CONNOR Institute - EPA Certified Renovator Training Classes (EPA RRP Lead Training for Contractors, Renovators, Remodelers, and Painters)

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EPA's Renovation, Repair, and Painting Rule

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Hello,

You may be asking these questions: What is all the buzz about? Who is impacted by the EPA Renovation, Repair and Painting (“RRP”) program, and the April 22, 2010 effective date? The short answer: Potentially, your current, loyal customers, and your prospective customers.

Because if they own, manage or work in pre-1978 housing or child-occupied facilities, they may need to employ Certified Renovators and have their businesses become EPA Certified Firms. EPA now regulates work such as window replacement and interior painting (e.g. paint, stain, shellac or varnish) that entails disturbance of over 6 square feet, or disturbs 20 square feet of the exterior. Some of your friends and customers may not yet be aware that they are now part of EPA’s plan to reduce future childhood lead exposure. You can provide the help they need, by hosting training classes at your store or elsewhere in your community.

How can you be part of the solution? Get involved with education. Stock the newly required supplies. Make it easier for your customers to focus their valuable time on the business of doing, rather than the challenge of researching. Enable them to work with the assurance that they have a partner in compliance, and that they can obtain exactly what they need from the long-term friend they trust.

CONNOR Institute is holding EPA Certified Renovator Training with partners like you across the United States. Among the advantages of hosting RRP training are (1) You will be helping to expand essential knowledge within the trade community; (2) You will continue to be that source of one-stop shopping; and (3) You will help your friends avoid substantial fines ($37,500). By hosting this training, you will provide these valuable services, while concurrently showcasing your company to people with whom you may not yet routinely do business. You will also have the opportunity to stock and then sell Lead Safe Starter Kits to the contractors who attend your event.

Professionals across the country are already hosting classes – taking the opportunity to really meet and talk with the more than 1.5 million people nationwide who need this certification. The contractor will be at your event for ten hours, with opportunities before the class, during lunch, and after class for you and your staff to get to know them better, ask what projects they are doing, and inform them about your products and services. In a world of 30-second sound bites, you will have hours.

Below are quotes from some of our existing partners:

“...I was able to meet some potential clients I had never done business with before. One new client ordered $30,000 of goods from me on a project he had coming up...”
“My sales staff was able to spend real time with our clients, not just the few minutes we have at the counter each day...”
“The instruction was thorough and moved quickly...”
“...the instructor did not try to sell us anything. He instructed us and reviewed the material...”

Please take a moment and call me at 443-322-1225, or email me at eryan@connorinstitute.com for more information.

Alternatively, you may submit an online request for more information by navigating HERE.

I look forward to hearing from you.

Thank you,

Erin Ryan

eryan@connorinstitute.com

CONNOR Institute

EPA Certified Renovator Generally what is covered by the new EPA rule:

Residential properties and child-occupied facilities (i.e. locations where children under the age of 6 typically visit – schools, day-care centers, places of worship, etc.) built prior to 1/1/1978;
Within regulated properties; components (i.e. doors, walls, floors, ceilings, trim, etc.) that are coated with paint, stain, shellac or varnish, that has not been certified as lead free (i.e. below regulatory standards); and
Disturbance of more than 6 square feet of coatings that is located on the interior or more than 20 square feet of coatings that is located on the exterior.

Why the rule does exists:

The Housing and Community Development Act of 1992 (Congress requirement);
Title X (a section within 1992 Act);
EPA regulations (published in April 2008);
To ensure adequate containment, controls and cleaning is associated with renovations in regulated properties;
To reduce or eliminate conditions that may contribute to a child’s lead exposure.

What typically must the regulated community do:

Submit an application plus $ 300 to EPA (become a Certified Firm);
Comply, as applicable, with state requirements;
Participate in training to become a Certified Renovator;
Educate (provide a pamphlet – Renovate Right) their customer as to potential hazards produced during a renovation;
Purchase and use new equipment [i.e. HEPA vacuums, EPA Recognized Test kits (optional), etc.];
Document adequate cleaning following the renovation; and
Maintain records for at least three years.

To view available classes in your area, please navigate to www.connorinstitute.com/classes/rrp.

EPA’s New Renovation, Repair and Painting Rule:

Will You Be Ready to Comply?

Basics of the Rule

Firm Certification and Responsibilities

Individual Certification and Responsibilities

Resident Information and Education

Lead-Safe Work Practices and the “Cleaning Verification” Procedure

Enforcement Provisions

Summary

The US Environmental Protection Agency’s Renovation, Repair and Painting Rule became fully effective and enforceable on April 23, 2010.

The Rule will impact a substantial number of firms and individuals, including many professional residential real estate managers and residential rental property owners, and create new regulatory requirements. Will you be ready to comply when Rule takes effect next year?

Basics of the Rule

The Rule applies to all "renovations" (which is broadly defined and includes many typical maintenance activities) performed for "compensation" in pre-1978 “target housing” and in pre-1978 "child-occupied facilities" (e.g., daycare centers). The Rule’s requirements are generally triggered when paint (including shellac, stain and varnish), which has not been certified as being lead-free, is disturbed by any renovation, repair or painting project. Owners and occupants of target housing and child-occupied facilities must receive information on lead-based paint hazards before these projects can begin. Also, certain lead-safe work practice standards must be met during the work and a “cleaning verification” must be conducted before the work area can be reoccupied. Finally, certain work records must be created and maintained for no less than three years. In the first year, EPA estimates that approximately 8.4 million renovation events will trigger the Rule’s requirements.

The legal entities performing these renovations must submit an application and fee to become EPA Certified Renovation Firms. Further, individuals who work for such Firms must be properly trained and EPA certified as "Renovators" or be trained and supervised on the job by Certified Renovators. EPA conservatively estimates that 211,000 organizations (many of which will be third-party property management companies and rental property owners) will need to apply to for firm certification. Also, several hundred thousand individuals will need to be trained as Certified Renovators by EPA-accredited training providers.

Renovation, repair and painting projects that will only disturb surfaces and building components that have been tested and found to be free of lead-based paint are excluded from the Rule. Other Rule exclusions include:

· Activities that disturb less than six square feet or less of painted surfaces per interior room.

· Activities that disturb less than 20 square feet or less of painted surfaces per exterior side.

· Abatement work, which is intended to permanently eliminate lead-based paint hazards.

· Emergency renovations necessitated by sudden and unexpected events, which are required to address immediate human safety or health hazards or to avoid significant damage to equipment or other property. These emergency renovations are exempt from the Rule’s information distribution, warning sign posting, containment, waste handling, training and certification requirements. However, the Rule’s cleaning, “cleaning verification” and recordkeeping requirements will still apply.

When any work involves window replacement, demolition of painted surfaces and/or building components, or “restricted practices,” such as using a machine sander with a dust collection shroud and HEPA vacuum exhaust port, the above exclusions do not apply.

Firm Certification and Responsibilities

Beginning on October 22, 2009, any legal entities that renovate, repair or paint in target housing or child occupied facilities must submit an application, including a $300 fee, to EPA in order to become a Certified Renovation Firm. Firm certification is good for five years. Firms must:

· Ensure that all personnel are either Certified Renovators or have received on-the-job training from a Certified Renovator.

· Meet pre-renovation education requirements.

· Assign at least one Certified Renovator to each regulated project.

· Ensure that contractors and subcontractors working on regulated projects are also Certified Renovation Firms meeting the same requirements.

· Ensure that lead-safe work practice standards and the “cleaning verification” procedure are followed on each regulated project.

· Meet recordkeeping requirements, including maintaining project records for three years.

Individual Certification and Responsibilities

Many maintenance technicians, maintenance supervisors, service personnel, unit turnover staff, building trades contractors’ and subcontractors’ workers, and other employees will have to be trained and certified as Renovators by EPA-accredited training providers. Certified Renovators will need to be assigned to each regulated project. They will also be responsible for training non-certified workers on the Rule’s required lead-safe work practice standards. Individual certification is also good for five years. Certified Renovators must:

· Individually perform the renovation, repair or painting work, and train and direct the work of any other uncertified workers on the job site.

· Be physically present on the job site or available by telephone at all times.

· Be physically present during job site set-up, including posting warning signs and establishing containment.

· Assure that any dust and debris generated by the work is minimized, contained, controlled and cleaned up as the project proceeds.

· Be physically present during final cleaning of the work area and ensure that waste is properly bagged and disposed of off-site.

· Conduct the “cleaning verification” procedure.

· Prepare and maintain required project records.

Resident Information and Education

Prior to conducting renovation, repair or painting projects in pre-1978 target housing or child-occupied facilities, Certified Renovation Firms must provide a new EPA booklet, entitled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools, to the adult residents of an occupied dwelling unit. Renovators must also obtain a signed form acknowledging their receipt of the pamphlet or maintain proof that the pamphlet was mailed or that there were unsuccessful attempts to deliver it. If working in common areas of a multifamily property or in child-occupied facilities, renovators must notify residents or parents/guardians of the children, and post informational signs about the work.

Lead-Safe Work Practices and the “Cleaning Verification” Procedure

The Rule requires that the work area be properly set up and contained before work begins, that lead-contaminated dust and debris generated by the work is minimized and controlled, and that the work area is properly cleaned upon completion of the work. Then, the Certified Renovator assigned to the project must conduct the “cleaning verification” procedure.

This procedure involves separately wiping uncarpeted floors, countertops and windowsills with commercially available individual wet cleaning cloths and then comparing each cloth to an EPA-issued “cleaning verification card.” For floors in the work area, one wet cleaning cloth is used for each 40 square foot section. If the initial wet cleaning cloth is darker than the images on the cleaning verification card, the Certified Renovator must re-clean that surface and then re-wipe it with a second wet cleaning cloth. If the second cloth is still darker than the images on the cleaning verification card, the Certified Renovator must wait at least one hour and allow that surface to dry completely. Then, the surface is wiped for a final time with a dry electrostatically charged cleaning cloth. This completes the cleaning verification procedure.

Enforcement Provisions

EPA has the authority to seek civil fines of $32,500 per offense for failure to comply with the Rule’s requirements. EPA can also seek criminal fines of $32,500, plus potential jail time, for knowing and willful violations of these requirements. Additionally, EPA can revoke the certification of any Certified Renovation Firm or Certified Renovator who violates the Rule.

Summary

To prepare to implement the Rule’s requirements, third-party property managers, multifamily property owners, trade contractors, and others responsible for or working in target housing and child-occupied facilities should consider developing a plan that includes a compliance strategy, a training strategy, a certification strategy and a recordkeeping strategy. By doing so, your organization will be well equipped and ready to meet the new requirements once they take effect in April 2010.

CONNOR Institute, a national real estate due diligence and environmental training firm headquartered in Baltimore, Maryland, has received EPA-accreditation to train the new EPA Certified Renovator Initial full day course and the EPA Certified Renovator Refresher half-day course in all 50 states, the District of Columbia, the Indian Tribal lands and the four US territories. CONNOR is offering EPA Certified Renovator open enrollment classes across the country. For more information about this training, contact Bob Bixler at 443-322-1220 or at bbixler@connorinstitute.com.