Recently, the EPA and Department of Justice announced a settlement with Home Depot regarding alleged violations of the EPA’s Lead Renovation, Repair and Painting (RRP) rule at several home renovations performed by Home Depot’s contractors. According to the settlement, Home Depot will pay a $20.75 million penalty, which is the highest civil penalty for a settlement under the Toxic Substances Control Act. In addition, Home Depot will implement a corporate-wide program to ensure that its contractors are certified to perform lead paint work and that they are implementing safe work practices.
The alleged violations included the use of uncertified contractors, lack of lead safe work practices, contractors who did not perform post-renovation cleaning, did not provide the required lead-based paint pamphlets to occupants, and did not establish compliance records.
Home Depot will be establishing an electronic compliance system to verify contractors are properly certified, and if they’re not, that they are removed from their hiring system. It will also require contractors to use a detailed checklist to document compliance. The checklist leads contractors through the steps required for compliance. They will also include provisions in its contracts with contractors to ensure that they are complying with lead paint regulations and conduct on-site inspections to ensure compliance with safe work practices.
Additionally, they will be tracking the lead paint certifications of their contractors and will take action to respond when a contractor is not operating in compliance with the rules. If violations are found, Home Depot is required to correct them and report them to the EPA.
Contractors that encounter potential lead paint during remodeling or renovation projects have to be certified in safe removal practices. The RRP rule applies to child-occupied facilities, such as daycare centers and preschools, and any housing that was built before 1978. Contractors must take a class to learn safe removal procedures before working on projects that may contain lead paint.
ACO provides RRP lead paint classes for contractors who perform work on projects with potential lead paint. Contact us to enroll in one of these classes.
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