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Massachusetts Enforcement of Lead RRP Rule

Massachusetts takes over Enforcement of Lead RRP Rule

On July 9, 2010, the MA Division of Occupational Safety (DOS) took over the enforcement of the Renovation, Repair and Painting Rule (RRP Rule) making it the ninth state to assume control of the Rule. The MA DOS, in conjunction with the Executive Office for Administration and Finance made several changes to both the Deleading and Lead-Safe Renovation regulation and the Licensing Fees for Lead-Safe Renovation Contractors and Lead-Safe Renovator Training Providers.

The following is a summary of the changes:

1. EPA RRP Firm Certification – Prior to July 9, 2010:

If you have already registered your Firm with the EPA prior to July 9, 2010 and you conduct your business in Massachusetts, you will only need to fill out the Lead-Safe Renovator Contractor Licensing Waiver Application and send this, along with a copy of the EPA RRP Firm Certification to the MA DOS (no additional cost).

2. NEW Lead-Safe Renovation Contractor – Beginning July 9, 2010:

If you have not yet registered your Firm prior to July 9, 2010 and you conduct your business in Massachusetts, you will need to fill out the Lead-Safe Renovator Contractor Application, provide a copy of the RRP Certificate obtained from the training course, and send it in with a bank certified check or money order for $375.00 to the MA DOS.

Note: A responsible person and/or manager must be RRP trained and certified prior to submitting this application.

3. Additionally:

If you conduct business in a non-EPA authorized state, you will need to fill out the EPA RRP Firm Application and send it in with a check for $300.00 to the EPA.

Non-EPA authorized states in New England include New Hampshire, Maine, Connecticut, and Vermont. For more information, visit the EPA website.

If you conduct business in Rhode Island, you will need to send the following information to the Rhode Island Department of Health:

Lead-Safe Remodeler/Renovator Application with a check or money order for $40.00.
Copy of the certificate indicating the successful completion of an approved initial Rhode Island licensed training course, or …

Copy of the certificate indicating successful completion of an initial EPA accredited training course from a state other than Rhode Island, and a copy of the results of the Rhode Island reciprocity test proficiency certificate.

4. Deadline Extensions for Massachusetts Workers

It would appear that the September 30, 2010 extension to obtain Firm Certification and December 31, 2010 extension to complete the RRP training course for Massachusetts workers may not be honored by the MA Department of Safety.

5. Massachusetts Department of Safety (DOS) Fines

The MA DOS will fine $5,000.00 per day, per violation for any renovators not complying with the lead-safe work practices beginning July 9, 2010.

Source: IEE – Institute for Environmental Education

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