
4. Lead Test Kit Documentation Form

EPA and Department of Commerce Contact Information for Compliance Assistance:

• EPA Region 10 Compliance Officer, Kim Farnham
• Department of Ecology Outreach