Five years since the implementation of the RRP Rule, and it’s still a common occurrence to encounter contractors and housing professionals who are unclear on, or completely unaware of, how RRP works with HUD or other federal funds.
As a lead based paint Risk Assessor, I often encounter well meaning contractors working in HOME, CDBG, or other federal programs who are unsure how to comply with RRP. The most common issue is the misunderstanding about trained non-certified workers. On a project that involves no federal funds, it is acceptable for a single RRP Certified contractor to train a crew of workers. These trained non-certified workers may perform lead safe work practices with minimal supervision as long as their training is properly documented and they are supervised by a Certified Renovator.
Once federal funding is involved, HUD rules supersede the RRP rule alone. Remember back in the day when we all had to take the HUD Safe Work Practices course? I took my Train the Trainer course at the 2001 Rural Housing Coalition conference and happily taught LSWP in library common rooms and coffee shops across the state until 2009 when HUD’s lead regulations got lobbied and lawyered into what we now know as the Renovation, Remodeling, & Painting Rule. For those of us who didn’t run housing programs under the first Cuomo administration, keeping RRP’s origin story in mind may help remind new program administrators and contractors about that often overlooked difference.
It’s been a few years since we’ve had a comprehensive, statewide training about RRP compliance when dealing with federally funded programs. It can be difficult enough to get contractors to work in our programs, and now we have to break the news that their entire crew needs a training that can cost upwards of $300 depending on your location. Free trainings aren’t as common as they used to be and even full price Initial courses are hard to find at the last minute. Most of our Initial classes these days are booked less than three days before the training – almost entirely by contractors who were just informed by a building inspector that they can’t start work without RRP Certification.
My advice to LPAs and other housing professionals is to carefully review the parts of Title X that apply to your funding sources, and cross reference this information with the RRP Rule. EPA and HUD have been partners on both regulations for over two decades, and don’t forget that Title X was essentially the beta version of RRP. Also remember that if you’re not currently in total compliance, it’s never too late to solve that problem. If you aren’t sure how to make HUD / EPA rules work cohesively in your housing programs ask questions. If you get conflicting answers, check with the National Lead Information Center, or contact the Rural Housing Coalition (they’re an invaluable resource for all sorts of compliance issues).
Michelle Read DeGarmo, President of Flately Read,LLC, is a lead based paint Risk Assessor, EPA Accredited RRP Trainer, and RHC’s resident lead based paint expert. Come meet us and chat one-on-one at the Rural Housing Coalition conference.