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Renovation Training

Renovation, Repair, and Painting Training
The Boston Public Health Commission is providing Renovation, Repair, and Painting (RRP) Training for home renovation contractors.  The US EPA implemented the new rule on April 22, 2010. The Commonwealth of Massachusetts Department of Labor Standards became a state authorized program to enforce the new RRP Regulation on July 9, 2010. It means that all firms and home renovation contractors who perform activities that may disturb lead-based paint in target housing (pre-1978 housing) and child occupied facilities and schools requires:
  • All Home Renovator Contractors to be trained, licensed, or certified in RRP.
  • Firms must be licensed or certified by DLS or EPA. DLS requirements require that firms be licensed at $375.00. If you were licensed or certified prior to July 9, 2010 by EPA, you must submit an application and seek a waiver from DLS.
  • Training Providers to be accredited and licensed or certified by DLS or EPA.
  • Lead safe work practices are to be implemented during all renovation work activities.
  • Provide Pre-renovation education in target housing and child occupied facilities.

Renovation, repair, and painting contractors have significant roles in the prevention of lead paint hazards such as leaded dust, lead paint chips, and debris during the performance of their home renovation work activities. It is important to understand the RRP regulations concerning:

  • Pre-renovation education activities must be provided to the Property Owner and Tenants. Distribution of the Renovate Right Pamphlet or Brochure and obtain signatures from property owner and tenants.   Notify Property Owners and Tenants 5 business before beginning renovation activities. Obtain signature of pre-renovation education on the RRP pamphlet form.
  • The use of an EPA Recognized Test Kits to determine if the work will disturb lead-based paint. Record information on an Recognized Test Kit Documentation Form.
  • Do not exceed the scope required by the RRP Rule of six square feet or greater on interior surfaces and 20 square feet or greater on the exterior surfaces. Post signs, limit access, use barrier tape, and orange cones to prevent people and pets from accessing the work area.  Do not eat, drink, or smoke in the work area.
  • The use of Containment Procedures on the interior and exterior of the property to prevent lead-based paint, lead dust, and debris contamination on the property or adjacent neighbor’s properties.
  • Use Respiratory and Dermal protection to prevent renovation workers from coming into contact with lead dust and debris. Workers must be fit tested for respirators, wear dermal protection (painter’s hat, protective goggles or face shield, workers gloves, nitrile (non-latex gloves, tyvek suits, shoe coveralls or booties, and monitored for lead exposure.
  • The Certified Renovator or Licensed Lead Safe Renovator Contractor Supervisor conducts a visual inspection after the work has been completed for any remaining dust or debris, using a microfiber cleaning cloth to wipe down any surfaces, and compare the cleaning cloth with the cleaning verification card or take dust wipe samples for lead dust analyses, and conduct a final cleaning up of the work site, bag all waste in heavy duty trash bags, goose-neck and duct tape down the top.  {Insert picture} If the bagged waste exceeds 220 lbs, it must be disposed of as hazardous waste and sent to a secure landfill.  Check your local regulations to ensure proper disposal.
  • Record Keeping  is a requirement for all records generated from the renovation activities.  Home renovation contractors should ensure that all paperwork, cleaning verification, pictures, certification, and training of workers are kept in a secure location. Records must be kept for 3 years after the renovation activities and made available upon the request from DLS or EPA.
  • Check local regulations for the proper disposal of home renovation waste.

EPA and DLS require certification or licensure for all renovation firms and also training and licensure or certification for renovators to prevent lead poisoning resulting from unsafe renovation practices.

DLS issued additional requirements for firms and home renovation contractors in accordance with their regulations of 454 CMR 22.00. Other regulations that apply are Massachusetts General Laws Chapter 111, 197B-199B, Massachusetts Lead Law 460.000, 460.175(A), and 460.100 with the short –term vacation or recreational rentals.  Monitoring of home renovation contractors for lead poisoning must be implemented in accordance with 29CFR 1926.62 of OSHA. A Model Written Medical Monitoring and Worker Protection Program for Firms is available from DLS. DLS also has a Model Written Respiratory Program for Firms.

All home renovation contractors representing the Licensed or Certified Firm initially must take an 8-hour course to be trained and certified as Certified Renovators or as a Licensed Lead Safe Renovator Contractor Supervisor. They must also take a 25 question examination with a passing score of 70% or more.   The Certified Renovator or Licensed Lead Safe Renovator Contractor Supervisor may train all other firm workers.  Copies of their training must be kept as quality assurance records and must be available for review during onsite renovation activities.  DLS requires that Certified Renovators or Licensed Lead Safe Renovator Contractors Supervisor are always available during onsite renovation activities. A 4-hour training course is required for refresher training and contractors must take a 25 question examination with a passing score of 72% or more.

DLS and their representatives will issue Cease Work Orders on any home renovation contractor or firm that fails to fully implement the RRP rule and regulations. Fines may also be levied against contractors and firms. A maximum fine of up to $5,000.00 may be assessed by DLS per incidence of violations of the RRP Rule under 454 CMR 22.00.

If you need to be trained as a Lead Safe Renovator Contractor Supervisor or received refresher training, please submit the Renovation, Repair, and Painting Training Application enclose your check for $50.00 for a Boston-based contractor or $150.00 for all other contractors with businesses outside the City of Boston and check the Renovation​, Repair, and Training Schedule for available dates and times.  You may also call the Environmental Health Office at 617-534-5965 or send email to leadpoisoning@bphc.org

If as a home renovation contractor you require additional training in Moderate Risk Deleading to enable you to perform component by component replacements that includes windows but not demolition you can refer to the Moderate Risk Deleading Training Application and the Moderate Risk Deleading Training Schedule.

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Boston Public Health Commission
1010 Massachusetts Ave, 6th Floor, Boston, MA 02118.
Phone:(617) 534-5395 Email: info@bphc.org