B. Federal Lead-Based Paint Enforcement Bench Book - National ...

Fig. 15: RRP Rule “Grandfathering” Provisions
Prior Training
(Completion of the prior training listed
below)
Abatement Worker Training
Abatement Supervisor Training
EPA &/or HUD Model Renovation
Training
LBP Inspector Training
LBP Risk Assessor Training
+ RRP Refresher
(Completion of the RRP
refresher course listed
below)
Refresher
Renovator Course
Refresher
DST Course
= RRP Certification
(Qualifies one for the
RRP certification listed
below)
Renovator
Renovator Responsibilities 446
Certified renovators must ensure compliance with work practice standards – and must:
• Perform the visual inspection and post-renovation cleaning verification. 447 (This function and the other
tasks cannot be delegated.)
• Perform, or direct uncertified workers who perform, renovation activities (posting signs, containment,
prohibited practices, waste control, and cleaning). 448
• Train uncertified workers on lead-safe work practices for their assigned tasks. 449
• Be “physically present at the work site” when warning signs are posted, and during work area
containment and cleaning. 450
• “Regularly direct” work performed by others to ensure adherence to the work practices, including
“maintaining the integrity of containment barriers and ensuring that dust or debris does not spread
beyond the work area.” 451
• Be available on-site or by telephone at all times that renovations are underway. 452
• When requested by the customer, must use an acceptable test kit to determine whether affected
components are lead-free (as explained above). 453
• Have copies of their course completion certificate (which serves as the renovator’s certification 454 ) with
them at the work site. 455
• Prepare records required to verify compliance with the work practices. 456
446 40 C.F.R. § 745.90(b).
447 40 C.F.R. § 745.90(b)(1).
448 Id.
449 40 C.F.R. § 745.90(b)(2).
450 40 C.F.R. § 745.90(b)(3).
451 40 C.F.R. § 745.90(b)(4). In EPA’s view, the renovator must be present “often enough to ensure that no violation” occurs.
452 40 C.F.R. § 745.90(b)(5).
453 40 C.F.R. § 745.90(b)(6). Nothing in the rule prohibits a contractor from using a test kit at times other than upon
customer request.
454 73 Fed. Reg. 21692, 21723, supra note 160.
455 40 C.F.R. § 745.90(b)(7).
456 40 C.F.R. § 745.91(b)(8). The renovator may use EPA’s sample checklist. Future Sample Renovation Recordkeeping
Checklist, www.epa.gov/lead/pubs/renovation.htm#contractors.
DST
NATIONAL CENTER FOR HEALTHY HOUSING www.nchh.org 61