By Michelle Read DeGarmo
It has been eight years since the Environmental Protection Agency (EPA) implemented the Renovation, Repair, and Painting (RRP) rules, and it’s still a common occurrence to encounter contractors and housing professionals who are unclear on, or completely unaware of, how RRP rules apply to Housing and Urban Development (HUD) or other federal funded projects. The most common issue is a misunderstanding about trained non-certified workers.
On a project that involves no federal funds, it is acceptable for a single RRP Certified contractor to train a crew of workers. These trained non-certified workers may perform lead safe work practices with minimal supervision as long as the worker has properly documented training and a Certified Renovator supervises them. However, once federal funding is involved HUD rules supersede the RRP rule alone and all workers must have RRP certification.
Free trainings aren’t as common as they used to be and often contractors find out they need RRP Certification at the 11th hour. Here at Flatley Read, most of our Initial classes are booked less than three days in advance – almost entirely by contractors who were just informed by a building inspector that they can’t start work without RRP Certification.
My advice to municipalities, contractors and landlords working with federal funding is to become familiar with the Residential Lead Paint Hazard Reduction Act of 1992, or Title X, in addition to the RRP Rule. EPA and HUD have been partners on both regulations for over two decades, and Title X was essentially the beta version of RRP. Also remember that if you’re not currently in total compliance, it’s never too late to solve that problem. RRP classes are listed on the EPA website, and on our training calendar at https://flatleyreadllc.com/events.
