New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This

**ChrWright** · 11-29-2009, 09:30 PM

That's a good point to bring up. Heretofore, only Wisconsin has established it's own lead safe rules (all states have that option)--but other states are bound to add their own wrinkles. They can't make something less stringent that the EPA rule, but they can certainly make it stricter.

Something to keep and eye out for over the next year.

charimon · 11-29-2009, 09:34 PM

Quote:

Originally Posted by ChrWright

I doubt they let you clear your own projects anyway, even if you did set up a separate company for it.

The wording is vague. I think this is intentional so local government agencies can do their own testing, abatement and clearance.

aside from that you would be setting your self up for tort claims.

carolinahandyma · 11-29-2009, 09:59 PM

The instructor I had for the EPA certified renovator class also teaches lead abatement classes. He pointed out several of the differences between lead abatement (much stricter) vs. RRP.

He stressed that the intent of RRP is conducting a safe renovation project (via containment, make as little dust as possible and clean-up). The intent of lead abatement is the safe reduction and/or removal of a lead paint hazard. They are similar but they have different purposes.

FremontREO · 11-30-2009, 12:02 AM

Quote:

Originally Posted by charimon

The key here is the wording in the contract. If you are covering lead paint with siding that is an "enclosure" abatement. If you are adding new siding that is a Renovation.

The key is in the contract. Keep it in the renovation side. your RRP firm license and certs have NO standing on an abatement...

Some Hoops for abatement:

abatement larger than 100 sf In NE you must pay an additional $200 large abatement fee

Inform the state 10 days prior.

inform the state job hours including lunches.

Have the unique abatement plan for that property.

all licenses, physicals, training certs on hand fro each worker.

OSHA documentation.

lead air sampling data to demonstrate all processes are under the action level or what actions are in place between the action level and PEL
only certified lead abatement workers with current physicals and fit tests.

a licensed lead supervisor present or with in one hour away (depending on where in the process you are)

Craig

Craig, thats a good explanation! I took a class in Omaha at MTI a while back. good bunch of guys doing abatement work and such. maybe you know of 'em.? Good time except getting truck broke into at the motel...

MEL · 11-30-2009, 07:22 PM

Does this thread really belong in the Marketing category?

I find these “Sticky” things to be kind of annoying, especially this one doesn’t relate to marketing.

**rselectric1** · 11-30-2009, 07:54 PM

Quote:

Originally Posted by MEL

Does this thread really belong in the Marketing category?

I find these “Sticky” things to be kind of annoying, especially this one doesn’t relate to marketing.

I agree that it might be misplaced, but "this one" pertains to a large majority of the posters here.

How much would it annoy you if it was stickied in new posts or general discussion?

A 36K fine might annoy you even more!

**ChrWright** · 11-30-2009, 08:15 PM

Quote:

Originally Posted by MEL

Does this thread really belong in the Marketing category?

I find these “Sticky” things to be kind of annoying, especially this one doesn’t relate to marketing.

I originally started this as a marketing thread for the lead rule, but the content has certainly veered away from that.

I have relocated the thread to General Discussion.

BCConstruction · 11-30-2009, 08:34 PM

So if they are coming down so strict on this law then what are they going to do about the main cause of lead poisening in the US? Lead water mains, Lead solder joints, Brass Fittings and faucets and so on. These cause far many problems than some paint on a wall.

**rselectric1** · 11-30-2009, 08:38 PM

Quote:

Originally Posted by BCConstruction

So if they are coming down so strict on this law then what are they going to do about the main cause of lead poisening in the US? Lead water mains, Lead solder joints, Brass Fittings and faucets and so on. These cause far many problems than some paint on a wall.

That's so true, but it's at least a start. BTW reply to this post so you can hit 1000, the suspense is killing me

BCConstruction · 11-30-2009, 08:51 PM

Quote:

Originally Posted by rselectric1

That's so true, but it's at least a start. BTW reply to this post so you can hit 1000, the suspense is killing me

Wow 1001 posts now. Dam thats gone up quick. Clearly i got to much free time on my hands

.

**rselectric1** · 11-30-2009, 08:59 PM

Quote:

Originally Posted by BCConstruction

Wow 1001 posts now. Dam thats gone up quick. Clearly i got to much free time on my hands

.

Congrats.

Me too. When I'm busy I'll ignore the site for days on end, but during the lulls, I spend WAY too much time here. Most of my posts are on a binge basis

**rselectric1** · 11-30-2009, 09:06 PM

Back to the subject at hand though.

I talked to my plumber and hardwood guys today with the same blank stares. I e-mailed them both the link Chr Wright provided.

My plumber contractor is licensed and union and even he has heard nothing about this.

I have a feeling the S*** might hit the fan in April.

If the "reward" system is in place like they did with freon with the EPA a while ago, I'll bet we will see a crapload of people trolling older neighborhoods looking for dumpsters and will make a living just turning people in.

It will be interesting.

tommytwo · 11-30-2009, 09:47 PM

I think that the exterior exclusion is going to be 20 square feet per project, not per side.

From the "Model Renovator Training Course:"

Summary of Updates/Corrections

November 6, 2009. Module 2, Page 2-3, in the student notes. The exterior exclusion for minor repair and maintenance activities was incorrectly stated as 20 square feet per side. Removed "per side," the exclusion for exteriors applies per project, not per side.

At the bottom of the page here:http://www.epa.gov/lead/pubs/epahudrrmodel.htm#manuals

charimon · 11-30-2009, 10:12 PM

Quote:

Originally Posted by FremontREO

Craig, thats a good explanation! I took a class in Omaha at MTI a while back. good bunch of guys doing abatement work and such. maybe you know of 'em.? Good time except getting truck broke into at the motel...

Im sure that gave you a Fine impression of Omaha. I took my classes from the MTi guys as well......... I think they are the only training company for this and asbestos in quite a distance.

I hear that the Iowa Lead laws are quite extreme.

Craig

FremontREO · 11-30-2009, 10:21 PM

Quote:

Originally Posted by charimon

Im sure that gave you a Fine impression of Omaha. I took my classes from the MTi guys as well......... I think they are the only training company for this and asbestos in quite a distance.

I hear that the Iowa Lead laws are quite extreme.

Craig

Iowa is extreme with anything anymore so they can help finance the debt on the backs of contractors....And they are re-writing the laws again for lead. Omaha is a great town-just a few bad apples like everywhere. Its fun watching the posts on this epa ruling and I truly think its going to get bad for all of us. Went to a house today to inspect a lead abatement job a contractor cleared and not a thing was done to cure the problem so maybe, just maybe this law is neede. (never thought I would say that

)

dadarnall · 12-01-2009, 08:42 PM

Absolutely amazing!! Another environmentalist whacko idea to save us from all the things that are going to kill us.

BCConstruction · 12-01-2009, 08:51 PM

Wait until the hazmat rule come in affect. We will all have to be fully kitted out in hazmat suits before we can enter a site.

charimon · 12-01-2009, 09:06 PM

LOL
What i really like is the little Dremel add with the multimaster clone Dry sanding lead based paint

"alligator skin" cracking is a "defining" characteristic of degraded lead based paint.

Craig

**ChrWright** · 12-02-2009, 04:28 PM

Has anyone yet contacted their agent regarding the new rule and what it will mean for your GL policy? As has been mentioned, many are fearing the insurance industry will apply lead abatement rates to companies who perform work under the RRP rule.

I sent this letter to my agent today and I recommend contacting our own agents/providers to find out what it might mean for you:

Quote:

Dale,
A new rule has been passed by the EPA regarding renovations to homes built before 1978. It takes effect in April of 2010 and is called the RRP Rule (Renovation, Repair, and Painting Rule). This rule addresses the creation of lead hazards from the disturbance of painted surfaces. The rules do not require abatement or abatement training/certification, and I know work in those areas requires special insurance riders. The requirements are that all firms who perform work in pre-1978 homes or child-care facilities apply to be certified by the EPA, and that every project have a Certified Renovator (individual), who has passed an EPA approved training program on lead safe practices. Those who perform the work must be trained by the Certified Renovator in those practices, and when the project is complete the Certified Renovator must perform a cleaning verification process to ensure any hazards created during the renovation were cleaned-up properly.

I have taken and passed the renovator class, and will be applying to the EPA for WrightWorks to be a certified firm. Needless to say, this rule has caused quite a stir in the industry. It requires additional practices and monitoring that will drive our project costs up, and many of us feel that if not well enforced, the fly-by-night contractors who don't play by the rules (compliance, permitting, insurance, etc.) will benefit by undercutting the prices of those of us who do.

My question to you is two fold:

1. Has there been any discussion within the contractor insurance community regarding the insurance implications of this new rule?
2. Are there any notices on this rule from my current GL insurance carrier, and what will the impact to my current policy be?

Many of us are concerned that the insurance industry is uneducated and unprepared for this, and will simply apply lead abatement policies and rates to those of us who perform work under these new rules. I will stress again that the EPA has written the rule so that the work and practices do not fall under hazardous material handling classifications. It merely specifies specific reporting and paperwork requirements, as well as lead-safe practices and clean-up proceedures. It does not require anything involving hazardous waste disposal, except that any refuse generated during a project must be removed in such a way as to prevent lead dust and particles from contaminating the rest of the house and that a thorough and verified cleaning process is performed at the end of the project.

The majority of my projects involve work in homes that are targeted by this rule, so needless to say I am very concerned about the insurance implications to my company. Please look into this with my insurance provider and let me know what those implications will be.

Regards,

Christopher Wright
President, WrightWorks, LLC
www.WrightWorks.net
President, Central Indiana Chapter of the National Association of the Remodeling Industry
www.NARIIndy.com

silvertree · 12-02-2009, 06:49 PM

Chris, I am connected to NARI and NAHB people, both groups are clueless to anything but the minimum requirements.

My insurance which is a dedicated contractor insurance company has not heard about the lead ruling.

It just gets worse when you talk to the city of Mpls inspectors, they don't know what I'm talking about.

Welcome to the new way of doing things, they will have fines and procedures for licensed contractors but nothing for enforcement on non licensed contractors.

11-29-2009, 09:30 PM	#81
ChrWright View Profile ChrWright Builder/Remodeler Send Message Follow Blogs (2) Threads (3,563) Photos (0) Reviews (0) Projects (6) Toolbox (0) View All Activity Builder/Remodeler Trade: Builder/Remodeler Join Date: Jul 2007 Location: Indianapolis, Indiana Posts: 3,563	Re: New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This That's a good point to bring up. Heretofore, only Wisconsin has established it's own lead safe rules (all states have that option)--but other states are bound to add their own wrinkles. They can't make something less stringent that the EPA rule, but they can certainly make it stricter. Something to keep and eye out for over the next year. __________________ Christopher Wright, CR: President @ WrightWorks, LLC/President @ Central Indiana NARI, Named to the 2010 REMODELING Big50 www.WrightWorks.net - Facebook - Twitter - Carmel Remodeling Indianapolis Kitchen Remodeling Contractor - You Can Get There From Here

11-29-2009, 09:59 PM	#83
carolinahandyma View Profile carolinahandyma Remodel & Repair Send Message Follow Blogs (0) Threads (580) Photos (0) Reviews (0) Projects (0) Toolbox (0) View All Activity Remodel & Repair Trade: Remodel and Repair Services Join Date: Jan 2006 Location: Chapel Hill, NC Posts: 580	Re: New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This The instructor I had for the EPA certified renovator class also teaches lead abatement classes. He pointed out several of the differences between lead abatement (much stricter) vs. RRP. He stressed that the intent of RRP is conducting a safe renovation project (via containment, make as little dust as possible and clean-up). The intent of lead abatement is the safe reduction and/or removal of a lead paint hazard. They are similar but they have different purposes.

11-30-2009, 07:22 PM	#85
MEL View Profile MEL Pro Send Message Follow Blogs (0) Threads (576) Photos (0) Reviews (0) Projects (0) Toolbox (0) View All Activity Pro Trade: Roofing Join Date: Apr 2007 Location: Detroit Posts: 576	Re: New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This Does this thread really belong in the Marketing category? I find these “Sticky” things to be kind of annoying, especially this one doesn’t relate to marketing. __________________ MEL

11-30-2009, 08:34 PM	#88
BCConstruction View Profile BCConstruction Pro Send Message Follow Blogs (0) Threads (4,742) Photos (2) Reviews (1) Projects (0) Toolbox (1) View All Activity Pro Trade: Construction Join Date: Jun 2009 Location: VA Posts: 4,742	Re: New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This So if they are coming down so strict on this law then what are they going to do about the main cause of lead poisening in the US? Lead water mains, Lead solder joints, Brass Fittings and faucets and so on. These cause far many problems than some paint on a wall.

11-30-2009, 09:06 PM	#92
rselectric1 View Profile rselectric1 Pro Send Message Follow Blogs (0) Threads (7,019) Photos (0) Reviews (31) Projects (0) Toolbox (30) View All Activity Pro Trade: Licensed Electrical Contractor and Remodeler Join Date: Sep 2009 Location: Chicago Suburbs Posts: 7,019	Re: New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This Back to the subject at hand though. I talked to my plumber and hardwood guys today with the same blank stares. I e-mailed them both the link Chr Wright provided. My plumber contractor is licensed and union and even he has heard nothing about this. I have a feeling the S*** might hit the fan in April. If the "reward" system is in place like they did with freon with the EPA a while ago, I'll bet we will see a crapload of people trolling older neighborhoods looking for dumpsters and will make a living just turning people in. It will be interesting. __________________ 220...221...whatever it takes!

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New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This

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11-30-2009, 09:47 PM	#93
tommytwo View Profile tommytwo Pro Send Message Follow Blogs (0) Threads (119) Photos (0) Reviews (0) Projects (0) Toolbox (0) View All Activity Pro Trade: Remodeling and Home Performance Join Date: Mar 2009 Location: MN Posts: 119	Re: New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This I think that the exterior exclusion is going to be 20 square feet per project, not per side. From the "Model Renovator Training Course:" Summary of Updates/Corrections November 6, 2009. Module 2, Page 2-3, in the student notes. The exterior exclusion for minor repair and maintenance activities was incorrectly stated as 20 square feet per side. Removed "per side," the exclusion for exteriors applies per project, not per side. At the bottom of the page here:http://www.epa.gov/lead/pubs/epahudrrmodel.htm#manuals

12-01-2009, 08:42 PM	#96
dadarnall View Profile dadarnall Registered User Send Message Follow Blogs (0) Threads (4) Photos (0) Reviews (0) Projects (0) Toolbox (0) View All Activity Registered User Trade: Exterior Remodeling / Framing Join Date: Dec 2009 Location: Columbus, IN Posts: 4	Re: New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This Absolutely amazing!! Another environmentalist whacko idea to save us from all the things that are going to kill us.

12-01-2009, 08:51 PM	#97
BCConstruction View Profile BCConstruction Pro Send Message Follow Blogs (0) Threads (4,742) Photos (2) Reviews (1) Projects (0) Toolbox (1) View All Activity Pro Trade: Construction Join Date: Jun 2009 Location: VA Posts: 4,742	Re: New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This Wait until the hazmat rule come in affect. We will all have to be fully kitted out in hazmat suits before we can enter a site.

12-01-2009, 09:06 PM	#98
charimon View Profile charimon Pro Send Message Follow Blogs (0) Threads (433) Photos (5) Reviews (1) Projects (0) Toolbox (2) View All Activity Pro Trade: Tile, and tool junkie Join Date: Nov 2008 Location: Omaha NE Posts: 433	Re: New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This LOL What i really like is the little Dremel add with the multimaster clone Dry sanding lead based paint "alligator skin" cracking is a "defining" characteristic of degraded lead based paint. Craig

12-02-2009, 06:49 PM	#100
silvertree View Profile silvertree Certified Remodeler Send Message Follow Blogs (0) Threads (3,207) Photos (0) Reviews (0) Projects (0) Toolbox (0) View All Activity Certified Remodeler Trade: Kitchen bath remodeler Join Date: Jul 2007 Location: North Oaks,MN Posts: 3,207	Re: New EPA RRP Rule Takes Effect April 2010--ALL Trades Need To Understand This Chris, I am connected to NARI and NAHB people, both groups are clueless to anything but the minimum requirements. My insurance which is a dedicated contractor insurance company has not heard about the lead ruling. It just gets worse when you talk to the city of Mpls inspectors, they don't know what I'm talking about. Welcome to the new way of doing things, they will have fines and procedures for licensed contractors but nothing for enforcement on non licensed contractors. __________________ Vote for Pedro Kitchen, bath, St Paul remodeling Minneapolis Remodel Blog 203K Loan Consultant Minnesota

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