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Contractor Alert; Massachusetts files to take over EPA RRP Rule


Massachusetts will soon become the 9th state to enforce and administer the EPA RRP Lead Rule. The state filed emergency legislation on April 2nd to begin the process that will lead to local enforcement. This change will provide local service from state government officials for contractors and property owners who must comply with the new law. The state filed today. Once approved the Department of Occupational Safety will run the program.

Contractors and Property Owners must still follow the EPA RRP Lead Rule while working on pre-1978 homes. When the State of Mass is confirmed to administer and enforce the law new changes will need to be included in work practices.  

Here is the article form the State of Mass site;

On June 25, 2010, the Division of Occupational Safety filed with the Secretary of the Commonwealth, amendments to 454 CMR 22.00 (Deleading and Lead-Safe Renovation) and, in conjunction with the Executive Office for Administration and Finance, amendments to 801 CMR 4.02 454 (16) and (18) (Licensing Fees for Lead-Safe Renovation Contractors and Lead-Safe Renovator Training Providers).  These amendments, which will be published in the Massachusetts Register and become effective on July 9, 2010, can be viewed by clicking HERE.  These regulations were filed as emergency regulations on April 2, 2010.  The edits made in red line (click HERE) indicate changes made after public comment to the emergency regulations. 

These amendments, which establish safety standards for renovation, repair and painting work that disturbs lead paint in target housing and child-occupied facilities built before 1978, parallel similar federal EPA requirements that became effective on April 22, 2010 under the "Renovation, Repair and Painting Rule" (RRP Rule), 40 CFR 745.80 - 745.92.  The amendments to 454 CMR 22.00 are designed to be as protective of human health and the environment as the federal standard.  At this time, EPA has the exclusive authority to administer and enforce the RRP Rule. DOS will be filing an application shortly with EPA, seeking authorization to administer and enforce the lead safety standards for renovation, repair and painting work set forth in 454 CMR 22.00, in lieu of the federal standard being enforced by EPA in Massachusetts. DOS will request that this authorization be approved as close as possible to July 9, 2010, to coincide with the effective date of the amendments to 454 CMR 22.00.

Further information on the current federal administration of the RRP Rule, including application forms for contractors, applicable fees and lists of approved training providers may be obtained through the following link:  Further information on Massachusetts' administration of RRP requirements, including application forms for contractors, applicable fees and FAQs, is being developed and will be posted on this website as it becomes available.  In the interim, questions can be directed to DOS Environmental Engineers Patty Sutliff, Rick Rabin or Frank Kramarz at (617) 969-7177

The Contractor Coaching Partnership will continue to post new movements on this important development.

For contractors looking for guidance and assistance deciphering all the new developments and help implementing RRP practices into your business, we are holding a RRP Implementation Workshop on 6/30/2010 at Brockway Smith in Andover Mass. To register for this timely workshop use the link below. Seating is limited.

RRP Workshop Link; Register today!

RRP Implementation Workshop with Shawn McCadden

Mark the Coach

RRP Training

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Contractor Business Coaching    Design/Build Training  CSL/CEU Training Fall Protection Training   


Thank you for the alert, Mark. Much appreciated.
Posted @ Friday, June 25, 2010 9:16 PM by Stacy Carpenter
Although Senator Inhofe has succeeded in achieving a much needed delay of enforcement of the EPA lead paint rule, proposed is an even more onerous addition to the Renovator Rule. If enacted, the latest EPA revision will require laboratory dust clearance for even many small jobs, at a cost of hundreds of dollars per job. The testing could often cost more than the job itself. 
The proposal also makes it illegal to use most of the HEPA vacs recently purchased for this purpose 
A more complete analysis of the revision is posted at The EPA comment period ends July 6th. If you have concerns let the EPA, your US Senator and Congressmen know how you feel. 
Posted @ Monday, June 28, 2010 1:33 AM by RenovatingDeb
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