Lead Renovation Repair and Painting Rule Q&A

Q. I am a renovator and I want to comply with EPA's Lead Renovation, Repair and
Painting Rule. What do I need to do?

EPA's Lead Renovation, Repair and Painting (RRP) rule sets up new requirements for firms
and individuals performing renovations in pre-1978 housing and child-occupied facilities,
such as schools and daycares.

Firms must be EPA certified. To become EPA certified, renovation contractors must
submit an application and fee payment to EPA (www.epa.gov/getleadsafe). Once certified,
the firm will be able to advertise that they are certified by EPA under the RRP program, and
will also be given rights to use EPA's "Lead-Safe Certified Firm" logo.

Renovations covered by the rule must be performed or directed by a Certified Renovator.
Individuals can become a lead-safe certified renovator quite easily. It requires successful
completion of a one-day training course in lead-safe work practices. The training courses are
offered by EPA-approved private training providers; there is no additional fee to EPA. You
can find a training provider in your area by using EPA's search tool at
http ://cfpub.epa. gov/flpp/searchrrp training.htm.

Over 194 training firms have been accredited to provide the specialized, one-day lead-safe
work practices training. Classes teach the specific work practices that contractors need to
protect themselves and their clients from lead contamination, and to allow them and their
firm to work legally. Certification is immediate upon successful completion of the training
class.

Q. I am planning to renovate my home. How can I find a lead-safe certified firm?

EPA has a searchable database to help you locate lead-safe certified firms near you at:
http://cfpub.epa.gov/flpp/searchrrp firm.htm. In addition, you can call EPA's lead hotline at
1-800-424-LEAD (5323) if you have questions.

Q. I have hired a firm to renovate my home, but now I am concerned about whether
the firm is a lead-safe certified firm. How can I find out?

EPA has a searchable database to help you locate lead-safe certified firms near you at:
http://cfpub.epa.gov/flpp/searchrrp firm.htm. It is possible that your firm is not yet listed on
EPA's web site, but is certified. If you do not find your firm on EPA's web site, you should
call EPA's lead hotline at 1-800-424-LEAD (5323) and speak to an expert who can help you
find out whether your firm is certified.

Q. I took a class to be a Certified Renovator and my firm applied for firm certification
before April 22, 2010, but my firm does not have its certificate yet. What do we do?

In these circumstances, EPA does not intend to take enforcement actions against firms who
applied for firm certification before April 22 and have not received their certification. The
certification requirement is important to making sure that firms are protecting children and

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other residents while renovations are ongoing, but EPA does not wish to disrupt ongoing
renovations for those firms that submitted applications on time. We expect that all of the
applications filed before April 22 will be reviewed by June, and that the applications
submitted for the first 60 days after April 22 will be reviewed soon thereafter. Thus, it will
only be a short window of time when firms that applied are waiting to hear back from EPA.

Q. How long will it take EPA to process my application to be a lead-safe certified firm?

EPA is required to process your application within 90 days of receipt. In most instances,
properly-completed firm applications are processed in about one month. EPA expects that all
of the applications filed before April 22, 2010 will be reviewed, and those that are complete
will be approved by June, and that the applications submitted for the first 60 days after April
22 will be reviewed soon thereafter. Thus, it will only be a short window of time when firms
that applied are waiting to hear back from EPA.

Q. What happens if my firm is in the middle of a renovation job on April 22, 2010? My
firm is not certified and none of my employees have taken the lead-safe certified
renovator training. What should I do?

You should submit your application for renovation firm certification immediately. You
should also arrange for lead-safe certified renovator training for at least one of your
employees as soon as possible, and you should require at least one of your employees to
review EPA's online training materials at http://www.epa.gov/lead/pubs/training.htm. In
addition, you must follow the lead-safe work practices required by the rule. Information on
these work practices can be found at www.epa.gov/lead or obtained from the National Lead
Information Center at 1-800-424-LEAD (5323). For the first 60 days after April 22, 2010,
EPA's general approach for work initiated before that date will be, upon learning that a firm
or individual conducting a renovation is not certified or trained, to issue a notice without
monetary penalties to that firm or individual. This notice will state that the firm or individual
needs to come into compliance as quickly as possible. To correct the noncompliance, the
individual or firm will need to provide a copy of an accredited course completion certificate
or firm certification to EPA within a reasonable time.

Q. I am a renovation firm and I have contracted for a renovation in a pre-1978 home to
begin on or after April 22, 2010. None of my people have taken the lead-safe
certified renovator training yet. I found out the Certified Renovator classes near me
are all full until after April 22, 2010. What should I do?

You should hold off on starting work in any pre-1978 home or child-occupied facility until
you have taken the certified renovator training course from an EPA-accredited training
provider. In addition, you should make sure that your firm is EPA certified. You can find
out more information at www.epa.gov/getleadsafe. You can find an accredited training
provider who is based near you by using EPA's search tool at

http ://cfpub.epa. gov/flpp/searchrrp training.htm. More than 100 EPA-accredited training
providers have indicated to EPA that they are willing to travel to offer training classes. You

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can find a list of training providers, including those who are willing to travel, by using the
same search tool.

Q. I am a firm and there are no training providers offering classes near me. What do I
do?

More than 100 EPA-accredited training providers have indicated to EPA that they are willing
to travel to offer training classes. You can find a list of training providers, including those
who are willing to travel, by using EPA's search tool at
http ://cfpub.epa. gov/flpp/searchrrp training.htm.

Q. I operate a renovation firm and I have heard that my state will adopt its own lead
Renovation, Repair and Painting program. Do I have to also be certified by EPA?

As of April 21, 2010, only seven states have their own RRP programs (Mississippi, North
Carolina, Wisconsin, Iowa, Kansas, Rhode Island, and Utah). If your firm is located in one
of these states, you should contact them for information on their certification requirements.
If you work outside of one of those states, your firm needs to be certified by EPA.

Q. Will EPA issue a final rule removing the opt-out and if it does when will the rule
become effective?

As of April 22, 2010, EPA has issued a rule revoking the opt-out provision of the 2008 Lead
RRP rule. EPA expects this rule to publish in the Federal Register within 2 weeks and
anticipates that it will take effect 60 days after publication.

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