At NSCA’s Best Practices Conference in Anaheim, CA, a spirited discussion on EPA requirements for the Lead Renovation Repair & Painting Program (LPPR) took place, raising questions about the requirements.
Nearly a year ago, 16 firms were fined – more than $100,000 – for not following the requirements. While the LPPR rule requires a certification and additional labor hours on jobs, the effects of not following it can cost your business thousands of dollars – and credibility.
Here is a quick reference guide for this rule:
1) LPPR is only applicable to pre-1978 housing and childcare facilities/preschools
2) LPPR is applicable to firms performing renovation, repair, and painting projects in these facilities
3) Work consists of disturbing 6 square feet or more of painted surface per room for interior activities, or 20 square feet or more of painted surface for exterior activities
4) The firm must be certified by the EPA (or an EPA-authorized state) and follow lead-safe work practices
As stated in the Small Entity Compliance Guide, “States and local requirements may be more stringent than these federal requirements. For example, federal law allows EPA to authorize states to administer their own programs in lieu of the federal lead program. Even in states without an authorized lead program, a state may promulgate its own rules that may be different or go beyond the federal requirements. For more information on the rules that apply in your state, please contact the National Lead Information Center at 1-800-424-LEAD (5323).”
This guide provides details on everything from the required customer documentation and communication to contractor training and on-site compliance.
In addition to the EPA requirements, there are additional regulatory bodies with rules regarding lead-based paint, including OSHA.