No Immunity to Change; New RRP Rule Takes Effect this April

New EPA Rule Affects All Levels of Apartment Management, Not Just Maintenance

Times, as they say, they are a changing... and in our world in the multifamily industry, we are definitely not immune to the changes around us. Apartment industry professionals are expected to stay on top of federal, state and local laws and regulations.

One big change is coming on April 22, 2010, when the U.S. Environmental Protection Agency (EPA) will require employees and contractors who perform any renovations, repairs, and painting in homes built before 1978 to be certified as part of the new Lead-Based Paint Renovation, Repair and Painting (RRP) Rule. And, guess what? That includes multifamily properties.

Every day, maintenance technicians must work consistently in all areas of interior and exterior building maintenance and repairs. This type of work involves maintaining, repairing, and replacing windows, doors, trim, walls and flooring, all of which can disturb the paint job in work areas and can create a dusty environment; an environment that could prove to be hazardous not only to residents and their families, but to the maintenance technicians who work on the property.

For this reason, maintenance technicians and all onsite personnel who work in apartment communities built before 1978 need to be aware of this new EPA rule that provides regulations and guidelines on how to work safely with lead-based painted surfaces.

The impact on onsite maintenance personnel as well as contractors, who will also work on the property, will require extra training through an EPA-accredited training provider. It is important to remember that whoever is doing the work/renovation on the property, whether onsite maintenance personnel or contractor, that this training be completed by the April 2010 deadline. The required training for these groups includes:

• For maintenance personnel/contractors/subcontractors without prior EPA-accredited training: the successful completion and pass of one 8-hour course.
• For maintenance personnel/contractors/subcontractors who have previously taken an EPA/HUD-approved Lead-Safe Work Practice course: the successful completion and pass of one 4-hour "refresher" course.

In addition, and regardless of previous training, maintenance personnel must also take and pass the "refresher" training every 5 years in order to maintain their renovator status.

The EPA's RRP Web site serves as an excellent resource for what requirements and recordkeeping need to be present during a renovation.

Here are some helpful resources to help you learn about EPA's RRP Rule and the Rule compliance:

The National Apartment Association Education Institute has provided information about RRP compliance. Click here to learn more.

The U.S. Environmental Protection Agency's Web site dedicated to lead-based paint: www.epa.gov/lead 

The U.S. Environmental Protection Agency's Web site dedicated to RRP: www.epa.gov/lead/pubs/renovation.htm

Download the EPA's Renovate Right Brochure: http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf

National Lead Information Center: 800-424-LEAD (5323) or click here.

Pablo Paz is NAAEI's National Safety and Maintenance Instructor. He may be contacted directly at camt@naahq.org.