Current EPA Authorization to States to self-manage RRP Rule

[SLS-Construction]

Current status of states applying to handle the RRP ruling

http://www.healthyhomestraining.org/RRP/State.htm

Got to love that you can not find this information on the EPA's site

Currently only Iowa, North Carolina & Wisconsin are authorized to self-manage

Many states including Alabama (I wonder if this is why I still don't have my CF yet?) are listed as pending - some will not go into effect until late 2010 / 2011 so they get nailed twice.

New Jersey & a few other states have a few items listed for additional regulations that apply to them

[Leo G]

Nothing on Connecticut.

[RCP]

Or Utah, but that seems typical!

[Leo G]

Maybe they will keep their collective noses out of it. But I find that unlikely. There is money to be taken out of contractors pockets.

[SLS-Construction]

Per the page: NCHH will track the state authorization and update the table below to help renovators and training providers. Please contact Tom Neltner at tneltner@nchh.org (tneltner@nchh.org) if you see problems, know of state activity, or have suggestions to improve the information.

These guys are in about the same boat as we are - it is hard to get information out of the EPA / States, but once they have a piece of information / source they can keep up with it.

As a reminder - not all states will do anything with the reg, but if they are it would definitely help those of us affected out if we knew about it.

[Leo G]

But the state couldn't collect untold fines if they were to tell people about it and spout out ignorance of the law is no excuse.

Same thing with the EPA. They made no reasonable effort to alert the contractors or public about this new ruling. They are leaving people in the dark on purpose. What this purpose is will soon be seen.

[ChrWright]

For any contractors is Oregon:

http://ccbed.ccb.state.or.us/WebPDF/CCB/Lead%20Based%20Paint/1-10_lic-req.pdf

This is a power point document outlining Oregon's requirements, which apparently take effect April 22. They will have their own certification process, fees, and a few minor variations in requirements.

[Blue]

Buildpinnacle. What are you hearing about Texas. I'm curious because I used to build in Austin.

[Dean CRCNA]

Buildpinnacle. What are you hearing about Texas. I'm curious because I used to build in Austin.

Texas is letting EPA handle everything on this.

[deckman]

Buildpinnacle. What are you hearing about Texas. I'm curious because I used to build in Austin.

No one here that I've talked to about this has even heard about this.

Not going to be a big deal for us deckbuilders here as 1/2 the homes here were built after '78. The few times I've worked on older homes I never had to disturb paint.

[Tommy]

At my class tomorrow, I'll see if they know anything about what the pending MN rule is going to be. Anybody have any other questions they want brought up?

[Silvertree]

Minnesota Dept of Health takes over the rule this summer.

They will regulate us by using audits, they will not enforce.
In other words, cover your butt if your a good guy, if your not a good guy be ready for an influx of business.

[Allrounder]

In other words, cover your butt if your a good guy, if your not a good guy be ready for an influx of business.

:bigcry: the "not a good guy" route is looking better and better...

[Leo G]

This wasone of the first things I thought when this rule started to show. Let me see, you pay a couple of hundred bucks to get into the class, which will automatically put you on a government list. Now all the government needs to do is locate the job you are at and ready the fines.

If you are an unknown, you are just that. Out of the loop. They don't know of you and therefore probably won't even be looking for you. This is just another trap for the good guys. We need to charge more and this is a money driven service, low bidder takes all (not always, I know, but a good average). So the guys following the rules willbe punished and the guys under the radar will win the bid.

Hooray for being legal.

[SLS-Construction]

Well he11 - Alabama went & joined in the fray & makes the EPA writers & bean counters look good

What a friggin nightmare - $100 a year per renovator (everyone & I mean everyone has to be one), $300 a year per firm including architects, designers, consultants, etc..., a special permit & fee to perform the job, and...

http://blog.sls-construction.com/2010/alabama-rrp-implemented

[Leo G]

They can smell the money.

[Allrounder]

A rep from the MN dept of health spoke at a continuing ed class last week, he said that MN will implement it's own program by this time next year, and we will have to be re-certified for MN, and the money we've already paid the feds will be lost.

[RCP]

A rep from the MN dept of health spoke at a continuing ed class last week, he said that MN will implement it's own program by this time next year, and we will have to be re-certified for MN, and the money we've already paid the feds will be lost.

If you were certified by an approved EPA trainer, are you sure you have to re certify (retrain) for your CR?
My state adopted RRP, they accept the training, but you have to pay the Certified Firm fee to them, so you do "lose" the $300 you paid to EPA, but at least you will still be in the searchable database on the EPA site.

And if you work in another state at all, you will need it. I was just reading this (http://www.shawnmccadden.com/rrpedia/bid/44877/Delegated-States-Likely-Better-Prepared-To-Enforce-EPA-RRP-Rule), I agree we may see better enforcement if the state's have control.

[SLS-Construction]

Sorry Chris - while I agree to some extent with McCaddens thinking, in reality only Massachusetts has pulled it off successfully through a combination of enforcement, training & getting the word out.

Eric, I agree with Chris - they are probably only talking about the Certified Firm portion. Granted they could also pull what our state did and basically nullify the training / limit it & / or add another fee on top. Pay attention to what they are trying to do - it is not supposed to happen behind closed doors & with enough pressure it can be blocked & changed

[RCP]

That's why I said "may".
As much as Mass has done, I still hear from several Mass guys who say they see no enforcement.
In Utah, they capped the fines at 10k and have openly stated they will work towards compliance and education rather than enforcement. The state did send out a letter to all licensed contractors explaining the rule. They also have a higher fee schedule, and all CR's have to register for $150.

If the state's have the revenue from fees, they may be more apt to use those to do more than the EPA, without the fees, they can't do anything.