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RRP/Some Down to Earth Questions

4K views 21 replies 14 participants last post by  ApgarNJ 
#1 · (Edited)
OK, here are some down to earth questions on the new EPA/RRP Rules:

-How are we going to tell the year of the house? (Go to the Couthouse? Take the customers word for it?)

-Garden Sheds, etc? (How are we going to tell what year a Garden Shed was built? Most of them were built in a shop and delivered on a truck. Even on some smaller buildings, around here you don't need a permit for some of them. How are we going to tell what year those are?)

-Small Jobs? (Many of my jobs are small jobs. Some just 1 hour. Am I going to spend multi-hours of set-up and clean-up as well as the other expenses for a 1 hour job? And charge the customer multi-$100's for a $50 job?)

-Go Through it Twice? (Many times I will pull apart a job first in order to find out what materials and/or what measurements I will need, then order the materials. I will temporalily close-up a job, so the customer can use normally use the area, then when the materials are ready (some special made) I will simply open it back up. Would I need to go through the time-comsuming procedure twice? And the customer will pay for it twice? They are going to have a hard time understanding it once).

-Plasitc in Landfills? (There will be multi-1000's of tons of plastic, etc thrown away each year. We will be filling up our landfills with non-decomposable material. How about all the fossil fuels it will take to make all that plastic? Aren't we causing more problems trying to fix one?)

These are just some quick thoughts. I'm sure I'll have more. All answers are welcome.

Bill
 
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#2 ·
Bill, you're a bit late to the party. These questions and many more have been beat to death ad nauseum both here and in other venues. Take a couple of weeks and read all the other threads here. :laughing:

Yes, 100% compliance is absurd on the face of it, but the EPA doesn't have to be concerned with that. They've been charged with setting up rules to protect the population, and have done so.

In the real world, that doesn't mean we're all going to get arrested for every tiny infraction. The point is to have the rules in place so that (A) we all do a better job than we have been, and (B) it enables them to throw the book at really egregious violators.

There's probably not a single driver on the road who hasn't exceeded the speed limit at least a few times. Imagine the mess if every single one of us got nailed every single time that happened.

Just don't go over the limit by 100% or more, and chances are you'll be just fine. Or you could just quit driving...
 
#3 ·
Yeah, I know I'm late and believe me I have looked back. There is so much to read that it's a little over-whelming. I've spent many hours since I recently came back to these forums. The reason I was away for a while? Dial-up. These forums were just not Dial-up friendly. They recently offered us Hi-Speed in this rural area and what a difference.

Appreciate the common sense info.

...I know what you are telling me.

Bill
 
#4 ·
#5 ·
I think everyone agrees, at least those of us in the trades that actually have a clue, that complete compliance is unrealistic and pretty much impossible.

Follow the rules with your best effort and go about your business.

I have been on a bunch of RRP jobs and done a few my self. It really is not that big a deal.

Now if you are the type of contractor that works like a slob this may be overwhelming. But if you already work neatly RRP will just be an expansion on that.
 
#6 ·
OK, here are some down to earth questions on the new EPA/RRP Rules:

-How are we going to tell the year of the house? (Go to the Couthouse? Take the customers word for it?) Ask Homeowner ... go to www.zillow.com ... county records.

-Garden Sheds, etc? (How are we going to tell what year a Garden Shed was built? Most of them were built in a shop and delivered on a truck. Even on some smaller buildings, around here you don't need a permit for some of them. How are we going to tell what year those are?) If you want to play it safe ... assume it has lead based paint.

-Small Jobs? (Many of my jobs are small jobs. Some just 1 hour. Am I going to spend multi-hours of set-up and clean-up as well as the other expenses for a 1 hour job? And charge the customer multi-$100's for a $50 job?) On small jobs, it takes me 1 hour to get the paperwork ready, do RRP, do clean-up, do verification and fill in paperwork.

-Go Through it Twice? (Many times I will pull apart a job first in order to find out what materials and/or what measurements I will need, then order the materials. I will temporalily close-up a job, so the customer can use normally use the area, then when the materials are ready (some special made) I will simply open it back up. Would I need to go through the time-comsuming procedure twice? And the customer will pay for it twice? They are going to have a hard time understanding it once). Do all demo, clean-up and verification. When you come back ... no disturbing paint, so no need for RRP.

-Plasitc in Landfills? (There will be multi-1000's of tons of plastic, etc thrown away each year. We will be filling up our landfills with non-decomposable material. How about all the fossil fuels it will take to make all that plastic? Aren't we causing more problems trying to fix one?)

These are just some quick thoughts. I'm sure I'll have more. All answers are welcome.

Bill
Didn't offer an opinion on landfills, but others answered in bold above.
 
#7 ·
I think everyone agrees, at least those of us in the trades that actually have a clue, that complete compliance is unrealistic and pretty much impossible.
I

Until a job goes sour or customer wants to find a reason not to pay--then try to explain to a court system how unrealistic or impossible the rules are. The epa in all its wisdom to collect money and increase its (epa) workforce, hung us all out to dry. If epa was confident that lead dust (created by contractors) was the leading cause of eblls then why wasn't there a statement saying--"The contractor by following these rules contains the dust he created and cannot be held responsible for any other lead dust from the past, the present or future disturbances." But there is no such statement. The epa says the license fees and fines will be used to educate and enforce these rules. (by hiring more epa workers) So epa creates a law to protect the homeowner--uses the license fees and fines to hire more epa to enforce and educate, shouldn't the fines and license fees be put in a separate fund to help the people this law was created to protect??? So the epa profits from the non compliance of a law that they created (that is" unrealistic and pretty much impossible")) to protect the homeowner?? With all regulations comes liability and this is a big one. Lead dust may be dangerous. Driving to work can be dangerous--should we pass a law to drop the speed limit to 35mph to solve that problem? Lead dust is dangerous only when a contractor works with it?? Why isnt it being enforced on the HO? Why hasnt epa had a media campaign about this if it is such a problem?? I havent had one customer yet that knew anything about this law. Another law holding the responsible(majority) hostage for the sake of the irresponsible (minority).
Another Example

http://www.wkow.com/global/video/flash/popupplayer.asp?ClipID1=4997744&h1=Fast%20food%20zoning%3F&vt1=v&at1=undefined&d1=51034&LaunchPageAdTag=News&undefined&activePane=info&rnd=29286056
 
#11 ·
Im going to need a refresher courser by the time they get done changing all the little incidentals every month. If they want more compliance they should be making the renovate right brochures free hand outs at every home store. But instead they want your money, want you to be confused and want the opportunity to dip back in the money tree they just planted.
 
#12 ·
We just have to show that we are in compliance even if we don't do everything 100% that's in the book. Containing the dust and cleaning up is the key. The EPA just wants your 300 bucks every 5 years. that is what it comes down to. They aren't going to enforce this that much. Every painter I have seen in the last 5-6 months , outside or inside, non of them, not one single company is complying, still normal drop cloths, no plastic, no hepa nothing.
customers aren't caring much either.

i just landed a small RRP job near me, old historical house very close to others in a city type setting. We have to repair the soffits on the second floor, alleys on each side of the house, and a tin roof porch on the front, so we have to setup on that porch. it's impossible to cover that whole porch with plastic and still setup ladders/picks or scaffolding to do the job safely. and the alleys can only get 5' or less of plastic. so for a 1-2 day job, we'll do our best to contain the chips that fall. The misting of the plastic and all that other crap outside is a joke.

I can't believe the amount of plastic that will go in landfills and keep the contents from ever rotting. They better make 6 mil biodegradable plastic very soon!!!
 
#13 ·
I've been doing it pretty much like Apgar.

Plastic...lots of plastic.

I also go around and pick up (the very few) stray paint chips when I'm done.

I confess that putting up warning signs feels stupid, and I skip it sometimes. My last 2 RRP jobs, no ones been around anyhow.
Signs and yellow tape would only make the neighbors curious, and make them come over to see WTF I'm doing.
 
#16 ·
Scenario:

I'm working away prepping a house ext.
I've got my signs and yellow tape up...prompting the guy across the street to come over and have a closer look.

I tell him to go the f**k home...but he's already seen my "lead hazard" sign.

He waddles home and googles "lead hazard", and ends up on EPA's website.

Then he watches me through binoculars..and sees me (momentarily) use my disc sander unshrouded so I can reach a tough place.

He calls the EPA's toll free number, they come over and bust me.

Meanwhile, the painter 3 doors down is working w/o following ANY RRP guidelines. But for lack of any yellow tape/signs he's gone unnoticed.

After he sees the EPA guys take me away in handcuffs, he walks over to the house I just finished prepping, and gives the HO his card.
 
#17 ·
Level 1b All Renovations: Failure of firms to post signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area; to prepare, to the extent practicable, signs in the primary language of the occupants; and/or to post signs before beginning the renovation and make sure they remain in place and readable until the renovation and the post-renovation cleaning verification have been completed, 745.85 (1). $ 16,000 $ 8,500 $ 2,840
AND

Level 1a All Renovations: Failure of an individual to perform responsibilities for ensuring compliance with745.85 at all renovations to which they are assigned, 745.90(b) or (c) $ 37,500 $ 25,500 $ 7,500
As for the misting

Level 1a Cleaning the work area: Failure by the renovation firm to remove the protective sheeting by misting the sheeting before folding it, folding the dirty side inward, and/or either taping shut to seal or sealing it in heavy-duty bags, 745.85(a)(5)(i)(B) $ 37,500 $ 25,500 $ 7,500
 
#19 ·
Everytime I see someone post a quote from the book or regulations with the strict legal language and serious penalties I cringe....... Its like these guys are reading scriptures for which failure to comply makes you an arch criminal and sinner.

Another worthless regulation that will be largely ignored
 
#21 ·
I cringe every time I see SLStech post anything after me.

(he's mean, and he hates me)
:eek::laughing::shifty::whistling

Tom M - I simply post what the reg says so you know what there looking for. I hate this thing probably just as much as you do & believe it does more harm than good - I am all for fighting it, but at the same time you need to learn how to live with it.
 
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