RRP job done by John Clark, read this folks.

[Silvertree]

Washashore an RC.com member did a test run on the RRP compliance.

By John Clark

This week, I completed my RRP Training on Tuesday. On Wednesday, I jumped into a remodel of a small bathroom in a ranch house that was actually a perfect test case of trying to comply with the RRP Rules. The house is occupied only in the summer. This allowed me to create a larger dust containment area by creating a plastic tunnel from the middle of the house to the exterior.

Prior to starting the complete demolition of the 6x8 bathroom, I went looking for coveralls or suits as required by the EPA. None of the lumberyards had any that would meet the requirements. I then went to a local Sherwin Williams and all they had, was coveralls with a hood, but none with feet covers built in. The ones that they had, cost $8.95 each. As an aside, I asked the Manager if he know about the RRP Rule. I got a blank look. I then explained what the rule would bring about. His response- "It's just another government scheme to get more money in fees from the trades"

Back to the job, after spending about an 2.5 hrs prepping and sealing this is what happened:

The suit lasted about an hour before it started to rip.
Putting tile into trash bags requires double bagging and many bags.
The same goes for drywall.
The suits hold in quite a bit of heat and restrict range of motion.
Door with slit and flaps kept falling down, I came up with a better way to fasten the top and sides of the barrier by cleating strapping onto the door trim.
This method will add cost, as the painter will have to repaint the trim.
Passing bags loaded with tile and drywall through a slit by myself is very slow and cumbersome. Some goes for larger pieces of lumber.

In training, the instructors said that anytime you leave the containment area you needed to perform a dry decontamination- I stopped doing this after repeated trips to my tool trailer and the dumpster- It go to a point where I was not sure if I was de-conned anymore.

I had forgotten to pull the toilet and sink before setting up the plastic barrier at the door and the cast iron tub? I had to move it to another area within the containment barrier, complete my demo and clean the entire job up before taking the plastic door down. Then the tub was removed for disposal.

Some Conclusions:
Expect to go through many coveralls if you want to avoid contamination of your clothing. The same goes for dust masks, I took mine off several times and set it down without thinking.

Demolition time will double or even triple especially in hot weather.

Bagging debris will be cumbersome and you will have to make many many trips to the dumpster.

The demolition phase will be the worse, but once your cleaned and verified then the job can proceed normally.

There is no question that it will be a challenge and costly to follow the EPA requirements for the new law. Yet, trying to get this law weakened will be an uphill battle. Personally, I am advocating that the law be changed to compel property owners to take more responsibility in ensuring that they comply with the law and hire only companies that are certified.

I just came home to open the front page of my local newspaper to find that our local town Selectmen approved a Stretch Energy Code, which from what I understand, takes the part of the MA building code that deals with energy efficiency and puts the requirements on major steroids. A local builder was quoted as saying that the new requirements could add between $10,000-$20,000 to the cost of a new home. Remodelers will also need to comply with the requirements. I am going to be calling the building inspector on Monday to find out what requirements impact remodeling.

So let's sum it up-

In the midst of a major economic slowdown, a major industry is expected to absorb the costs of meeting a federal mandate, accept the whims of local officials who want to be politically correct and then sit back while Congress decides to make growing beyond four employees impossible.

[nEighter]

wow.:thumbsdown:

[neolitic]

I think this guy was mixing in
HUD and lead remediation rules
with the EPA stuff.
I will admit to some confusion
on my part,:rolleyes3: but my take away
is a tad less complicated than what
he's up to there.
This just points up more of the sloppy
roll out, as his instructors might well
have been using stricter guide lines
than what is in the actual rule.

[Silvertree]

He is pretty close to what I was taught at my class. Plus Massachusetts runs their own show.

No, he did exactly (actually less) what his instructor told him to do. I know John and talked to him this morning and he said it cost him about $700 more and that didn't include taking photos, doing the paperwork and a couple of other things.
All told it was about 4% upcharge and he did not follow the rule exactly, close for testing purposes but he did leave out a few things. We thought if he followed exactly it would have been 6 or 7% added to costs.

I think most people that took the class got Johns understanding of the procedures.

[SLS-Construction]

Neo, your right - Body suits are not required, bagging the tile is not required, setting up a tunnel is not required

The bagging or wrapping of any lead paint products is required & even without wearing the suit your times will increase due to the heat being confined in the room(s). Then you have the time for pulling nails or screws so they don't tear the bags. I am curious how many times he fell when he did the wet sweeping work at the end... Come on John - we won't laugh to hard or did you cheat and use that other product?

[Eieio]

I think this guy was mixing in
HUD and lead remediation rules
with the EPA stuff.
I will admit to some confusion
on my part,:rolleyes3: but my take away
is a tad less complicated than what
he's up to there.
This just points up more of the sloppy
roll out, as his instructors might well
have been using stricter guide lines
than what is in the actual rule.


What John explains is exactly what we will have to do on our 203K and Hud renovations..

What he described is exactly what we have either experienced or expected to happen based on past work performed on the HUD jobs...

My guys have experienced the same problems with the suits and booties tearing very easily, the Wood slats and plaster is very unforgiving and tear through the suits like a knife going through hot butter..

You will forget things and when that happens its a nightmare to start over, re set up or clean the area.


The rule will add 10-15% of the project cost.. On this particular project we are looking at 20-30K in additional fees to meet the requirements..

Those additional fees will probably kill the project unless the homeowners find an additional source of funding..

[Silvertree]

Bagging is required, that's according to the class I took.
Body suits were considered mandatory, thus you did not become a moving lead problem to protect after you left the job.

The tunnel was not mentioned at my class.

Did we take different courses?

[Eieio]

Bagging is required, that's according to the class I took.
Body suits were considered mandatory, thus you did not become a moving lead problem to protect after you left the job.

The tunnel was not mentioned at my class.

Did we take different courses?


He created the tunnel probably like we do so that the other areas are not affective..

So if you are doing a bathroom and kitchen at the back of the house. You seal off all the rooms leading to the front door where the dumpster is located.. Which for me is often, there is no room for the dumpsters at the rear of most DC row houses

Also the the HUD guidelines rule is stricter than the EPA RRP rule

[Allrounder]

Bagging is required, that's according to the class I took.
Body suits were considered mandatory, thus you did not become a moving lead problem to protect after you left the job.

The tunnel was not mentioned at my class.

Did we take different courses?

I was with you, I don't remember the tunnel. It does make some sense though, as the possibility of dust coming off of you as you move through the home would be there.

[SLS-Construction]

Rory - I think you switched that, HUD is actually stricter than the EPA

Ok guys, I can post the whole RRP, but why - you still will not find one place that says its mandatory to wear them - its not there (no we all took an EPA approved class - it's just the additional crap the trainers through out, that is an issue) Sure we all had to put the dumb suits on in class, but it's not mandatory that we wear them. It starts becoming necessary when you are kicking up enough dust to trip the OSHA standards.

Tunnels - be careful - 745.85
(2) Containing the work area . Before beginning the renovation, the firm must isolate the work area so that no dust or debris leaves the work area while the renovation is being performed. In addition, the firm must maintain the integrity of the containment by ensuring that any plastic or other impermeable materials are not torn or displaced, and taking any other steps necessary to ensure that no dust or debris leaves the work area while the renovation is being performed. The firm must also ensure that containment is installed in such a manner that it does not interfere with occupant and worker egress in an emergency.

[Bodger]

What John explains is exactly what we will have to do on our 203K and Hud renovations..

What he described is exactly what we have either experienced or expected to happen based on past work performed on the HUD jobs...

My guys have experience the same problems with the suits and booties tearing very easily, the Wood slats and plaster is very unforgiving and tear through the suits like a knife going through hot butter..

You will forget things and when that happens its a nightmare to start over, re set up or clean the area.


The rule will add 10-15% of the project cost.. On this particular project we are looking at 20-30K in additional fees to meet the requirements..

Those additional fees will probably kill the project unless the homeowners find an additional source of funding..


So $30K is added. That is going to go over like a fart in church with HOs who are already looking for ways to cut costs as most of them are.

I KNOW what is going to happen here. The HOs aren't going to want to hear this, and they will go with contractors that don't even mention it. Opening up a whole new underground. Yes, some of them will get busted, but most will not, and guys who are trying to work completely legally and within guidelines are going to get butt-stabbed.

Sorry to be negative, but I know at some point I will lose a remodel and $40K in profit over this. Probably many times over.

This is it in a nutshell:


So let's sum it up-

In the midst of a major economic slowdown, a major industry is expected to absorb the costs of meeting a federal mandate, accept the whims of local officials who want to be politically correct and then sit back while Congress decides to make growing beyond four employees impossible.
__________________

[Washashore]

Allow me to jump in here.

Just about everything I did, was taught at the Certification Class and my understanding was that it was required.

The tunnel that I created, was simply 2 parallel walls of plastic floor to ceiling, that I set up from the hallway outside the bathroom, to the exterior. It allowed me to have a smaller containment zone and in addition, it allowed a small staging area outside the workspace. The tunnel is not required, rather it is just working smarter.
As an aside, if the homeowners had lived in the home, I would have had to restrict my containment zone to the bathroom and placed the plastic door at the bathroom opening. This would have made a difficult job much, much harder.

I am going to check the law/rule when I get to my office, but I'm sure bagging or encapsulating debris is required, as the EPA does not want lead contaminated dust blowing out of the back of a dumpster or truck while it is been taken for disposal.

The body suit is something I am going to wear even if it is not required. I have an 8 year old at home and knowing what I know now about lead dust, it is the right decision on my part to wear one to minimize any exposure.

Hopefully in time, Someone will develop a body suit that allows heat to escape and provides more range of motion while been cost effective. (They may be such a thing, I just have not found it yet.)

If I was a larger company, I would provide my employees with special demo only clothing to wear, that could be cleaned in a designated washing machine. But then, the water would need to be treated and I would have to have multiple changes of clothes.

Round and round we go!

SLS-According to the rule as written in the Federal Register, plastic or any impermeable barrier must be laid on the floor. The product I use, PolyKraft* paper is considered impermeable so in my book, it met the criteria. and yes, I used it.

*PolyKraft is kraft paper, a layer of polyethylene and a layer of fibeglass mesh.

I think that more clarity could have been provided at the training about what was mandatory and what was optional.

[Eieio]

Sean your right.. Here is some info from the hud site...


The Renovation, Repair and Painting Rule

What's New -

The RRP Course

This course was developed by the U.S. EPA, in collaboration with the U.S. Department of Housing and Urban Development (HUD) to train renovation, repair, and painting contractors how to work safely in housing with lead-based paint and comply with EPA's Renovation, Repair, and Painting (RRP) Rule, and HUD's Lead Safe Housing Rule. Below are links for the initial renovator model training course materials. This course should be used for individuals needing EPA certification as renovators. Visit EPA's "Model Renovator Training Course" website for course materials.


Additional Information is available on EPA's RRP Website for States and Tribes | Property Owners of Rental Housing, Child-Occupied Facilities | Homeowners Working at Home | Tenants and Families of Children Under Age 6 in Child Care Facilities and Schools | Contractors Fee Rule Information for Training Providers | Lead Test Kit Vendors Related Notices, Final and Proposed Rules | EPA's Lead Renovation, Repair and Painting Program Rule

Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children.

On April 22, 2008, EPA issued a rule requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning. Under the rule, beginning in April 2010, contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination. Until that time, HUD and EPA recommend that anyone performing renovation, repair, and painting projects that disturb lead-based paint in pre-1978 homes, child care facilities and schools follow lead-safe work practices.

There are some differences between the EPA RRP Rule and the HUD Lead Safe Housing Rule (LSHR). A major difference is that the LSHR requires clearance examinations. All housing receiving federal assistance must still comply with the LSHR. OHHLHC provides Information on complying with the LSHR and RRP, and Frequently-asked Questions from Grantees. Additional information for renovators is available.

All contractors should follow these three simple procedures:

* Contain the work area.
* Minimize dust.
* Clean up thoroughly.

From December 2008, the rule has required that contractors performing renovation, repair and painting projects that disturb lead-based paint provide to owners and occupants of child care facilities and to parents and guardians of children under age six that attend child care facilities built prior to 1978 the lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools (PDF) | en español (PDF)

Starting on April 22, 2010, the rule will affect paid renovators who work in pre-1978 housing and child-occupied facilities, including:

* Renovation contractors
* Maintenance workers in multi-family housing
* Painters and other specialty trades.

Under the rule, child-occupied facilities are defined as residential, public or commercial buildings where children under age six are present on a regular basis. The requirements apply to renovation, repair or painting activities. The rule does not apply to minor maintenance or repair activities where less than six square feet of lead-based paint is disturbed in a room or where less then 20 square feet of lead-based paint is disturbed on the exterior. Window replacement is not minor maintenance or repair.

Read EPA's Lead Renovation, Repair and Painting Program Rule.

Additional information on becoming an EPA-certified renovator or training provider is available on EPA's Renovator and Trainer Tool Box site.



Link: http://www.hud.gov/offices/lead/training/rrp/rrp.cfm

[Eieio]

So $30K is added. That is going to go over like a fart in church with HOs who are already looking for ways to cut costs as most of them are.

I KNOW what is going to happen here. The HOs aren't going to want to hear this, and they will go with contractors that don't even mention it. Opening up a whole new underground. Yes, some of them will get busted, but most will not, and guys who are trying to work completely legally and within guidelines are going to get butt-stabbed.

Sorry to be negative, but I know at some point I will lose a remodel and $40K in profit over this. Probably many times over.

This is it in a nutshell:


So let's sum it up-

In the midst of a major economic slowdown, a major industry is expected to absorb the costs of meeting a federal mandate, accept the whims of local officials who want to be politically correct and then sit back while Congress decides to make growing beyond four employees impossible.
__________________



THE homeowners, the bank, Realtor, the appraiser, not even THE HUD CONSULTANT, had ever heard of the EPA RRP rule before I mentioned it and thought I was crazy..

[Eieio]

There is a PDF on the Hud site with a step by step procedure manual for following the EPA RRP Rule..

http://www.hud.gov/offices/lead/library/lead/contractor_brochure.pdf

[Eieio]

Here is the difference in the EPA rule and huds requirements

http://www.hud.gov/offices/lead/enforcement/lshr_rrp_changes.cfm

[Silvertree]

But wait Johnny, there's more!

So I ask with the 203K loans is that a HUD job?

I would handle it as such, its more but not that much more work.

To date some of us know about the rule and we seem to be advertising it for the EPA, maybe that's part of the plan.

As we go forward we are recognizing this will punish compliant companies in the beginning. The question now is do we renovate right or learn to work around it? I'm not saying we should but how many jobs can you afford to lose to this rule.
Lots of questions, very few answers. We will know much more in a year, and how many will fail in that year?

[neolitic]

For now, I will continue to
pursue the oversight committee route.
One of my Senators (Bayh) is
a member of the Senate Small Business
and Entrepreneurship Committee.
I believe they might have more
than passing interest here, especially
with the recession...and the off-year
elections looming.
I'm having some trouble finding the link
that had some of the in house EPA discussion
leading up to the rule.
Anyone have it at their finger tips?

[SLS-Construction]

Neo - http://www.remodelcrazy.com/forum/showpost.php?p=36063 post 48, 49, 128 all have some good links by Chris - there are a quite a few more in between & after, but I think those are the one's your looking for

John - I fully agree with you - that product is allowable & it sure beats using plastic - I would love to watch an epa guy walk on the plastic in booties trying to wet sweep - if they don't fall on their a$$ before the wet sweep, they sure will while doing it.

[Bodger]

But wait Johnny, there's more!

So I ask with the 203K loans is that a HUD job?

I would handle it as such, its more but not that much more work.

To date some of us know about the rule and we seem to be advertising it for the EPA, maybe that's part of the plan.

As we go forward we are recognizing this will punish compliant companies in the beginning. The question now is do we renovate right or learn to work around it? I'm not saying we should but how many jobs can you afford to lose to this rule.
Lots of questions, very few answers. We will know much more in a year, and how many will fail in that year?


I'm all for working around it if doing so does not legitimately endanger anyone. But I have a feeling that this is going to be enforced the same way the state of CA enforces their contractor licensing laws. By spot checking and making extreme examples of the violators they snare and then publicizing the lynchings.

If we were risking a $1500 fine or something like that, it could be considered a cost of doing business. But $32K fine and possible lawsuits starting at $150K and up, which aren't protected by GL insurance. That's a business buster and a life-breaker.

My guess is that what will rise to the top and be most prominent regarding this issue is the fact that enforcement and fines will be a moneymaker for some entity, be it Federal, State, or municipal.
We'll see more effort made by the government to enforce and collect instead of publicity for public awareness and safety. And these agencies will have a much greater knowledge of what is a violation and punishable offense than they will of what we must do to comply and be legal.

[kevjob]

[QUOTE=Silvertree;51450]So I ask with the 203K loans is that a HUD job?/QUOTE]

As far I as I know any federally funded housing program falls under HUD. I am tunneling on my job after the kitchen so I will let you know how long, how much etc..right now I am adding 5% onto my bids for EPA stuff.

[neolitic]

Neo - http://www.remodelcrazy.com/forum/showpost.php?p=36063 post 48, 49, 128 all have some good links by Chris - there are a quite a few more in between & after, but I think those are the one's your looking for ......

Thanks.
Your link is a single post (#49)
# 50 is relevant, but there is one
that was to notes on EPA's own discussions
....or the lead poisoning may be causing
hallucinations.
Or maybe it's the Purple Owsley.

[SLS-Construction]

Or maybe it's the Purple Owsley.
Busted :mad2:

http://www.remodelcrazy.com/forum/showthread.php?t=2035 try this link... post 128

[neolitic]

........http://www.remodelcrazy.com/forum/showthread.php?t=2035 try this link... post 128

I am strip mining there currently.....

[paulie]

White suits - cut the booties off, tape to the ankles. Buy the white suit a size bigger for mobility. During the summer it's way hot. Do not go commando, there see thru and will gross out your fellow workers.

Staging area for garbage bags - Plan how much refuse you will generate and build a room that size. Pile it in the room. Leave containment and grab it from the outside. If lots then have a worker hand it to you.