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Big Changes to the EPA RRP Lead Rule: Summary

July 20, 2011

On July 15, 2011 the EPA finally released a PREPUBLICATION VERSION of the final rule. The 113 pagedocument touched on many points that contractors have been waiting on. Fortunately, Mark Paskell of The Contractor Coaching Partnership, created a great summary of the changes.  (Thanks Mark!) Here are the main points:

1. Dust wipe testing and clearance requirements are not required. The clearance verification process taught in the RRP course stays.

2. Exterior work; Vertical containment must be used when affected surfaces are within 10 feet of the property line. The containment can be set up as close as possible to the disturbed surface so long as all debris are contained in the work area. For example vertical containment can be set up 5 feet from the disturbed surface.

Interior work; Vertical containment from floor to ceiling. Certified Renovators do not have to place the minimum 6 feet of plastic on interior floors. The vertical containment can be set up as close as possible to the disturbed surface so long as all debris are contained in the work area. For example vertical containment can be set up 3 feet from the disturbed surface.

3. Certified Renovators are allowed to collect a paint chip sample and send it to a recognized laboratory for analysis in lieu of using a test kit.

4. Records to be kept on file for five years instead of the former three year requirement.

5. Minimum penalty for states and Tribal programs of $5,000.

6. HEPA vacuums EPA has decided to promulgate the requirement that HEPA vacuums be operated in accordance with manufacturer’s instructions, but not the requirement that compliant vacuums be rated at a MERV value of 17 or higher. More details coming soon!

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