April 2010 Lead Safe Practices

Aframe

Harvey Ind. is hosting classes (check your location) $300, I don't know if I will take that or see if other trainers offer group rates.

Taking the steps to ensure a clean work site is a good thing, but some of this sounds a bit extreme.

I have not read through the literature yet , but one thing I will be looking for is:

In my area the average house age is pushing 100+ years, so we know they have lead. What testing would be required in a case like that?
Prior to starting any work to get a base #, and after to see if you've made it worse?

I can also see this as a benefit to the contractor is some cases where it can be established that a lead issue was present before work was done, that way blame can't be placed on a contractor for a preexisting condition.

oldfrt

Good to see Harvey taking a proactive stance.I'm going to look into this.

Such a drag that window replacement is included in the abatement process for a few reasons:

1)It's the dust that causes the hazard(being airborne),and there is only chips created which can be easily swept up.
Replacing the windows would eleviate any dust that may be created by just operating old DH windows.
How many kids do you see licking window sills?Duh!
2)Most of the people that are taking advantage of the energy tax credit are installing new windows.
A lot of these retrofits are for the older homes(pre 1978)
Now that market could be crushed by the new abatement rules.
3) HO's will look for less expensive ways to get the work done,hiring those that will do it without following the abatement laws.
Now that market could be crushed by the new abatement rules.
4)Insurance rates will probably rise because of the liability of dealing with lead abatement.
Probably a whole new rating system will be initiated.

We can take the tests,get approved,and only hope that there is some kind of enforcement involved to save this segment of the market.

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W-Tinc

Yup, was reading the work requirement flow charts the other day, going to be rough.

One thing about replacement windows is we are generally in every room of the house for a very short time, I'm thinking this will easily double the time it takes to complete a job.

I talked to a couple different pm's from companies we sub for, neither had any clue about this or any upcoming changes to the way they do things.

Tell you what I am not going to be playing russian roulette with this thing, we will only work in homes built post 78 or opt out qualified unless we can get paid for all the extra time involved following the new laws.

abacab

I think windows will need to be done from the outside from now on. Put a piece of plastic over the inside, and then vacuum the sill when you are done. What bothers me is the testing. It appears to me that this will add another $900 per job, no matter how small (assuming more than 6 sq ft disturbed).

JonM

Don't put that check book away just yet...


Once you get your RRP completed course certificate, you have to submit this application for certification to the EPA...$300.00


http://www.epa.gov/lead/pubs/firmapp.pdf

angus242

Wow, I'm feeling used already.

Maybe I need to become a federally recognized tribal firm. Their fee is only $20

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JumboJack

How?




















....

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in texas with framing and cornish people will do it for 3.00 a foot. What do yall think about that? Just laber

kevjob

just signed up for my class in october. 200 for individual then 300 for firm certification both last 5 years.

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bconley

I will using the new law to sell our services by being a company that cares about the health and safety of my customers and differentiating ourselves from the the other who don't care and don't follow the rules and regulations. If the homeowner doesn't like the added costs they can go elsewhere.
I see a big problem with disclosure when anyone goes to sell a pre 1978 house that has had any kind of work done to it.

abacab

bconley stole my post. While I'm going to follow the regulations I'm not going to get the mandatory testing done until the law takes effect (unless if a homeowner wants it). I'm also leary of paying for a class and certification when the law could be struck down at any moment, most likely the day it is to take effect. I remember they did this with the automobile industry with mandatory testing in Michigan (maybe elsewhere?) Garages payed tens of thousands for the equipment to test vehicles and the day it was to take effect it was struck down.

RCPainting

I did a bid recently on an interior/exterior of a pre 1978 home that had just been purchased. Part of the sale included a lead test report. i don't think it was required by law, or will be, but I believe the rules for disclosure and providing the pamphlet still apply to sellers/realtors.

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bconley

Theoretically if a potential buyer asked if any remodeling, painting etc. had been done and if the lead rules had been followed the seller would have to disclose that by law.
If the rules were not adhered to, the buyer could ask for concessions or worse a law suit if any known issues were not disclosed.
The lead paint testing is just to see if there is lead paint present.
My understanding is that if it is encapsulated with another coat of paint it is OK, it is the disturbing during prep or demo that is the problem, much like asbestos.

Mike Finley

Why would there be an issue to a new buyer if remodeling had been done years earlier and whether these rules were followed or not?

It's all about the dust being released into the air at the time of remodeling isn't it? It isn't like you are releasing radioactive matter that will contaminate the house right?

bconley

I understand that it shouldn't be a concern, but when did common sense ever matter when the lawyers get involved?
If there is something in the laws that can be leveraged it will.

carolinahandyma

The actual EPA rules of this program are likely to get tougher going forward as the Sierra Club and other organizations have taken legal action against the EPA.

From the Sierra Club website--Improving the Lead Renovation, Repair and Painting Rule (RRP)

In an effort to protect more children from the threat of lead poisoning in their homes, the Sierra Club settled a legal challenge brought last year against the Environmental Protection Agency (EPA) with a commitment by the agency to fix flaws in its recent lead in renovation rule that could have jeopardized children's health. The result of this work is that the US EPA will address several shortcomings prior to the rule's effective date of April 22, 2010, add additional safeguards by July 2011, and expand the scope of the rule to public and commercial buildings over the next six years. A great success for kids' health nationwide. See more at http://www.sierraclub.org/communities/lead/default.aspx






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cokeorpepsi

I have taken a class and passed the tests to be a LBP abatement supervisor. I still have to take the EPA class and pass that test.

I have talked to lots of people about this stuff, and there is so much confusion, I don't think anyone really knows all the specifics. It seems the biggest part of this is to use best work practices. They are not requiring LBP tests to be performed on a renovation. The only time it is required is if you are to perform a lead base paint abatement -- In my area of the country there is lots of government money being thrown around to clean up older homes in the community. To get these jobs, you must have all the certifications, and they will send someone out to the job site during the process and they will perform a dust wipe test to see if the property passes.

As someone stated earlier, the biggest problem is on the demo phase of a renovation project. You must use lots of plastic. You must tape all supply and returns. You must use use a water sprayer to contain the dust. There are certain things you cannot do, such as dry scrape and sand. Respirators and tyvek suits need to be worn. You must educate your people about the dangers of LBP. There cannot be eating, drinking, or smoking in areas where LBP is disturbed. You must make the homeowners aware by giving them a brochure from the EPA. I had one instructor say you cannot pressure wash a house unless you can contain all of the water runoff as it will be contaminated.

Putting a coat of paint over LBP is not abatement. skim coating with mud is not abatement. putting wallpaper over it is not abatement. It must either be completely removed or it must be covered with something substantial -- like sheetrock. The definition is something like a permanent cover which will last a minimum of 25 yrs (i took the class several months ago and don't remember the exact definition).

If you take no precautions and get caught they are going to fine you severely. If you are using best work practices and are making a real attempt to do things correctly, you should be fine. You must have the EPA certification and others working on the project should have it as well. Any house built prior to 1978 is assumed to have LBP. Unless you get the house tested to prove otherwise, the house is hot and you must work accordingly.

This is going to be a huge headache. It is going to increase the cost of all jobs. The extra materials isn't really the issue, it is the time to do things the correct way which will cost money.

JMAZMA

Where is the file???

jackson27

I can not access the file either. Can someone repost it or point to a new location?

I have taken the class but I want to make sure this is the same 1" stack of papers that I received.