EPA Inspection Reveals Violations of Renovation,
Repair, and Painting Rule for RDF Inc. in Lincoln,
FOR IMMEDIATE RELEASE
(Lenexa, Kan., March 19, 2015) - EPA Region
7 conducted a random record-keeping inspection
at RDF Inc., doing business as Paul Davis Restoration,
a Lincoln, Neb., remodeling company, in December
2012, which revealed violations of the Renovation,
Repair, and Painting (RRP) Rule. As a part of
a settlement, RDF Inc. has agreed to spend $27,304
to replace windows in pre-1978 homes in Lincoln,
and pay a $3,033 penalty.
According to an administrative consent agreement
and final order filed by EPA Region 7 in Lenexa,
Kan., the inspection revealed that RDF Inc.
failed to provide the Renovate Right pamphlet
to the owner; failed to retain records for three
years; failed to assign a certified renovator
to each renovation; failed to keep warning signs
in place until after the renovation passes post-cleaning
verification; failed to clean the work area
after the renovation was completed until no
dust, debris or residue remained; and failed
to collect all paint chips and debris and seal
in a heavy duty bag. RDF Inc. also failed to
ensure that collected waste was stored behind
containment at the conclusion of the renovation.
RDF Inc. is a home remodeling company offering
emergency renovations for fire and water-damaged
homes. Emergency renovations are those performed
in response to situations necessitating immediate
action to address safety or public health hazards
or threats of significant damage to equipment
and/or property. Many renovators are unfamiliar
with the limitations to emergency renovation
situations. The need for immediate action relieves
firms from some, but not all, lead-safe work
requirements. Once the emergency renovation
is over, the typical RRP rules apply.
The RRP Rule requires that contractors who work
on pre-1978 dwellings and child-occupied facilities
are trained and certified to use lead-safe work
practices. This ensures that common renovation
and repair activities like sanding, cutting
and replacing windows minimize the creation
and dispersion of dangerous lead dust. EPA finalized
the RRP Rule in 2008 and it took effect on April
This enforcement action addresses RRP Rule violations
that could result in harm to human health. Lead
exposure can cause a range of adverse health
effects, from behavioral disorders and learning
disabilities to seizures and death, putting
young children at the greatest risk because
their nervous systems are still developing.
Today at least 4 million households have children
that are being exposed to high levels of lead.
There are approximately half a million U.S.
children ages 1-5 with blood-lead levels above
5 micrograms per deciliter (µg/dL), the reference
level at which the Centers for Disease Control
recommends public health actions be initiated.