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The purpose of the Renovation, Repair, and Painting Program (RRP) is to minimize exposure to lead-based paint dust during renovation, repair, or painting activities. Common renovation activities like sanding, cutting, and interior demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children. Firms performing renovation, repair, and painting projects that disturb lead-based paint in pre-1978 homes, child care facilities, and schools, must be certified by the Department of Commerce and use certified renovators who are trained by an approved training provider to follow lead-safe work practice. EPA has the authority to seek civil fines of $37,500 per offense and an additional criminal fine of $37,500 plus jail time for knowing and willful violations of the Renovation, Repair, and Painting Rule requirements.
WHEN TO PERFORM LEAD DUST CLEARANCE
Renovation activities that disturb lead-based paint can create lead dust so proper cleanup after these jobs is critical. The purpose of lead dust clearance is to determine if the area is safe for re-occupancy. Lead dust clearance is performed:
• After renovation, repair, painting, and cleaning activities are finished in a property built before 1978 and where children are assumed to spend time.
• After hazard reduction or maintenance activities in most federally-assisted properties built before 1978 that are covered by HUD’s LSHR. Lead dust sampling technicians should NEVER perform post-abatement clearance. (Abatement—as opposed to renovation, repair, and painting— is a term used for the complete removal of lead.) When performing clearance, the lead dust sampling technician is required to bring a copy of his or her certificate of initial training to the worksite.
Where To Collect Samples
Lead Dust Clearance Tests If there is more than one room, hallway, or stairwell within the work area, take:
• One windowsill sample and one-floor sample within each room, hallway, or stairwell (no more than four rooms, hallways, or stairwells need to be sampled).
• If the windows were not closed and covered with plastic during the renovation, also take one window trough sample in each room, hallway, or stairwell (no more than four need to be sampled).
• One-floor sample adjacent to the work area, but not in an area that has been cleaned. For federally-assisted housing, take these samples if the work area is contained, otherwise, clear the whole unit.
If the work area is a single room, hallway, stairwell, or a smaller area, take
• One windowsill sample and one-floor sample.
• If the windows were not closed and covered with plastic during the renovation, also take one window trough sample.
• One-floor sample adjacent to the work area, but not in an area that has been cleaned.