Agency (EPA) announced two important updates regarding the
Lead Repair, Renovation, and Paint (RRP) Rule.
The agency, which had been contemplating these updates in
response to the destructive storms of the past year, has issued its
answers on two crucial points regarding recordkeeping: How
to reflect the job was subject to an emergency renovation as
well as clarifications on what constitutes a “whole-house gut
rehabilitation project.”
In each case, EPA provided a new FAQ entry.
• Application of Record keeping for emergency renovation
• Whole-house gut rehabilitation project clarification
These updates are most important for work in the areas
hardest hit by the hurricanes in the fall of 2017, such as the Gulf
Coast. Contractors, property owners and operators will now be
able to more efficiently conduct repair work, helping hard-hit
communities recover faster.
The EPA’s Inspector General also recently sent out
notification that the office will review the agency’s overall
implementation of the RRP Rule. The aim of the review is
to determine whether the EPA has an effective strategy to
enforce the RRP, as well as if it will support businesses seeking
compliance. Any improvements under the RRP are welcome
news to the real estate community, as reform is sorely needed.
Owners and contractors have struggled to comply with the
onerous provisions of the RRP rule since it was since it went into
effect in 2008 (with additional amendments in 2010 and 2011).
The RRP Rule requires contractors certify through the EPA
any work conducted in properties where lead paint is present.
RRP also requires that contractors hire only specially trained
workers. In some areas, it is extremely difficult to find workers
who have this special qualification. The RRP rule’s certification
requirements are burdensome and contribute to the labor
shortage in the construction industry, which leads to downstream
project delays and higher costs.
NAA expects the EPA to continue its review of all of the
federal regulations relating to lead-based paint. As always, NAA
stands ready as a resource for the apartment industry.
www.aamdhq.org
MAY 2018
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