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EPA lead ruling - updateJul 02, 2010


it may be that coops can let in uncertified contractors until October.


EPA Delays Enforcement of New Lead-Based Paint Certification and Training Requirements
Beveridge & Diamond, P.C., June 25, 2010

On June 18, 2010, the Environmental Protection Agency (“EPA”) announced its decision to delay enforcement of the certification and training requirements in the Lead Renovation Repair and Painting Rule (“RRP Rule”). The RRP Rule required renovation firms and individual renovators to become certified by April 22, 2010, prior to performing work on target housing and child-occupied facilities. EPA responded to complaints from the regulated community and related pressure from Congress regarding the processing time for applications and difficulty obtaining the necessary renovator training. The new deadlines for compliance with the rule’s certification and training requirements are as follows:

Renovation Firms: EPA will not enforce against renovation firms for violations of the certification requirement until October 1, 2010.

Individual Renovators: EPA will not enforce against individual renovators if the person has applied to enroll in, or has enrolled in, a certified renovator training class by September 30, 2010. Renovators must complete the training by December 31, 2010.

Join the Conversation Comments (2)
Re: EPA Lead Ruling - HabitatReporter Jul 03, 2010


Hi everyone, HabitatReporter here --

We haven't heard too much about this yet, but rest assured we are looking into it and will have more information for you this coming week. Have a great weekend everyone!

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> Join the conversation Comments (1)
epa - Louis Jul 06, 2010


letting uncertified contractors is not a great idea because even if epa doesn't bother you a shareholder may. Also beware how much you teach your staff other wise your board may be libel as a gate keeper .

As a certified contractor and a board member of my Co-Op I can tell you this new law may very well double the cost of most jobs in any building built before 1978 and all boards should talk with their attorneys first.

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EPA Lead Paint Requirements - HabitatReporter Jul 06, 2010


Hi, everyone,

The above commenter is mostly correct. The EPA has extended the deadline for training and certification. According to the official EPA memorandum,

"Until October 1, 2010, EPA will not take enforcement action for violations of the RRP Rule's firm certification requirement. For violations of the RRP Rule's renovation worker certification requirement, EPA will not enforce against individual renovation workers if the person has applied to enroll in, or has enrolled in, by not later than September 30, 201, a certified renovator class to train contractors in practices necessary for compliance with the final rules. Renovators must complete the training by December 31, 2010." [The full PDF can be found here: http://www.epa.gov/lead/pubs/giles_RRP_memo.pdf ]

So far this is all the information that we've been able to get from the EPA, but as our phone calls are (hopefully!) returned, we'll let you know what we find out.

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