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RRPedia has been created by Shawn McCadden to help remodelers and others affected by the New EPA Renovation Repair and Painting Rule. 

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What is Required To Become A Licensed Lead Inspector?

Posted by Shawn McCadden on Fri, Aug 27, 2010 @ 09:32 AM

What is Required To Become A Licensed Lead Inspector?

Licensed Lead InspectorMany remodelers have shared with me that they have been entertaining the idea of become licensed lead inspectors.  Recognizing the new EPA RRP rule as here to stay, many see doing inspections as an opportunity to diversify their business's offerings and at the same time add some much needed revenue due to our current economic challenges.

I asked John MacIsaac of ASAP Environmental, a lead testing expert and recognized leader in his industry, to write an article for RRPedia.  The article below was written by John to help contractors understand what is involved if they would like to consider become inspectors.  John pointed out to me that licensing requirements definitely vary from state to state.  John's article is specific to Massachusetts requirements, but should help provide a general understanding of what to expect if you seek to be licensed in other states.

The Article:

The first step in being licensed as a lead inspector in Massachusetts is to attend a six-day, 48-hour CLPPP approved training course.  The course costs $1675 at The Institute of Environmental Education (IEE).  The training course teaches how to perform lead inspections and risk assessments in residential property in Massachusetts. Topics include background information on lead, sources of lead exposure, health effects for adults and children, regulatory information, testing equipment, and procedures for performing lead inspections, risk assessments, re-inspections and post compliance inspections.  Once the course is completed you have to take an exam given by the Massachusetts Department of Public Health.  You will need an 80% or better in order to pass the test.  There is no charge to take this test.

Blood Test VialUpon successful completion of the examination and a lead physical and blood test, you need to complete an apprenticeship program with a licensed Master Lead Inspector.  It costs between $3,000 and $5,000 to do an apprenticeship.  You must work with the Master Lead Inspector for a total of 80 hours and you must accompany the Master inspector on 15 inspections.  The 15 inspections will consist of 7 Initial Inspections (5 using the XRF gun and 2 using sodium sulfide), 6 re-occupancy reinspections or final deleading reinspections, and 2 PCADs (post compliance assessment determinations). 

Once the apprenticeship is completed the paperwork is sent to the Childhood Lead Poising Prevention Program (CLPPP) and they will issue you a lead inspector’s license for Massachusetts.  This license will allow you to do Initial Lead Inspections, Reinspections, and Lead Determinations.  It will also allow you to issue Letters of Reoccupancy and Letters of Compliance.  The license will only be valid in Massachusetts.  There is no reciprocity with your licenses, in other words you will not be able to use the license in any other state for inspections.  All other states in New England have their own licensing process that would need to be followed to inspect in that state.

After having preformed 75 Inspections or Reinspections you can apply for a risk assessors licenses in MA.  As a Risk assessor you can do risk assessments for interim control. 

CLPPP offers refresher courses that will need to be taken periodically to maintain your license.  They are a 1 day course with a test at the end of the day that you must pass in order to maintain your license

You must renew your license once a year.  For Lead Inspectors/Risk Assessors the renewal fee is $325.  For Master Lead Inspectors the fee is $425.

XRF GunBrand new XRF Machines go for anywhere from $15,000 to upwards of $30,000.  You may be able to purchase one used from the manufacturer or online.  It can cost upwards of $5,000 a year to maintain them. 

If you are a Certified State Licensed Renovator as well as a Certified Lead Inspector, Massachusetts will not allow you to do Comprehensive Initial Inspections, Risk Assessments, or Lead Determinations on your own property or a property you are working on (RRP) because of a potential conflict of interest.  You will be required to have it tested by another Massachusetts licensed inspector.

For information you can go to the following:

Childhood Lead Poison Prevention Program (CLPPP)

Massachusetts Childhood Lead Poisoning Prevention Program’s database for lead inspected homes.

MA Department of Occupational Safety (DOS)


Institute for Environmental Education (IEE)

RMD Instruments

Thermo Scientific

Note:  This information was provided by John MacIsaac of ASAP Environmental, Inc.

Topics: RRP Questions, Definitions, Lead Test Kits and Testing

Comparison of EPA RRP and MA RRP Rule Requirements

Posted by Shawn McCadden on Tue, Aug 24, 2010 @ 03:17 PM

Comparison of EPA and DOS RRP Rule Requirements

NOTE: DOS (Department of Occupational Safety) is now called DLS (Department of Labor Standards)

MA Seal


The MA Division of Occupational Safety has released a very helpful comparison of the new MA RRP rule with the existing EPA RRP Rule.   This comparison should help those doing RRP renovations under the recently enacted MA RRP Rule understand any difference between the two rules.



The following information is directly from the DOS web Site:


I.  Applicability of Requirements

EPA: The EPA RRP Rule applies to renovation, repair and painting (RRP) work conducted for a fee in pre-1978 target housing and child-occupied facilities where the work involves the disturbance of more than 6 ft2 of painted surfaces per room or more than 20 ft2 of paint on exteriors (total), except that the quantity exemptions do not apply to any projects involving window replacement or demolition of structures.

DOS:  Same as EPA.

II.  Firms or Entities Requiring Licensure

EPA:  All firms or other entities performing work subject to the Rule require certification as “Certified Firms.”

DOS: Firms or other entities performing work require licensure as “Lead-Safe Renovation Contractors,” except that the following entities may apply to DOS for a “Contractor License Waiver”:

1.  Entities that perform regulated work in facilities that they own, using their own employees.

2.  Entities that were certified by EPA (or a state delegated by EPA to administer EPA RRP Rule) prior to July 9, 2010.

DOS also allows Deleading Contractors licensed by 454 CMR 22.00 to perform regulated renovation work without being separately licensed as “Lead-Safe Renovation Contractors.”  Entities applying for a “Contractor License Waiver” do not have to pay a fee for the waiver but must subsequently comply with all other provisions of 454 CMR 22.00, including the requirement to have the work supervised by a “Lead-Safe Renovator-Supervisor”, compliance with work practices (including cleanup), notifications, cleaning verification and recordkeeping.

III.  Contractor Licensing Fee and Required Documentation

EPA:  $300 for five years.  Applicants must submit identifying information, list of professional certifications related to lead-based paint activity and list of previous violations related to lead-based paint activity.

DOS:  $375 for five years.  In addition to filling out identifying information on application form, applicant must:

1.  Document that a person in a supervisory or management capacity has received the one-day Lead-Safe Renovator-Supervisor (“Certified Renovator”) training.

2.  Document that a medical monitoring/respirator protection program is in place (entities with employees only). Program templates are on DOS’s website.

3.  Submit information related to organization of the business or entity – corporate articles of organization, business certificate, etc., as applicable.

4.  Submit lists of current and previous employees.

5.  Document workers compensation coverage (entities with employees).

6.  Affirm compliance with Massachusetts tax laws, including DOR, DUA, FSC.

7.  Submit lists of occupational health and safety-related violations, notices of noncompliance, enforcement actions, etc. 

IV.  On-site Supervisor Requirement

EPA:  EPA requires the supervisor (“Certified Renovator”) to be on site only during certain phases of the work (posting of Warning Signs, establishment of work area containments, during final cleanup and cleaning verification) and available by phone the rest of the time.

DOS:  DOS requires the supervisor (“Lead-Safe Renovator Supervisor”) to be on site at all times when RRP work is in progress.

V.  Training and Certification Requirement for Supervisor

EPA: EPA requires a one-day “Certified Renovator” course given by an EPA-certified training provider.  Possession of the training certificate, which includes a digital image of the trainee, constitutes the certification – persons who possess this certificate do not have to apply to EPA directly.  The one-day training course does not include respirator/personal protection training elements.  The training/certification is good for five years, after which time the “Certified Renovator must take a one-half day refresher course.  EPA allows persons who have taken the deleader-supervisor and deleader-worker courses to take a one-half day upgrade/refresher course to upgrade to “Certified Renovator” status.

DOS: DOS requires essentially the same one-day training course for certified “Lead-Safe Renovator-Supervisors” that EPA requires for “Certified Renovators” except that the DOS-required course includes respirator/personal protection training elements. Where the training is given in Massachusetts, the course must be given by a Massachusetts-licensed training provider.  As is the case with EPA, possession of the training certificate, which includes a digital image of the trainee constitutes the certification – persons who possess this certificate do not have to apply to DOS directly.  The training/certification is valid for five years, after which time the “Lead-Safe Renovator-Supervisor” must take a one-half day refresher course.  DOS also allows persons who have taken the deleader-supervisor and deleader-worker courses to take a one-half day upgrade/refresher course to upgrade to “Lead-Safe Renovator-Supervisor” status.  DOS also requires training providers to include “Lead-Safe Renovator-Supervisor” training elements in four-day training courses required for “Deleader-Supervisors” given after July 9, 2010, and DOS will therefore allow “Deleader-Supervisors” to function as “Lead-Safe Renovator-Supervisors” on renovation worksites after they have completed this training.

VI.  Certification and Licensing Reciprocity between EPA and DOS

EPA:   Firms or entities that have been licensed as “Lead-Safe Renovation Contractors” by DOS in Massachusetts must become certified with EPA as “Certified Firms” in order to carry out RRP work in states where EPA is running the RRP program.  EPA allows individuals who have been trained/certified as “Lead-Safe Renovator-Supervisors” in Massachusetts to act as supervisors and perform the functions of “Certified Renovators” on RRP projects in other states where EPA is running the program without needing to obtain separate EPA certification as “Certified Renovators.”

DOS:   DOS allows firms that were certified with EPA as “Certified Firms” prior to July 9, 2010 to perform RRP work in Massachusetts without becoming licensed by DOS as a “Lead-Safe Renovation Contractor,” provided that they have received a “Contractor Licensing Waiver” from DOS – there is no fee for this waiver.  The “Contractor Licensing Waiver” application is on the DOS website.  Contractors that apply for EPA certification after July 9, 2010 are required to pay the licensing fee and become licensed as “Lead-Safe Renovation Contractors” with DOS.  DOS will allow “Certified Renovators” that have received training from EPA-approved training providers to perform the functions of “Lead-Safe Renovator-Supervisors in Massachusetts without further training or licensure.

VII.  License/Certification Fees for Providers of RRP Training

EPA:  EPA issues a four-year certification to lead training providers.  Certification fees, which are assessed on a per-course basis, range between $400 and $870 per course.  The charge for certification to give to the initial “Certified Renovator” training course is $560, and the charge to give the refresher course is $400.  The charge for renewing the certification in either discipline is $340.  The training provider certification fee is waived for providers who are state and local governments, federally recognized Indian Tribes and non-profit organizations.

DOS:  DOS issues a one-year license to lead training providers and charges a flat licensing fee of $1775, regardless of the number of lead training course disciplines in which the trainer is seeking approval to provide training.  DOS has the same licensing fee waiver as EPA for training providers who offer only RRP training and are state and local governments, federally recognized Indian Tribes and non-profit organizations.

VIII.  Work Practice Requirements

EPA: The set of work practice requirements specified by EPA’s RRP Rule is a somewhat relaxed version of the work practices currently required for deleading projects.  As opposed to what is required for deleading projects, units undergoing renovation are not required to be unoccupied while the work is in progress; it is only required that persons be excluded from the work area, which must be isolated from the rest of the dwelling or child-occupied facility by appropriate means.  Plastic sheeting, which must be disposed after each use, must be used to cover floors and other surfaces on building interiors and plants and ground on exteriors.  EPA specifies the use of a “cleaning verification” procedure, which is carried out by the on-site ”Certified Renovator” to determine if interior work areas have been adequately decontaminated.  Under this procedure, the color of a wiping cloth, that is used to wipe down the work area following the final cleaning, is compared to the color of a standard “cleaning verification card” issued by EPA.  If the color of the wiping cloth is the same shade as (or lighter than) the cleaning verification card, the area “passes.” Dust-wipe clearance, as is used to clear deleading projects, may also be used to “clear” RRP projects.

DOS:  DOS’ work practice requirements for RRP work are almost identical to those required by EPA, except that DOS allows the use of tarpaulins to cover plants and ground on exterior projects, provided that the tarpaulins are thoroughly decontaminated after each use and not subsequently used for any interior work in target housing and child-occupied facilities.


Click here to find this information at the DLS web site

Topics: RRP Questions, MA RRP Updates, MA RRP Lead Rules

What Is The Lead Disclosure Rule?

Posted by Shawn McCadden on Tue, Aug 24, 2010 @ 08:22 AM

What Is The Lead Disclosure Rule?

XRF lead testRenovators doing RRP work will be involved with lead testing.  Lead testing for RRP related projects can be done by the certified renovator, a certified lead inspector or certified lead risk assessor.  The type of testing that can be done by each varies, but regardless of who does the testing written reports are required and, by law, certain individuals must be given a copy of those reports if lead is found.  The EPA RRP rule is specific about who must receive test reports if the testing is done for the purposes of an RRP renovation.   


House for sale signRegardless of the original purpose of testing (RRP or any other purpose), once a reports exists, the Lead Disclosure Rule below dictates who must receive the reports and when in regards to the selling or leasing of a property.  The rule also specifies what documentation must be created and maintained to prove the reports were distributed to the required parties.  Because of the considerations of the Lead Disclosure Rule, I recommend renovators get the property owner's written permission prior to conducting any lead testing.


The following information is from the HUD web site:

Congress passed the Residential Lead-Based Paint Hazard Reduction Act of 1992, also known as Title X, to protect families from exposure to lead from paint, dust, and soil. Section 1018 of this law directed HUD and EPA to require the disclosure of known information on lead-based paint and lead-based paint hazards before the sale or lease of most housing built before 1978.

What is Required?

Before ratification of a contract for housing sale or lease, sellers and landlords must:

  • Protect your familiy from lead coverGive an EPA-approved information pamphlet on identifying and controlling lead-based paint hazards ("Protect Your Family From Lead In Your Home" pamphlet, currently available in English, Spanish, Vietnamese, Russian, Arabic and Somali).
  • Disclose any known information concerning lead-based paint or lead-based paint hazards. The seller or landlord must also disclose information such as the location of the lead-based paint and/or lead-based paint hazards, and the condition of the painted surfaces.
  • Provide any records and reports on lead-based paint and/or lead-based paint hazards which are available to the seller or landlord (for multi-unit buildings, this requirement includes records and reports concerning common areas and other units, when such information was obtained as a result of a building-wide evaluation).
  • Include an attachment to the contract or lease(or language inserted in the lease itself) which includes a Lead Warning Statement and confirms that the seller or landlord has complied with all notification requirements. This attachment is to be provided in the same language used in the rest of the contract. Sellers or landlords, and agents, as well as homebuyers or tenants, must sign and date the attachment.
  • Sellers must provide homebuyers a 10-day period to conduct a paint inspection or risk assessment for lead-based paint or lead-based paint hazards. Parties may mutually agree, in writing, to lengthen or shorten the time period for inspection. Homebuyers may waive this inspection opportunity.

Types of Housing Covered?

Most private housing, public housing, Federally owned housing, and housing receiving Federal assistance are affected by this rule.

Effective Dates:

The regulations became effective on September 6, 1996 for transactions involving owners of more than 4 residential dwellings and on December 6, 1996 for transactions involving owners of 1 to 4 residential dwellings.


Sellers and lessors must retain a copy of the disclosures for no less than three years from the date of sale or the date the leasing period begins.

What Can You Do?

If you did not receive the Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards form when you bought or leased pre-1978 housing, contact 1-800-424-LEAD (5323).


According to the HUD web site, this content was current as of March 4, 2008.  Click here to view this information on the HUD website

Topics: RRP Questions, Definitions, Documentation Considerations, Info for Landlords, EPA RRP for Dummies, Lead Test Kits and Testing

For Large RRP Remodels; Renovate or Tear Down and Start Over?

Posted by Shawn McCadden on Wed, Aug 18, 2010 @ 07:19 AM

For Large RRP Remodels; Renovate or Tear Down and Start Over?

Question from an RRPedia User:

Renovate, tear down or start over?
“Shawn, We have met a number of times, most recently at the Rings End event, which was great, informative and overwhelming. I'm not sure where to go for the answer to this question and thought maybe you could direct me. We are bidding a sizable remodel and the architect has note for that bidders are to follow RRP guidelines. Its pre-1978, we will be disturbing 75%+ of the existing structure and it is unoccupied. I'm thinking that we don't need to address the tarping and cleanup because of the magnitude and vacancy. If we do then we need to consider a tear down. Any guidance you can give would be appreciated. I'm sure you get this all the time so I understand if you can't get to it. Best regards, 
Ray Gaines Sr, Gaines Construction Co. Inc.


Thanks for your message. This question has come up several times already from other contractors like you who are trying to do the right thing and interpret the EPA RRP rule correctly.

The fact that the property is unoccupied during the renovation makes no difference regarding whether the EPA RRP rule applies. This is confirmed on the FAQ page of the EPA web site. Because of the removal of the opt-out provision in July of this year, any residential property where people live or will live (referred to as target housing) now requires the lead-safe practices unless the home tests out negative for lead under the EPA guidelines.

Also under the EPA RRP Rule, unless the entire interior of the structure is gutted down to bare wood, with no coated or painted surfaces remaining, the project must be treated as an RRP project and again the work must be done using lead-safe work practices.  A full removal of all exterior finishes however does require the RRP Lead-safe work practices.  Again, this is confirmed on the FAQ page of the EPA web site.  Keep in mind, all documentation requirements apply as well.

As a side note, your message does say the building is pre 1978; however you do not say whether the property was tested for lead.  If it hasn't been tested, one option to the owner would be to test it.  Of course, if there is no lead, the rule would not apply.

Lead test kitsThe EPA approved test kits sold by LeadCheck are very accurate.  These tests reliably determine the presence or absence of lead.  If you use these tests the owner would know if any lead is present at all.  However, under the RRP Rule, the EPA says the rule exempts renovations that affect only components that a certified lead inspector or certified risk assessor has determined are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight. EPA further explains that the determination that any particular component is free of lead-based paint may be made as part of a lead-based paint inspection of an entire housing unit or building, or on a component-by-component basis.

So, if the property owner wants to know if there is any lead at all, the EPA approved LeadCheck test kits could be used to do so.  If the owner chooses to use the EPA's action level of lead paint amount to determine if the lead-safe practices would be required, then currently the only way to test for amount of lead would be to use a certified lead inspector or certified lead risk assessor.  

Nice fishOne way to think about this might be to relate it to eating fish.  The government often says that if you fish in certain bodies of polluted water, you can safely eat up to so many of the fish you catch without any health concerns.  If the government says you can eat up to 3 fish a year, how safe would you feel eating even one fish?  Using this analogy, how safe might the owner feel having renovations done if there is any lead present at all at their property?

If you have opportunity to interact with the property owner, I suggest you might find you would stand out from the other bidders if you could share what I have written here with the owners.  It is my opinion that the property owners should know the facts, know their options and then make a decision about how to move forward regarding lead at their homes.

Topics: RRP Questions, EPA RRP Lead Rules, Sales Considerations, Estimating Considerations, Health Effects of Lead, Compliance Options, Work Practices, RRP for Dummies, Containment Considerations, Lead Test Kits and Testing

EPA Offers Clarification About Approved EPA RRP Lead Test Kits

Posted by Shawn McCadden on Thu, Jul 15, 2010 @ 01:53 PM

EPA Approved Lead Test Kits

Trainers and renovators have been expressing some confusion about the EPA approved lead test kits.  The confusion revolves around whether the current test kits can still be used and/or if and when they might be replaced.


7/15/10: The following is the most recent information and communication about EPA approved lead test kits sent from EPA Headquarters in DC to each of the EPA regions. 


EPA LogoEPA Communication to EPA Region Headquarters:

"I wanted to take this opportunity to clarify an RRP issue because I understand that there may be some mis-information that may have been given out to training providers.  I understand that training providers have been told they should not buy a lot of the currently available test kits because they will not be valid after September 1.  This is incorrect.  I would appreciate it if you would ask your staff to clarify this with the training providers in particular.

 Background on Test Kits

  • EPA has recognized two Phase 1 test kits (LeadCheck and State of Massachusetts kit) for use in determining if there is lead-based paint in target housing and child-occupied facilities.  These are currently being used by renovators and in renovator training classes.
  • These kits will continue to be recognized until EPA recognizes Phase 2 kits.  The Phase 1 kits do not automatically sunset on September 1 or any other date in the absence of approved Phase 2 kits.
  • EPA, under the Office of Research and Development’s (ORD) Envirnomental Testing Verification (ETV) process is currently evaluating 4 test kits for the Phase 2 criteria.  At this time we do not know if any of the kits will pass.

 We should have results in late July and will share that with you and post the preliminary results on the web."

Note: This information was shared with me by Joe Moriarty of LeadCheck.  LeadCheck® Swabs is the only EPA recognized rapid lead detection product available for RRP use by EPA Certified Renovators.

Topics: RRP Questions, EPA RRP Rule Updates, Tools and Supplies, Lead Test Kits and Testing

Working on Buildings Where a Child Occupied Facility Exists

Posted by Shawn McCadden on Thu, Jun 24, 2010 @ 08:00 AM

Chruch interior


Several renovators seeking clarification about the EPA RRP Rule have asked me about working on buildings where a child occupied facility occupies part of the building, but not the entire building.  The most common example they ask about is a church.  The following question and answer are from the FAQ page of the EPA Web site.  Although not mentioned in EPA's answer, I suggest that play areas outside of the building would also be considered common areas where the required containment procedures and work practices would be required.

Question Posted to EPA Web Site: If a building contains a child-occupied facility, must all renovations in the building follow the RRP Rule?

EPA Answer: Not necessarily.  "Child-occupied facility'' means a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days within any week (Sunday through Saturday period), provided that each day's visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours.  Child-occupied facilities may include, but are not limited to, day care centers, preschools and kindergarten classrooms.  Child-occupied facilities may be located in target housing or in public or commercial buildings.


With respect to common areas in public or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only those common areas that are routinely used by children under age 6, such as restrooms and cafeterias.  Common areas that children under age 6 only pass through, such as hallways, stairways, and garages are not included.  In addition, with respect to exteriors of public or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only the exterior sides of the building that are immediately adjacent to the child-occupied facility or the common areas routinely used by children under age 6.

Areas of a building that fall outside this definition are not "child-occupied facilities" for purposes of the RRP rule.  

Topics: RRP Questions, Work Practices, Work Practice Exclusions, Containment Considerations

Personal Protection Equipment Requirements Under The EPA RRP Rule

Posted by Shawn McCadden on Mon, Jun 21, 2010 @ 07:57 AM

Question: Does the RRP rule require people working on a renovation to wear respirators, Tyvek(R) suits or other personal protective equipment (PPE)? 

OSHA logo


Most renovation contractors have little knowledge or experience with OSHA requirements.  OSHA requirements concentrate on the occupational safety of the worker.  There are many OSHA requirements that contractors should already be following if they use employees or sub contractors on their job sites.  Because lead can create serious health risks for employees and workers, employers would be wise to become familiar with the OSHA requirements related to the work they perform under the EPA RRP rule. 

The required containment methods and work practices have changed the way work gets done in the field.  Even if working within OSHA requirements in the past, new activities and methods used on RRP related projects most likely trigger personal protection considerations under OSHA regulations.

Unfortunately, while creating the EPA RRP rule, the EPA did not include reference to any specific OSHA requirements.  Therefore, renovators need to know and understand both the RRP rule as well as any related OSHA requirements in order to protect workers and avoid potential penalties from OSHA and or EPA.  To learn more about the related OSHA requirements, renovators can refer to the OSHA Lead in Construction Standards.

MAIn the new MA RRP rules, still yet to be enforced as of this posting, many of the OSHA requirements related to RRP work have been included in the regulations.  When I met with employees from the MA Department of Occupational Safety to discuss the proposed rule, they were very helpful in clarifying the reasons for adding these consideration.  So, although the EPA and OSHA may not have collaborated when the EPA RRP rule was created, MA renovation contractors will have the advantage of knowing what OSHA requirements they will need to consider depending on the work they do as well as the methods they use to do the work.  Reading the MA RRP rule would help renovators working under the EPA RRP rule identify many of the related OSHA considerations.

Here is EPA's response to the question at the beginning of this post:

"EPA would like to clarify the requirements for personal protective equipment.  The Occupational Safety and Health Administration (OSHA) has requirements for personal protective equipment, EPA does not.  For many years, EPA has recommended the use of personal protective equipment as a way to protect workers and to help ensure that leaded dust and debris does not leave renovation or abatement work sites.  EPA recommends that renovators make use of the minimum respiratory protection recommended by the National Institute of Occupational Safety and Health (NIOSH) for environments where lead is present, but respiratory protection is not required by the EPA regulations.  In addition, disposable clothing, if removed and disposed of before the workers leave the work site, can provide additional protection for workers' families by ensuring that no leaded dust or debris is carried home on worker clothing.  However, EPA does not require this and allows renovators to use other methods to ensure that dust and debris does not leave the work area, including the HEPA vacuuming of clothing, tools, and other items before they leave the work area."  

Topics: RRP Questions, RRP in MA, EPA RRP Lead Rules, OSHA Considerations, Subcontractor Considerations, Health Effects of Lead, Work Practices, Personal Protection

EPA RRP Considerations for Demolition of All or Part of a Structure

Posted by Shawn McCadden on Fri, Jun 18, 2010 @ 09:40 AM

House demolition


Question from RRPedia visitor Dan Tibma of Tibma Design/Build"Under the EPA RRP rule, if I demo an attached garage completely, except for the foundation, what site and debris containment measures do I need to take?"

Dan, thanks for visiting my web site and for your question.  I hope you are well.  I had already started a post about this topic, so you motivated me to finish it and get it posted.  Thanks!

I had asked the EPA a similar question in the list of questions presented to the EPA Region One Office on January 6th, 2010 on behalf of the Eastern MA NARI Chapter.  Eventually, on April 7, 2010, EPA answered the question in the FAQ section of their web site.

Here is the question I asked:

Does the Renovation, Repair, and Painting (RRP) Rule apply to demolishing and disposing of:

  • An entire pre-1978 home or building?
  • An entire, non-attached free-standing structure on the same property such as a garage, shed, or gazebo?
  • An attached but segregated section of pre-1978 home or building such as a sunroom, addition, two-story porch, or garage attached by a breezeway?

Here is the EPA's response:

Garage demolition"The RRP Rule covers renovations, which are defined as modifications of existing structures or portions of structures. The rule does not apply to demolitions of an entire free-standing building or structure.

The RRP Rule does apply to renovation activities that modify portions of existing structures. Waste from these activities must be contained to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal. If a chute is used to remove waste from the work area, it must be covered.

At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work are an d prevents access to dust and debris.

When the firm transports waste from renovation activities, the firm must contain the waste to prevent release of dust and debris."


Topics: RRP Questions, Production Considerations, Estimating Considerations, Work Practice Exclusions, Containment Considerations

How much will it cost contractors to comply with the EPA RRP Rule?

Posted by Shawn McCadden on Tue, Apr 20, 2010 @ 10:06 AM

How much will it cost contractors to comply with the Renovation, Repair, and Painting (EPA RRP) Rule?

Firm applicationFirst, there are up-front costs including firm certification (required to offer, sell and or be under contract to perform the work) and the cost of Certified Renovator training for those doing and or supervising the actual work.  Other up front costs can include tools and equipment needed to perform the work including a HEPA vacuum, cleaning equipment, personal protection equipment for workers, specialized tools and containment related equipment such as products like Zip Walls.

Zip wall example

There will also be job related costs specific to the kind of work performed.  Examples could include additional labor, tape, plastic sheeting, cleaning solutions, sprayers, staples, disposable wipes, HEPA filters, trash bags, tack pads, etc. Click here to request a tools and supplies shopping list.   Contractors will need to consider new estimating categories/divisions as well as matching job costing categories to help verify and or improved estimated cost assumptions.  Time cards and labor tracking codes should also be considered.

Contractors should also be aware of related overhead costs.  These costs could include employee time to fill out and maintain required documentation, training of non-certified workers, delivery and documentation of pre-education materials, marketing and sales related expenses, time trying to get answers from the EPA, recertification costs, employee health testing, updating contracts, legal advice, insurance costs, continuing education, law suits, etc. 

Contractors should devise ways to separate out EPA RRP related  job costs and overhead expenses within their financial system in a way that gives them the ability to determine how RRP related compliance affects their costs of doing business.

Here is how the EPA answers this question:

"Information collected by EPA for the purposes of the rulemaking indicates that many contractors already follow some of the work practices required by the rule, such as using disposable plastic sheeting to cover floors and objects in the work area.  These estimates do not include the costs of those practices.

EPA estimates that the costs of containment, cleaning, and cleaning verification will range from $8 to $167 per job, with the exception of those exterior jobs where vertical containment would be required.  This includes:
·     Costs of equipment (for example, plastic sheeting, tape, HEPA vacuums and tool shrouds - the equipment varies by job).
·     Costs of labor (for example, the time required to perform cleaning and cleaning verification).

In addition to work practice costs, your costs will include training fees and certification fees.  The costs include:
·     Training costs to individual renovators working in pre-1978 housing or child-occupied facilities who must take a course from an accredited training provider (cost is set by the training provider; estimated to be about $200 for a 5-year certification).
·     Certification costs to firms to obtain certification from EPA ($300 fee to the U.S. Treasury for a 5-year certification.  (This fee is required by law to cover program administration)." 

Topics: Business Financials, RRP Questions, Legal Considerations, Estimating Considerations, Business Considerations, Tools and Supplies

Does the EPA RRP Rule apply in unpainted spaces?

Posted by Shawn McCadden on Sat, Apr 17, 2010 @ 04:47 PM

Questions (2):

(1) If a homeowner removes all the painted surfaces in a room and then hires a certified firm to remodel the room, does the renovator need to follow the RRP Rule?

(2) Does the RRP Rule apply where no paint at all is present, such as in a 100 year old unfinished basement?

According to the EPA web site:

"No.  The EPA RRP Rule applies to activities that result in the disturbance of painted surfaces.  Where there is no paint to disturb, the RRP Rule does not apply."

effects of lead poisoningNote: If the home owner has removed all painted surfaces and or has already done all required demo, renovators should still be cautious.  Just because all of the painted surfaces have been removed does not ensure that there is no lead dust still present in a work area.  If the renovator spreads that dust while working, he or she could still be held liable for doing so.  If demolition has been done by others prior to the start of work, it might be wise to have the area tested before you begin your work.

NOTE: According to the EPA RRP rule, you cannot offer, sell or do work on pre-78 target housing for compensation unless you or your business is a certified firm.  Although the work practices may not be required at a property if you are not disturbing any paint, the firm doing the work must be an EPA Certified Firm.

Topics: RRP Questions, EPA RRP Lead Rules, Work Practices, Work Practice Exclusions