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Lead Regulations & Penalties (RRP, LSHR, OSHA)

epa-certified-firm-sls-constructionApril 22nd 2010 the EPA started enforcing a new lead paint regulation commonly referred to as the “RRP” (Renovations, Repairs, & Painting) or in legal speak 40 CFR §§ 745. This affects anyone owning, living in, or working on any pre-1978 “target housing” that may contain lead.

I can’t state this enough: You are responsible for knowing what the actual regulation states and following it. Be careful following others advice, or relying on information found elsewhere (yes even on the EPA’s site or this one) as it can be wrong or outdated. Relying on bad or outdated advice will not give you any protection if you are brought in for a hearing.

us-regionsResponsible Agencies & Contact Information

Currently 12 states have taken over the handling of the RRP (in red) while the remaining states & territories are overseen by the 10 regional offices of the EPA. For contact information: Click Here

Articles & FAQ’s on EPA’s RRP:

The Penalties & Fines Portion:

Adding to the mix- OSHA & the LSHR:

All articles, history & commentary:

RRP Refresher Training (Alabama)


This week I had the “pleasure” of attending one of the first “refresher” training courses for the RRP. Ah but wait, per the EPA one shouldn’t need to take a refresher course until 2015 (based on the extension given to those that completed training before April 22nd 2010). Well, welcome...Read More »

A look at the RRP enforcement actions & how it impacts you

Can you believe that today marks 943 days since the RRP went into effect? It only took them 119 days to come up with enforcement guidelines, and over 531 days to actually bring their first enforcement action? Well last week, (937 days...Read More »

RRP Updates: Effective October 5th, 2011

Has it really been 9 months since we had our last RRP update, and 17 months since we publically commented on the new changes that go into effect October 5th 2011 – whew it sure has been. Besides one fine being handed out finally (I mean the...Read More »

Guest Post: Introduction to RRP and Lead Certification

Well this is a first for me, instead of writing down my thoughts, I did a 30 minute podcast with James Dibben of the Blue Collar Coaching & Radio Network. James is a pretty interesting guy who not only still puts on the tool...Read More »

Alabama & the RRP: Shafted Part Deux

Interior Designers, Home Designers, Architects, “Consultants” and those already affected by the EPA’s RRP regulation – life just got more complicated & expensive if you work in Alabama. Unfortunately my sentiments after the first Public Comment meeting were correct, but none of the required...Read More »

140 Day's Later: RRP Penalty Guidelines Explained

In yesterday’s article, we did a quick overview of the RRP’s enforcement policies, looked at the current exemptions, what their 4 levels of enforcement options are, and provided a ton of links to help you hopefully avoid getting into trouble in the first place. In today’s...Read More »

139 Days Later: RRP Penalty Guideline's Established

About a month ago, I was asked to write a 300-word opinion piece on the RRP & where it stood 100 days later. In that piece, I made this comment about enforcement. “Enforcement: Well after being caught in a few lies, the EPA has effectively had...Read More »

EPA RRP Updates – The Three Stooges & a few other updates

As we had previously mentioned and discussed, as of July 6th there is a new Record Keeping Requirement that affects all contractors working on Pre78 Target Housing. Unfortunately, it appears that what the EPA stated it was going to be & what they posted on the Read More »

Public Comment on EPA RRP Proposed Changes

As we have mentioned in some previous posts that the EPA has requested Public Comments on a Proposed Extension into Public, Commercial & Industrial Buildings & a Clearance Testing Proposal....Read More »

EPA RRP: Proposed Extension into Public, Commercial & Industrial Buildings?

As we have mentioned in our recent articles on the EPA RRP updates, the EPA is requesting public comments on numerous items. One item they are considering is should they extend the current RRP policies to include public, commercial, and possibly industrial buildings. While this one issue theoretically...Read More »

EPA RRP Proposed Changes: Clearance Testing

Oh boy, here we go again. As a quick history recap – The following “proposed” & open for “public comment” changes to the RRP are due in part to the Sierra Club settlement that the EPA agreed to back on August 26, 2009. In this settlement, the EPA committed to propose...Read More »

EPA RRP Updates – The New Record Keeping Requirement

*** Update: The reg as stated below was not what they fully published – new article here *** But hey, who knows they might fix their mistake – yeah right 

As we mentioned in the EPA RRP & HomeStar Updates article back on May 6th, there is...Read More »

RRP Updates: Home Insurance, LSHR, HR 5177, & the Brochures

Well this has been a busy week on many fronts. For most of this week, I have been attending RESNET Training here in Atlanta. Needless to say, the EPA and the fallout from the RRP has not started to dissipate yet. In this article, I have three...Read More »

EPA RRP & HomeStar Updates

The RRP’s Opt-Out Provision:
As we mentioned in the 10 days later article, the Opt-Out is going bye-bye. The EPA’s proposed changes to remove the Opt-Out provision have been published in the Federal Registrar. In essence, that means any jobs your customers wish to Opt-Out of,...Read More »

10 days later; EPA RRP Updates

It has now been 10 full days now since the EPA’s Renovation, Repair & Painting Regulations were put fully in place. According to all of the EPA’s talk, we should have had plenty of news on this subject, but it has ended up being pretty quite overall. With that said,...Read More »

Last day before the RRP goes into effect: The 6/20 Exemption Limits

Well this is it – tomorrow the EPA’s new regulation goes into full effect. While there are plenty of misconceptions out there, we tried to concentrate on some of the biggest ones in the closing days. On day 5, we covered misconceptions concerning Certified Firms, while on...Read More »

2 Days to Go: The Logos, Testing & Pricing Misconceptions

Seeing I missed yesterday’s article on clearing up some RRP misconceptions, I figured I would double it up today & just for fun, I added in a third one that popped up today. Many of these items we have covered previously in other articles, but they bear some repeating.

Lead...Read More »

4 days to go – Clearing up a few misconceptions about Certified Renovators

In the last few days before the RRP regulation goes into effect, we decided to try to clear up some misinformation being propagated about the RRP. In yesterday’s article we covered some of the issues dealing with Certified Firms, and in today’s we are going to try to...Read More »

5 days & counting - Do I need to use a Certified Firm?

As I have mentioned before, there are plenty of gray areas in this regulation & some of the biggest questions revolve around the certification issue. “Do I need to be certified” or “does the firm I hire need to be certified”? As a homeowner, while you may be exempt from...Read More »

Guest Post: EPA’s New Lead Regulation and How It Affects You

You have been tagged, your mission if you choose to accept it is to write a blog article for BMoxieBMore - ahhh, welcome to the grown up’s version of tag. Seeing we are only 9 days away from the new RRP regulation being implemented, and there has...Read More »

10 days to go – Some praise, some links, and a WTF?

As many of you may recall, less than a month ago the EPA reversed course and finally decided to put the list of certified firms online. At that time, there was only 1806 firms registered, and as of 10 days ago, they had only managed to register 2272....Read More »

15 days to go – Where the RRP stands

LeadCheck Update:

The EPA still has not gotten back to me on the LeadCheck question – I have a letter from the EPA Regional Coordinator saying I heard wrong in class & that it is good to go for testing drywall & plaster. Then on the other hand, we...Read More »

20 Days to go – I am calling the EPA out

You know it is late and I planned to let day 20 simply slide on by. I was hoping at least to get one email to clarify an issue with the “approved” test kits, but alas – no answer. Then @NHCC sends out a Press Release from the...Read More »

25 Days to Go: RRP Work Practices – Clearing up some misconceptions

I happen to be a member of quite a few Contractor forums. Needless to say that this is one of the hottest topics on these boards as it affects almost every contractor out there. As I have mentioned in other articles there are plenty of “grey” area’s with the new...Read More »

30 Days to go – a quick look at the numbers

As many may recall in the 67 days & counting article I referenced the EPA’s original study found here: In it, they had four options for a 2-phase rollout. One option does come close to what we are looking at & it is called Option...Read More »

35 Days to go – the EPA & Alabama Public Comment Meeting

Needless to say, even though I had to shuffle some jobs around, I managed to make it to the Alabama’s Public Comment Meeting today. I had emailed all the Certified Firms in Alabama (12 currently) and two of them actually showed up (Champion Windows of Birmingham and Huntsville)....Read More »

38 days to go - Some good news & then the Alabama RRP issues

First the good news: The EPA has apparently reversed course and actually made the Certified Firm Database online. List of all EPA Certified Lead RRP Firms Perform a search based on your zip code

I do see one big issue – they calculated 215,000 firms would be impacted...Read More »

40 Days & Counting: RRP in the news / updates

My oh my, as we start getting closer to the deadline, it is amazing how many groups are now scrambling, political games are getting played out across the country, and unfortunately some contractors have been forced to make a tough decision.

41 Days to go - Alabama RRP Update

Follow up on the 65 days to go article – Alabama Remodeling Contractors get the shaft, and oh boy are we getting shafted… The Public Notice Period has already started & ends on April 2nd. On top of that, there is only ONE scheduled...Read More »

50 days & counting: Why OSHA is irrelevant to the RRP regulation

It is truly amazing how much bad information is put out on the internet every day. We have testing companies promoting their products, which a CLR cannot use. We have Lead Inspectors trying to sell their services as a way of getting around the RRP by saying – well only...Read More »

55 days & counting: OSHA & the RRP – Who’s affected, the requirements & the costs (part 2)

For anyone that has attended the EPA’s Lead RRP training knows, there is more to worry about then just what the EPA requires. As we discussed and showed in a prior article, OSHA has its own regulations that in some cases contradict what the EPA requires. One...Read More »

58 days & counting: One organization says enough and my thoughts about it

Well it appears that I am not the only one questioning the EPA’s hurried rollout, and one organization is actually pushing a letter writing campaign. While I personally disagree with a few items in the letter, it is actually nice to see that some of the current issues are at...Read More »

60 days & counting: OSHA and the EPA’s Renovation, Repairs and Painting Regulation

For anyone that has attended the EPA’s Lead RRP training knows, there is more to worry about then just what the EPA requires. As I have listed in previous articles, numerous federal agencies have their own regulations that we must know about – the CDC, CSPC, EPA, HUD,...Read More »

65 days to go – Alabama Remodeling Contractors get the shaft

You know it really is a beautiful day outside and all I have to do today is a final polishing on two articles that I want to get posted on the HRC. The kids are back in school today, the wife’s out and my next project does not start for...Read More »

67 days and counting… an open letter

I am sure you have heard this popular legal mantra, that “Ignorance of the law is no excuse.”  Really, so what might happen if a regulatory agency does not inform the public that such a regulation exists? Well, according to one agency’s own internal documents; “If the regulation is not...Read More »

LEAD FAQ’s – To Test or Not to Test – that is the question

As the property owner you have a question you should seriously consider, due to the increased costs of the EPA’s RRP rules, should I get my house or areas that are being worked on tested for lead, or should everyone just assume lead is present and proceed accordingly?...Read More »

LEAD, the EPA, and You – The Process of Remodeling a pre 1978 house

In the prior two articles on the new EPA Rules on Lead aka RRP (Renovation, Repair and Painting) rule being implemented by the EPA, we covered the Renovate Right brochure and a quick primer on the EPA’s RRP requirements. In this article, we are...Read More »

LEAD, the EPA, and You – a quick primer for Home Owners, Rental Owners, and Contractor’s regarding Renovation’s of pre-1978 houses

As I mentioned in a prior article, the EPA has released new regulations concerning LEAD in houses built before 1978. Unfortunately, there is still a lot of confusion out there on the subject and many contractors still don’t know this is coming. One quick example involves...Read More »

EPA Lead notice requirements for houses built before 1978

Effective Dec. 22nd, 2008, federal law requires that individuals receive certain information before renovating six square feet or more of painted surfaces in a room for interior projects or more than twenty square feet of painted surfaces for exterior projects in housing, child care facilities and schools built before 1978....Read More »