Changes to 2008 Lead RRP Rule May Affect Your Renovation Project

Last week a client asked me to explain how the upcoming changes to the RRP Rule may affect his business and upcoming projects.  RGA has provided health & safety training for his workers for more than five years.   I understood that like many small construction companies, my client was still adjusting to the changes the original RRP Rule required for his day–to-day business practices and was a little apprehensive about the new requirements.   I was happy to take the time to help him understand and prepare for the changes before they go into effect on October 4, 2011.

The past few years have been a learning experience for both the EPA and contractors.  As a result of the lessons learned since 2008, the EPA has finalized a Clearance Rule that will amend the RRP Rule.  The impending changes affect collection of paint chip samples, use of vertical containment, the criteria for a HEPA vacuum and on-the-job training requirements. Here are the rule changes in short:

  1.  A certified Renovator can start collecting paint chip samples in some states. The samples can be send to a NLLAP accredited laboratory and analyzed by the lab in accordance with the Lead rule. The Renovator will have to educate him/herself in how to collect the samples properly. RGA Environmental will start teaching the students how to collect these samples right away. (This is NOT allowed in California.)
  2. A vertical containment is required when you can not ensure the dust will not go past the 10 feet of plastic on the exterior. What does this mean? The Renovator will have to build some sort of a plastic tent if the property line is too close to put plastic 10 feet out. RGA Environmental already teaches this technique to our RRP students and will continue to do so.
  3. The EPA has clarification the criteria for a HEPA vacuum. Many  vacuums on the market claim to be HEPA vacuums, but do not meet the EPA criteria. This rule change requires the HEPA vacuums to be capable of capturing particles of 0.3 microns with 99.97% efficiency.  This means that the filters must have a Minimum Efficiency Reporting Value (MERV) of 17 or greater.
  4. The EPA clarified the on the job training requirements for non-certified workers. EPA did not intend to require training in any other subjects, such as how to paint or how to connect pipes.


Now what does this mean for those who are already certified Renovators? You will have to comply with these rule changes beginning October 4th, 2011.  If you have questions or would like to arrange custom training for your staff please contact RGA’s training division at 888-281-8858.

Andre Zwanenburg, Trainer  – Seattle, WA


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One Response to “Changes to 2008 Lead RRP Rule May Affect Your Renovation Project”

  1. Tim Smith says:

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