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New EPA Lead RRP Rule


New member
How do you guys see this affecting your industry?
We don't really do much PW, just as prep for painting.

Are any of you getting certified (or see the need to) to work on pre 1978 homes?

Do you routinely reclaim and filter water?

The RRP Rule is not real clear on the use of PW's, mostly defers to state rules and OHSA.


Trevor Steel

New member
I am not sure but I don't think we currently fall under the renovation category, so this shouldn't directly affect us. I may be wrong I am by no means an expert.

Tim Fields

New member
The new rule is pretty clear that it applies to us if we disturb more than twenty square feet of paint on the exterior. We will need this for paint prep. There are a variety of exclusions that you can use if certain conditions are met (Owner signs off that there are no children under six living in or occupying the space to be cleaned).

Word on the street is that as a licensed home improvement contractor in Maryland, I will not be able to renew my MHIC if I am not certified for lead.

The local authorities are saying that they currently have no way of managing or enforcing all of the requirements but that in no way implies that anyone is exempt.

It appears to me that the record keeping requirements are rather strict and the ability of the authorities to reach back and penalize lasts up to three years.

I am scheduled for certification next month and intend to maintain compliance with the new regs to the fullest extent practical, including the copius amounts of record keeping needed.

It does not appear that a low pressure soft wash would fall under the regs as there should be no disturbance of the surface.

Oh yeah, the maximum fine is $32,500.00 per occurence, per day.


New member
Thanks Tim.
I believe the opt out is no longer an option.
You can search for trainers here.
Some states are taking over the training, check here, it changes often, so you may want to contact your state.

In addition to taking the certification (2-300 dollars), you must also register with the EPA or State to be a "Certified Firm", $300. You should send in the app for this now so it is processed by April 22, you do not need to have had the training class to send this in.

Again, the RRP Rule states,
"To protect against this risk, on April 22, 2008, EPA issued a rule requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning. Under the rule, beginning in April 2010, contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination."

Michael Kreisle

Contributing Member
We just had a trainer come to a Local Apartment Association meeting las week. Spoke about this regulation. They were educating the Apartment owners/managers of the liability when hiring non-certified. Was kinda cool that they were educating our customers too.

Still not sure here if it will apply to us washing. Still checking on it.

Tim Fields

New member
We've had that stuff in place in NC for years? Enforced - no it wasn't but we knew about it as a very young company.

There has indeed been lead safe procedures and practices that must be followed in place for years.

This is a whole new round of EPA requirements that require updated traing/certifications to comply with the new regs. Even for those that have held lead-safe certs in the past.

Update. Wisconson, Iowa, and North Carolina are the only states that apparently have their own program in place and are allowed to substitute their stuff for the new EPA regs. Sorry about jumping the gun Celeste.
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Ken Fenner

Active member
I don't think anyone really knows for sure. We are all dancing around it. This is something the orgs (plural) should be looking into.


New member
I am reading stuff now how the EPA is backing off on a lot of waste water related violations. My experience in my own area - I think we'll continue to see hacks galore grinding lead paint like I have seen on a consistent basis. I have hard time believing the industry is going to be policed. To me, this is an area where you are a high profile contractor doing work for municipalities, large inner city commercial work, etc. Anyone else is just going to be self-policing if they jump on board - and trying to explain to homeowners why the price is even higher than the hack.

I admire the flow of information and knowledge on these boards - but the typical residential contractor that goes down to the local paint store - I doubt they'll catch wind of any of this for a very long time. This is good for me - I've been looking for a good excuse not to bid pre-78 homes anyways, too much work, not enough pay. Now I can just tell folks, that my business direction has changed for the upcoming year and won't be bidding on these older structures, and then tell them about all the new EPA regulations and the requiring of lead abatement licensing, etc. This way they can bitch at Uncle Sam vs. bitching at me.