Stage
of Job
|
Requirement
|
HUD
LSHR
|
EPA
RRP
|
Changes
to LSHR Projects to Comply with RRP
|
Planning
and Set-Up
|
Determination
that lead-based paint (LBP) is present
|
EPA-recognized
test kits cannot be used to say paint is not LBP. Only a certified
LBP inspector or risk assessor may determine whether LBP is
present.
|
Certified
renovators use an EPA-recognized test kit to determine if
RRP rule applies or not.
|
None.
|
Training
|
HUD does not certify renovators or firms. All workers and
supervisors must complete a HUDapproved curriculum in lead
safe work practices, except that non-certified renovation
workers need only on-the-job training if they are supervised
by a certified LBP abatement supervisor who is also a certified
renovator.
|
EPA
or EPA authorized States certify renovation firms and accredit
training providers that certify renovators. Only the certified
renovator is required to have classroom training. Workers
must receive on-the-job training from the certified renovator.
|
Renovation
firms must be certified. At least one certified renovator
must be at the job or available when work is being done. (The
certified renovator may be a certified LBP abatement supervisor
who has completed the 4-hour RRP refresher course.)
|
Pre-Renovation
|
HUD
requires conformance with EPA regulations, including EPA’s
Pre- Renovation Education Rule. EPA had required renovators
to hand out the EPA / HUD / CPSC Protect Your Family from
Lead in Your Home (Lead Disclosure Rule) pamphlet.
|
Education
Renovators must hand out the EPA / HUD Renovate Right: Important
Lead Hazard Information for Families, Child Care Providers
and Schools pamphlet. (This requirement went into effect on
December 22, 2008.)
|
None.
|
During
the job
|
Treating
LBP hazards
|
Depending
on type and amount of HUD assistance, HUD requires that lead
hazards be treated using “interim controls” or “ongoing lead-based
paint maintenance.”
|
EPA
generally requires that renovations in target housing be performed
using lead-safe work practices.
|
None.
|
Prohibited
Work Practices |
HUD
prohibits 6 work practices. These include EPA’s 3 prohibited
work practices plus: heat guns that char paint, dry scraping
or sanding farther than 1 ft. of electrical outlets, and use
of a volatile stripper in poorly ventilated space. |
EPA
prohibits 3 work practices (open flame burning or torching,
heat guns above 1100 degrees F, machine removal without HEPA
vacuum attachment). |
None. |
Threshold
minimum amounts of interior paint disturbance which trigger
lead activities. |
HUD
has a lower interior “de minimis” threshold (2 sq. ft. per room,
or 10% of a small component type) than EPA for lead-safe work
practices. HUD also uses this lower threshold for clearance
and occupant notification. |
EPA’s
interior threshold (6 sq. ft. per room) for minor repair and
maintenance activities is higher than HUD’s de minimis threshold.
|
None. |
End
of job |
Confirmatory
Testing |
HUD
requires a clearance examination done by an independent party
instead of the certified renovator’s cleaning verification procedure.
|
EPA
allows cleaning verification by the renovator or clearance examination.
The cleaning verification does not involve sampling and laboratory
analysis of the dust. |
None.
|
Notification
to Occupants |
HUD
requires the designated party to distribute notices to occupants
within 15 days after lead hazard evaluation and control activities
in their unit (and common areas, if applicable). |
EPA
has no requirement to notify residents who are not the owners
after the renovation. |
None. |