EPA Updates

Update No. 2 (June 2010)

Delayed Enforcement Policy

While Congress is considering legislation that would delay enforcement of the RRP certification requirements, the extension has not been passed and signed by the President as of the date of this update.

In response to the efforts in Congress to delay enforcement of the RRP Certifications, the EPA issued a guidance letter on June 18, 2010 which provides:

1.  The EPA will not take enforcement action for violations of the requirement for firms to obtain RRP certification until October 1, 2010; and 

2.  The EPA will not enforce violations of the individual certification rule provided until December 31, 2010, if:

        a.   The worker has applied to enroll or actually enrolls in an approved training class by not later than September 30, 2010; and

         b.   The worker completes the class and obtains certification by December 31, 2010.

Key Point:  These only apply to the certification requirements, they do not extend to any of the performance requirements.  The memo specifically states "EPA WILL CONTINUE TO ENFORCE THE WORK PRACTICE REQUIREMENTS IN THE RULE WHICH PROTECT CHILDREN AND REDUCE LEAD EXPOSURE. "

If you would like to read the full text of the guidance letter, click here.

The EPA has also published a list of  Frequently Asked Questions about the extension. If you would like to review the questions, click here.

Regional EPA Contacts for RRP Rule

The EPA recently published a list of Regional Contacts and Enforcement Offices for the RRP Rules.  Click here to read the contact list. 

 

Update No.  1 (May 2010)

The Opt-Out Provisions of the RRP rule DID expire on July 6, 2010.

On May 6,2010, the EPA published the items below in the Federal Register. 

1.  Opt-Out & Recordkeeping

This final Rule eliminates the "Opt Out" provisions and requires contractors to give homeowners and/or occupants a copy of records demonstrating compliance with the training and work practices of the RRP.  This rule became final on July 6, 2010.

To read the Final Rule click here.

2.  Proposed  Rule to change and expand the "Clearance Testing Requirements"

To read this proposed change click here.

To submit comments on this proposed change  click here.

3.  An Advance Notice of Proposed Rule Making to expand the RRP rules to commercial and public building.

To read this proposed change, click here.

To submit comments on the proposed change  click here.
 

RRP training is provided by Seagull Environmental Management Company, Inc. and assisted by Kinberg Contractor Training. Courses are approved for certification under section 402 of TSCA for the Certified Renovator.