EPA Clarifies that RRP Enforcement Delay Applies to Certification, Not to Safety Practices and Recordkeeping

On June 18, 2010, the EPA published a memorandum about a partial enforcement delay for the Repair, Renovation and Painting (RRP) Rule. Citing delays and difficulties on the part of firms and renovators to obtain the necessary certifications, the EPA announced a delay in enforcement for the certification portions of the rule. Specifically, the EPA stated that:

•they will not enforce the firm certification requirement of the RRP Rule until October 1, 2010
•they will not enforce the certification requirement of the RRP Rule against individual renovation workers if they have taken or have applied to take a certification class by September 30, 2010 (providing the training will be completed by December 31, 2010)

As information about the RRP enforcement delay spread across the internet, various misinformation quickly spread as well. The most common misinterpretation was that the enforcement delay applied to the entire RRP rule. This was merely an affliction of hopeful thinking, which the EPA promptly squelched with its new clarification, delivered in a “question and answer” format.

In the updated notice, the EPA clarifies that the safety practices and recordkeeping portions of the RRP Rule are currently in effect and are not part of the delay. This indicates that renovators who have not yet taken the training are still expected to be following the safety and recordkeeping practices spelled out in the Rule.

Renovators who have not yet taken the required training are being encouraged to reference the EPA’s model training materials, at http://www.epa.gov/lead/pubs/training.htm .

John P. Lapotaire, CIEC
Certified Indoor Environmental Consultant
Microshield Environmental Services, LLC
http://www.Microshield-ES.com http://www.CFL-IAQ.com

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