EPA ANNOUNCED IMPORTANT UPDATES TO THE RRP FINAL RULE. THESE UPDATES GO INTO EFFECT ON 10/5/2011!
1) Vertical Containment - Vertical Containment is now REQUIRED outside if you are within 10 feet of a neighboring property line. That means you must have plastic (or equivalent) hanging from eaves, roof, et cetera if you are working within 10 feet of the neighboring property line - this is no longer optional!
2) If you want to decrease the size of your containment area, either inside or outside, you can now use vertical containment (similar to asbestos set-up) to decrease the size (6' inside, 10' outside). Please remember containment is still required on the ground, and you still must clean an additional 2'.
3) A new page has been added to the Renovate Right brochure - explaining the importance and option to have dust wipe CLEARANCE tests performed at the completion of a project. The clearance is not required (unless HUD) but now it is clearer to the owner that this is an option.
Please click here for the updated Renovate Right Brochure (updated July 2011) which you should be using NOW!
4) In addition to D-Lead and Lead Check, the Certified Renovator now has the option of taking their own paint chip sample and submitting it to a lab for analysis. We are developing a procedure for this, please check back shortly!
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EPA HAS RELEASED THEIR "CONSOLIDATED ENFORCEMENT RESPONSE AND PENALTY PROVISION".
This document guides the EPA staff in assigning a fine for various rule violations. It establishes guidelines for what violations incur lesser penalties and which result in a full $37,500 fine. Please click on the link below to read this 44 page document.
COSOLIDATED ENFORCEMENT RESPONSE AND PENALTY PROVISION
This is a very long document, however please pay special attention to Appendix A (starting on pg. 30). This appendix lists out the violations of different parts of the rule and gives the corresponding penalty for not complying with the law.
The fine is dependent upon if a child is present or not, pg. 41 describes the "levels" of the fine and the associated dollar amounts.
