RRP And The EPA Must Be Stopped

hiteams

Mike,

As Greg Di said, "real late" to this.

Ton of organizations fighting against this. Ton of organizations trying to ask for delays. Even some of the guys on Contractor Talk have been organizing and fighting. Some even trying to get congress to help (although with their phones being flooded with Health Care ... don't think they are too interested )

A lot of the stuff you have mentioned, has been repeated over and over.

I wish you luck, but maybe the best advice is for you to help those guys/organizations that have been fighting for awhile.

On another note: I've done several RRPs. All bathroom remodels. Can't say they were fun, but not worth making a mountain out of a mole hill.

My 2 cents

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Dean

Dave R

My wife tells me that I am a mean spirited and vindictive type of person. That being said, I would like to see a list posted of all the Sierra Club members. If all licensed contractors nation wide had this list and would boycott doing any kind of work for these people, then they would not be able to have any type of construction work done on their homes. Just a little pay-back.

Ok, I'm through venting,,,, back to the beer.

Mike Finley

If it's a HUD home it's 2 sq ft.

You must also contact the homeowner's mortgage company to determine if his mortgage falls under FHA making it a HUD home.

How's that sound?

Also if you are working on a job site for a GC and the house is still in the containment phase - (meaning you're doing rough in work) you must be certified and you must operate under the same guidelines. Tyvek, gloves, booties, mask, trashbags, goosenecked, take off suit when you leave the containment area, hepa vac all your work clothing... go out to the truck get that wire nut you forgot, go back put all your work clothing back on go back into the containment area put the wire nut on... oh damit I needed that switch cover... hepa vac yourself, remove all work clothing go out the containment door to your truck come back put on all your work clothing...

rselectric1

Six square feet adds up pretty quickly. Even enough remodel can cutouts and you pass the limit.

As Mike Finley said, HUD is only 2 square feet. (maybe 4 can light holes?)

As a courtesy to the person who comes in after me to repair the walls on a service call, I usually make a nice neat cut down the center of the studs and if possible, cut out and re-install the drywall with a cut out so all they have to do is tape.

Not anymore (at least on target housing)

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SLSTech

Don't forget the few other small words that come after the size limits "or demolition"

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Tom M

What if your doing the procedure to a "T" on a small kitchen, a neighbor is also doing work--- an add-a level. Since its a beautiful day the client opens the windows so even though your golden the client gets lead dust from the demolition next door because of a breeze.

rselectric1

Supposedly, the lead dust is heavier and will drop within about 6 feet. Add some wind and about 10 feet of elevation and who the heck knows.

There are so many parts of this rule that don't take reality into consideration, that I think that the procedures will mostly be attempted for awhile by some, and then slowly be ignored---until someone local gets busted, then the pendulum will swing the other way temporarily.

I'm certainly going to try to comply, but for god sake, I can't even walk away from my jobs for a few hours without something going awry.

Ever try to explain to drywaller contractors that the curtains you hung are to keep dust contained, and to por-favor close the zipper after you walk through?
Si, no prolem boos, and still it continues until you have to get ugly. Only then does it start to work.

We are going to have to start babysitting even our best subs big-time.

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Mike Finley

What is the question?

angus242

What about all the renovations that have been done since lead paint has been used until now?

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Angus
L+M+O+P=C
"Promise only what you can deliver. Then deliver more than you promise"

FStephenMasek

That is a good reason to pre-test for lead dust.
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rselectric1

In Illinois, as soon as lead is detected CR's have to hand off the job to an abatement company. My instructor said only to test for lead if requested by the HO. He said don't test, and just use the procedures.

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angus242

That has nothing to do with say the millions of renovations that happened in 1990-1999.

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Angus
L+M+O+P=C
"Promise only what you can deliver. Then deliver more than you promise"

oldfrt

This is where I get confused.
Isn't part of the RRP to do the dust samplings after we finish our clean up?
So,if we find a trace of lead after a sloppy clean up,we weren't suppose to do the job?
I've also heard locally that its a separate class for being certified to read the sampling.

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Greg Di

Here's what I think is going to happen starting in mid-May:

HO will call up the usual three contractors to get pricing for their project. Two contractors come in aware of RRP. The first is certified, but he is so worried about compliance that he's not even willing to submit a bid. The second guy is not certified, but knows about the RRP standard and is waiting to get into a class. He can't do the work because he's not certified. The third contractor walks in, has no clue about RRP, gives a price and does a job for a homeowner that would have definitely taken the opt-out had he been able to.

See where this is going?

95% of the general public will not give two craps about RRP compliance. They don't care about it now and they sure as hell aren't going to embrace it now that the government is ramrodding it down there throats.

This is going to create a whole new underground construction trade. You just watch.

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Mike Finley

There is no requirements to test for lead at any time, before, during or after.

The only 'testing' at the end is a cleanliness test for dust based on a very specific cleaning process to remove all dust from the work area. The test is a visual test for dust, not lead in the dust. The object is to have not dust and therefore there would be no lead.

The entire RRP is based on an assumption that lead is present unless tests
prove otherwise. But lead testing is not required in any part of it. In our class we were certified to test for lead using the only EPA approved test kit that exists currently.

rselectric1

Dust sampling yes, but not lead testing. They are two different things.
(This is the way I understand it) You have to do the swiffer mop thing until the pad is the same color or less dirty than the EPA card when cleaning up. But that's just "dust".

Testing for lead is different. You need the test kit for that and it is done prior to starting the job (or not if you are in Illinois)

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Mike Finley

That's very different then what we were told.

We were instructed that the RRP's purpose is only to protect the workers working in a lead contaminated home and the residents during the time the work is being done in their home.

In other words it is only a method of working within a lead contaminated environment, whether it is contaminated or not.

Abatement can't be done by a RRP certified contractor and abatement is not required at any time. A clear distinction was made that no abatement can be undertaken, if you are there to remove or encapsoluate lead you are in violation of EPA requirements.

We were also told the same thing that testing can only be undertaken if the homeowner requests it.

rselectric1

I think we were basically instructed the same. The exception though is the Illinois angle. This is that if we test positive for lead, CR's cannot do the job. We have to call in an abatement contractor, or walk.

His advice was not to test, and just treat EVERY target housing project as if it was contaminated.

I'm sure it's a legal thing like absence of actual notice or something like that.

In other words, we were told WE DONT WANT TO KNOW if there is lead there. Just assume it is and use lead safe practices.

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oldfrt

I think Mike was suffering a little Post Traumatic Class Syndrome.
I've heard many come out of the training with a negative attitude towards this once they realize the organization ,costs,and paperwork needed to comply 100%.
Most electricians,plumbers,and sheet rockers,painters are more in the dark about this than we are.
It seems to have become our responsibility to actually inform them.

The Sierra Club is also responsible for lowering the lead reading and doing away with the opt out clause.
They have other plans for the near future;
http://www.sierraclub.org/communitie.../default.aspx#

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oldfrt

This may be what the Sierra Club is referring to when they say next year they will address short comings in the current RRP rules.
I'll bet they will make it mandatory to test for lead.
Read this statement on their site:

Currently the rule allows renovators to check their own work by merely running a wet cloth over the work area to look for dust. This scientifically unproven technique is likely to fail to identify invisible but still dangerous lead hazards. Less than one-tenth of one gram of lead dust is enough to contaminate a 2,000 square foot home and poison a child. In some cases, EPA will propose requiring that the renovator do more than testing and ensure that lead hazards are not left behind. EPA will finalize the clearance and testing rulemaking before July 15, 2011.

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