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

TGCatKTG

Right now, the whistle blowers are the trigger for the EPA.

Later, once all of this is settled, the EPA will be doing audits of our paperwork and all of our fines will stem from the audit, not the work itself. The only way this will work is if every contractor or subcontractor is certified and keeps the correct records. You not only have to keep records of lead homes, but you also keep records of testing and verification of no lead on the non-lead projects.

Tom R

As I keep saying, - - PARTICIPATING makes you a TARGET . . .

BCConstruction

That would be all well and good if the people who done the work unlicensed and non compliant with RRP rule kept records and were audited. We all know the only people this is going to affect is the legit contractor. Yeah we wont have any fines because we stick to the rules but we also wont have a hope in hell getting any work if we have to compete with hack prices.

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Home Serve

That is right Tom, folks....think about this. The more you play the game the more attention is given to YOU! Jump in with all your paperwork and stuff and guess what? The #hit starts here.

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Missouri Remodeling Company with services for Replacement Windows Vinyl Siding and Entry Doors

ApgarNJ

they aren't going to be able to contact every single township in every single state in this country to audit every licensed contractor. not all jobs require permits.
I just have to figure out where Im going to be putting all the records.
for non lead jobs, you dont have to show anything if it's post 78. if it's questionable, you get tests filled out the test sheet they gave us to make copies of and put in the file what your results were using the lead check swabs or XRF results if it's on drywall/plaster.
it's sometimes easier to just assume if the house is a certain age.

Tom R

Right, - - when these clowns come to audit you their JOB is to bring in money, - - THEY determine the RULES of SERVITUDE . . .

ApgarNJ

they can audit anyone!
all they need to do is get permits pulled on older homes from any township they choose and if you aren't licenses, then you are busted even worse.

so the only thiing we can do is comply and keep good records.
and pray.

Tom R

Correction, - - they can audit anyone who works on pre-'78 homes . . .

TimNJ

I don't like this as much as anybody else, but I'm not in a position to retire just yet. I will go through the motions if things are slow and I am looking for work. If things are busy i would be more inclined to pass on a pre '78 job. I looked at a guys place last week that wants all his interior doors replaced. I gave him the brochure, got his signature, and explained what was what. At the time the job was leaning to slab replacement, not pre-hung. He called and left a message he wanted to talk in more detail. If he wants to go the pre-hung route I will offer to test his trim to see if it is in fact lead or not. I haven't figured a hard number yet but probably ballpark of $150-$200 to test. Being these are bed/bath doors he could have one room that might have lead trim whereas maybe the hallway doesn't. That means I will use up about 8-9 Lead Checks @$4 each plus my time. They could all test clear in which case I'm clear and I will tell him he will save on added set up costs. I'll see what he says tomorrow.

ApgarNJ

well. that's what we are talking about. lol i thought you meant if we weren't certified and registered with epa, then we couldn't get audited.

Tom R

Hey, Tim, - - can't you just do the job before April 22nd (I'm under the impression that's the date in question, no??)


P.S. Were you looking for steel shelving?? (I can probably get you some for free). PM me if you wanted some.

Tom R

I'm starting to seriously think the ultimate plan here is possibly for the unions to be able to take over residential construction remodeling by fining the legitimate right out of the trade . . .

TGCatKTG

The way they "EPA" see it, they are allowed to audit anyone doing construction work.

We have the burden to prove through our paperwork that we do not work on pre 1978 homes. The only way to do that is keep the same records required for the rule.

If I'm going to do that, I might as well be certified and do the extra work also.

I give them credit this time, they covered every corner of the page when they set down to write this rule. Once you read through it, you will see what I mean. You can read it on line.

ApgarNJ

tim, you can get lead checks for 2 bucks a piece online. also, from what i have read, you don't have to hand out that renovate right brochure, 7 days or earlier before you actually start the job. not just to any job you look at.

ApgarNJ

I was told for any house after 78 we dont have to keep the same exact strict records as we would if it was a pre 78 house.

TimNJ

If I can get the guy to make the decision fast enough, though the date in it self is a motivating factor. It has worked to my benefit twice so far. He thinks (wife has final call) that they just want wood 6 panels. I can get them anywhere. Any other style I would have to order.

TGCatKTG

You will need records showing positive tests and negative tests. Along with these records will be something stating the home on whatever block in whatever city is a post 1978 building. The documentation will be the same for pre or post 1978 buildings the way the rule reads. The only change will be no testing required on post 1978 homes.

TimNJ

$2 bucks my cost. I'm in business, customer pays $4. I find that it is just as easy to hand out the brochure when I go to do the estimate and be done with it. It would also give the ho the info so if some flybynighter comes after me he "will have some 'splainin' to do"

TGCatKTG

This is a good thing as long as you are not giving the pamphlet out more than 60 days prior to startingthe project. They cover that also.

ApgarNJ

We don't have to TEST in a post 78 home, so there is no reason we have to have a record of testing. they are not the TARGET housing they are after. it says it right in the booklet.

gotta watch out how early you hand out that renovate right brochure, i think it has to be less then 7 days prior to start but not more than 60 days, dont quote, but that is how i remember it. i will only print out copies of the brochure for people im actually going to work for. when they sign the contract they get it.