1.20.10 Lead Webinar Revisited

[SLS-Construction]

First off - to everyone that attended, I wish to thanks

PLEASE NOTE - for those of you in Wisconsin, Iowa & North Carolina - please visit your states web site as they are now in control of this program.

For those that missed it or would like to see it again: http://www.remodelcrazy.com/2010/headline/get-the-lead-out-webinar.html (Sorry, I am the one that forgot to the record button so my Intro & about 30 seconds of Chris's are missing)

I managed to pull the Chat transcripts & will try to answer most of the questions listed here. For those being addressed in the next webinar I placed them in this thread. http://www.remodelcrazy.com/forum/showthread.php?t=3053

For a copy of the slides used the link is here: http://www.remodelcrazy.com/forum/downloads.php?do=file&id=80

Ok, I think I got them all listed & my mind is fried - if you asked another question & do not see it listed here it is probably slated for the next webinar (link below). If you have a question on the rules themselves, a clarification of what is below - feel free to post them here. If you have a question on liability, or something not specifically listed here - please post them here http://www.remodelcrazy.com/forum/showthread.php?t=3053

[SLS-Construction]

Does sending a link to the brochure meet the requirements?
Chris Wright answered: No, you have to give them the brochure and they have to sign off

Is there a place to mass order these brochures? Can we print brochures at the office or must you buy them
Chris Wright answered: NARI sells packs of the brochure... You can also print it from the EPA site

There are numerous vendors out there offering "RRP packages" of pre-printed forms, brochures, etc... which can be customized with your logo and number. You can also order limited supplies from the EPA

[SLS-Construction]

Kinda makes me think a little more of my own safety. Guessing my shop vac ain't gonna make it

No per the EPA, a HEPA Vac is required for final cleanup & to use sanders, etc.. A HEPA filter on your shop vac does not meet the requirements

As a quick side note - there is nothing on there site that says that they are certifying vacuum - all it has to do is meet there definition

Another side note - except for the two times listed there is nothing saying you can not use a shop vac as long as it is inside the containment area - however, you may run afoul of the "intent" of the rule

[SLS-Construction]

What about cabinet installation without any demo. Only wall disturbance will be screws to hold cabinets

Per my reading - you are fine as you are not disturbing the paint, In fact those that just apply paint over existing paint without any prep work are also ok

[SLS-Construction]

Update on change requiring providing tenants with compliance records? One of the proposed changes requires us providing Home Owners with copies of our compliance records.

I haven’t heard of this, but if it is the case, or a HO requeted it, I would just give them a copy of the Renovation Record Keeping Checklist which is one form required by the EPA

[SLS-Construction]

If we do the demo and do complete cleanup and test-then you can use subs that are not yet certified. Right?

This is not what the EPA sent me via email (see 3rd slide from the end), but others that have talked to the EPA said yes this is correct

As I answered above, cabinet installs and other tasks do not require certification either as they do not impact any painted surfaces - so I would assume that if all painted surfaces were demo'd one would be fine (assuming a full bath / kitchen / house remodel), but I rather see the EPA clarify that in writing with no disclaimers

[nEighter]

thanks button is non operative.. thanks Leo..

"thanks"..

[SLS-Construction]

Can you guys please expand on 3rd party testing? What is the turn around time for a 3rd party to get back with results?

Per the Sierra Club settlement, the EPA is supposed to consider requiring third party testing starting in April 2011 for the post cleanup. At this time it is not required by the EPA, only HUD.

As for how long will it take - this will depend on the Certified Inspector you hire

[SLS-Construction]

1. Can the demo debris that is contaminated be hauled to any landfill or is it considered haz mat like asbestos?

For Residential remodels, per the EPA it is listed as Household waste, that being said your state laws may vary.

2. What about big chunks of wood thats been removed from a house? Do they need to be bagged or can they go straight in the dumpster?

As I recall if they have paint on them - they would then need to be wrapped in plastic

[SLS-Construction]

Ok just a small smattering of the questions:
I'm both a CLR and CF and can train my employees. Can I also train my subs, or do they need to take an approved class? Does every firm have to be certified AND have their own certified renovator employees? If the PM is a certified renovator, why would the subs need to be certified? Do all subs have to be certified even if they do no demo at all? So, with multiple certified firm subs working in the same room (possibly each sub having their own clr) then which companies clr is held responsible? or does each sub/clr do their own test and record the results?
As mentioned above & discussed in the webinar - almost every company that will be working in pre 1978 houses & has the potential of disturbing paint needs to be a Certified Firm
Just because you as a GC may take care of all the demo (if allowed per the EPA) on your job sites, that might not help your plumber when they do a re-pipe, or you favorite siding company does work for somebody else. They need to be a Certified Firm
Does each sub or even the GC have to have a CLR? No - only 1 CLR is required to be on record per project. He is responsible for everyone on the site either being trained on Lead Safe Practices, or verifying that they have been trained as a CLR.
Who is responsible - the CLR on record & all Certified Firms when push comes to shove (in case of a lawsuit, who gets sued - just one person or everyone that might have money???)
As a GC / CF / CLR, I will provide each sub with proof that the HO was notified & a copy of the record keeping checklist --- all my subs will answer to me like normal, we just have to add a few more steps to cover everyones assets folks - that's all

[SLS-Construction]

1. So my painter who is coming in to paint all the new wallboard and trim has to be certified right?

2. I'm simply a painting company, but if I go in to work on a GC's remodel, then I'm assuming the risk of the other subs employees screwing something up?
New wallboard & trim - is it a painted surface? Nope (maybe - see above)
Surface Prep on existing - CF & CLR - yes if nothing is contained, no other CLR on record, or prior work has already been signed off on, etc...
2. - that's funny, we all knows it's the painters fault :laugh3: --- seriously catch the second webinar & use your best judgement - if you have to contain everything, posts warnings & signs etc... per the regs, no one is allowed entrance unless you have trained them
This issue will have to be worked out with each GC that you work for, and should be covered in your contract(s)

[SLS-Construction]

If the EPA does not plan to enforce...do they plan to support compliant remodelers by listing/promoting those who certify themselves...a gold standard of sorts?
Pfftt, originally they were going to have a database on-line of Certified Firms, the section mentioning it has disappeared off their site & when I was checking on my firm cert & asked about it – they stated we would have to call to see if someone was certified as there were no plans to put it online.
As of 2 days ago, they did mention on their site an online database of contractors that have heard their certs revoked

[SLS-Construction]

I thought I read that even if test came negative on pre 78 you still had to practice lead safe?

You read wrong

If you test & it comes back positive - you have to follow the procedures, if it comes back negative, your good to go

[SLS-Construction]

does our cleaning lady have to be certified after we finish a remodel? She's not very smart but cleans good :laugh3:

As long as you have passed your cleaning verification / closeout - she can clean away

[SLS-Construction]

What about testing of the soil after the power washing is done are we opening a can of worms?

Yes that would be opening a major case of worms (especially if your close to a highway major street - think leaded gas)

This is not required by the EPA, make sure you meet the cleanup requirements listed in class & your done.

FYI - soil remediation can either be scraping out the dirt & replacing with clean dirt (what an oxy moron) or planting grass, or applying another covering

[SLS-Construction]

I have no (even vague) numbers to go on from the past since this was never an issue...but what % of your projects fall into the pre 1978 category?

As for your market - that is anyones guess
JasonW who works on Historic homes is @ 100%, I am at about 25% in my area, after April my numbers might go up :2thumbsup:

Nationally per the EPA - 35% of the all the houses in the US contain lead
Built between 1960 - 1978: 25%
Built between 1940 - 1959: 66%
Built before 1940: 86%

[ChrWright]

A link to some Q&A from a training firm:

http://www.ieetrains.com/docs/MASS%20WEBSITE%20Construction.pdf