On March 31, 2008, the U.S. Environmental Protection Agency (EPA) announced a final regulation imposing new requirements on anyone engaged in renovation, repair and painting activities, including apartment maintenance workers, that disturb lead-based paint in housing built before 1978. NMHC/NAA have been actively involved with the EPA and other federal agencies on the proposed rule.
The rule, which goes into full effect in April 2010, requires workers who disturb lead-coated surfaces to complete an EPA-certified training course on lead-safe work practices. Workers must also verify that the work site was appropriately cleaned based on EPA standards.
In a move that will surely cause confusion among property owners, the rule diverges from the previously established standard of when such requirements kick in. All other lead-based paint regulations are triggered when work disturbs more than two square feet of painted surface. This latest regulation is not triggered until six square feet of painted surface are disturbed. The final rule creates other inconsistencies. For instance, the existing federal regulations explicitly prohibit dry sanding of lead-coated surfaces; this rule would permit renovators to use this practice.
Full DocumentFinal Renovation, Repair and Painting (RRP) Regulation
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