EPA RRP Rule in the News

[ChrWright]

http://www.swtimes.com/articles/2010/02/28/business/business022810_01.txt


“I feel like the cost and the effort is minimal,” he said. “People should apply for certification so as not to worry about the fines or being shut out of a job because of a lack of certification. Eventually, homeowners will all know about the dangers of lead-based paint.”

What do your "feelings" have to do with it? :rolleyes3: Give me a break.

There's also a reference in there to the opt out... :rolleyes3:

[ChrWright]

http://www.shreveporttimes.com/article/20100228/NEWS01/2280312/1060

Painters, electricians and plumbers could all face tighter regulations when working in older homes, and added costs for compliance could ultimately be passed on to homeowners.

"COULD" be passed on?

[nEighter]

bunch of crap.

[Allrounder]

Jeez, I'd rather they NOT spread the word if they're going to be this clueless about it.

[ChrWright]

http://www.ky3.com/news/contactky3reports/87419652.html

Mostly basic info... Watch the video to the end for this nugget:

ANCHOR 1: "Ok, so what happens if the homeowner hires someone who's not certified?"

ANCHOR 2: "Well technically, the homeowner is breaking the law. But the good news for them is it's the contractor who's held responsible..."

Good news. GOOD news.


And here's your DIY Permission Slip to turn your house into a dusty lead mess:

ANCHOR 1: "So what if you can just do that work on your own?"

ANCHOR 2: "It doesn't apply to you. If you want to do the work on your own, you're fine. You're good to go. You don't need to be certified. This only applies if you're paying someone to do the work for you."


You're fine. You're good to go. :rolleyes3:

I understand the piece is about contractors and the rule, but DIYers are creating more hazards in their own homes than we are.

[Allrounder]

The video was actually pretty good until the end there. Too bad.

[Silvertree]

Easy, anything that protects children is good, of course you can sicken your own children, just not someone else' s.

I wonder if some people will ignore the rule?

[neolitic]

Easy, anything that protects children is good, of course you can sicken your own children, just not someone else' s.

I wonder if some people will ignore the rule?

You forgot the sarcasm smilie.....:grin:

[Bender]

"And with the money you save you can buy your kids some nice toys from China, or your hubby some quality tools from Harbor Freight!"

"Don't forget to throw out those family heirlooms as well."

[Bodger]

ANCHOR 1: "So what if you can just do that work on your own?"

ANCHOR 2: "It doesn't apply to you. If you want to do the work on your own, you're fine. You're good to go. You don't need to be certified. This only applies if you're paying someone to do the work for you."


You're fine. You're good to go.

It doesn't apply??? So, a homeowner can spread lead dust all over their house, not contain it or dispose of it properly, leave that residue everywhere and they are GOOD TO GO?

What if they do that and sell the house two months later? Are the new unsuspecting homeowners also good to go?

I love the part about the "good news". Yeah, technically they're breaking the law, but it's okay because we have have a contractor fall guy.

[afkama]

Easy, anything that protects children is good, of course you can sicken your own children, just not someone else' s.

I wonder if some people will ignore the rule?

I have no doubt they will, judging by how they pay little regard to the Building Code.
I have seen DIY electrical work that made me cringe.

[Bodger]

I have no doubt they will, judging by how they pay little regard to the Building Code.
I have seen DIY electrical work that made me cringe.

It's also a matter of time before you hear an HO insist that the contractor ignore it too, so they can save money.

Who doesn't have a list of illegal things they've been asked to do?

[afkama]

Who doesn't have a list of illegal things they've been asked to do?

It's hypocritical of me to admit, after my tirade about how we should all be law abiding Americans, but we do things all the time that meet the letter of the law, but not the intent.

In Ca we have figured out standard ways of getting around Title 24. The electricians carry fixtures on their trucks to install as temporaries until after final, when they come back to change them out. The inspectors know this game, and as long as it meets code at the time of inspection, it's all a nod and a wink.

There are a lot of things I won't do, because the liability is too high, and because it is just plain dangerous and irresponsible. I tell the client they'll have to get someone else. This would definitely fall into that category for me.

[Bodger]

It's hypocritical of me to admit, after my tirade about how we should all be law abiding Americans, but we do things all the time that meet the letter of the law, but not the intent.

In Ca we have figured out standard ways of getting around Title 24. The electricians carry fixtures on their trucks to install as temporaries until after final, when they come back to change them out. The inspectors know this game, and as long as it meets code at the time of inspection, it's all a nod and a wink.



Shocking.



And I do it on every job. Especially the light in the shower on the timer. Forget that.

[Leo G]

It's hypocritical of me to admit, after my tirade about how we should all be law abiding Americans, but we do things all the time that meet the letter of the law, but not the intent.

In Ca we have figured out standard ways of getting around Title 24. The electricians carry fixtures on their trucks to install as temporaries until after final, when they come back to change them out. The inspectors know this game, and as long as it meets code at the time of inspection, it's all a nod and a wink.

There are a lot of things I won't do, because the liability is too high, and because it is just plain dangerous and irresponsible. I tell the client they'll have to get someone else. This would definitely fall into that category for me.


http://www.energy.ca.gov/2005publications/CEC-400-2005-005/chapters_4q/6_Lighting.pdf

[Eieio]

Lead Paint Rule Weighs On Contractors’, Consumers’ Wallets

By Ann Marie Somma

Special To The Hartford Business Journal

03/15/10

Farmington contractor Darek Talewicz is among those who have taken the renovation course and registered with the EPA.Farmington contractor Darek Talewicz is among those who have taken the renovation course registered with the EPA.

Darek Talewicz’s Farmington home improvement business is so slow he worries about how he’ll pay $1,400 in monthly health premiums for his two small daughters.

But by April 22 he must dig into his pocket for $500, plus forfeit a potential day of work, to meet a new lead paint requirement set by the U.S Environmental Protection Agency.

Under the new EPA requirement, painters, electricians, plumbers, and contractors who renovate or remodel homes built before 1978 must be certified. That means sitting through an eight-hour class costing $185 to $195 to learn how to prevent lead contamination, then paying $300 to register with the EPA.

The new rule has many Connecticut contractors and handymen, including some who claim to be unaware of the regulation, worried about the cost and how it will impact their business.

“I think it’s a good idea that people know about lead and its consequences but right now it’s a lot of money for me,” said Talewicz, owner of Vento Home Improvement in Farmington.

In addition to the cost of the class and certification, contractors must invest more than $1,500 in equipment such as a commercial HEPA vacuum and filters, plastic, and a host of testing supplies.

Contractors say that the cost of the training, the equipment they must buy and extra time spent on a job will be absorbed by homeowners.

“The construction industry is in the tank and now there is this burden,” said Gene Burch, who teaches EPA lead certification classes at RTK Environmental Group in Newington.

Ron Locandro Jr., whose Mr. Handyman franchise employs five, paid almost $700 to attend the class with one of his employees and to register his business with the EPA. Those expenses will get passed down to his customers, he said.

“I got to charge more now. I’m going to spend an hour more on the job and it’s going to cost the customer,” Locandro said.

Bob Hanbury, past president of the Home Builders Association of Connecticut, fears customers will back away from a project or find a contractor who isn’t certified because the EPA hasn’t educated consumers about lead certification.

“People don’t trust contractors; they trust the government less,” Hanbury said. “The federal government hasn’t built a public awareness campaign. They put the regulation on file on the federal register and assumed they did their job.”

More (http://www.hartfordbusiness.com/news12333.html)

[Bodger]

My biggest problem with this right now is the expense. I'm not stone broke, but I really don't want to have to run out and spend a couple of grand on this crap when business is this bad. And it remains to be seen how these HOs are going to react to the financial aspect of this.

It does not escape my awareness that this was thought up by people who work for the government and probably don't have a clue what it's like to run a small business. Their jobs are secure, even more so when they create this bulls**t.

[afkama]

http://www.energy.ca.gov/2005publications/CEC-400-2005-005/chapters_4q/6_Lighting.pdf

Actually the new revision went into effect Jan. 2010

http://www.energy.ca.gov/title24/2008standards/index.html

They are well aware that we have been flaunting the regulation, so they are trying to tighten things up to make it more difficult.

[bconley]

Actually the new revision went into effect Jan. 2010

http://www.energy.ca.gov/title24/2008standards/index.html

They are well aware that we have been flaunting the regulation, so they are trying to tighten things up to make it more difficult.

Thats a lot of "stuff" to know, does it all get sorted out at plan check and by the architects?

Now I know how much light is needed for religious worship :rolleyes3: (pg. 129)

[Allrounder]

This story isn't bad, other than the Dept of health official telling us that it estimates only a $65 increase per job :rolleyes3:

http://www.myfoxtwincities.com/dpp/news/epa-lead-safe-rules-mar-10-2010#viewSingle94033769

[Bodger]

This story isn't bad, other than the Dept of health official telling us that it estimates only a $65 increase per job :rolleyes3:

http://www.myfoxtwincities.com/dpp/news/epa-lead-safe-rules-mar-10-2010#viewSingle94033769


Yeah, so when it's actually $1500 the HOs think we're pocketing the rest. This is a CF of magnificent proportions.

[afkama]

Thats a lot of "stuff" to know, does it all get sorted out at plan check and by the architects?

Now I know how much light is needed for religious worship :rolleyes3: (pg. 129)

There are consultant engineers who do the calcs and certify compliance. This is submitted with the prints, engineering, soils report etc.

[ChrWright]

USA Today's VERY brief article on the RRP Rule:

http://content.usatoday.com/communities/greenhouse/post/2010/03/lack-of-epa-certified-workers-could-stall-home-remodeling/1

[Leo G]

It still burns me it doesn't apply to HO. That we have to protect their childrens health but the parents can kill them off if they wish.

[RCP]

It still burns me it doesn't apply to HO. That we have to protect their childrens health but the parents can kill them off if they wish.

Yes, that bugs me too! Every time I watch one of of those stupid DIY shows and see them tear into old homes, I wait for the "host" to mention the possibility of Lead Paint!:rolleyes3:

Remember the switch to digital tv? Commercials every 2 minutes!

[SLS-Construction]

Yes, that bugs me too! Every time I watch one of of those stupid DIY shows and see them tear into old homes, I wait for the "host" to mention the possibility of Lead Paint!:rolleyes3:

Remember the switch to digital tv? Commercials every 2 minutes!

You will love this one then - today on one of the shows (HGTV 2010 air date), the host came to help a HO, fix there outside that was covered with 80 year old paint. The HO had used paint stripper & had problems as soon as it got down to the old Barn Red Paint.

In comes the host, gives him the Craftsman Belt Sander and they start going to work on the trim. Then they sand the detail spots with sandpaper. No respirators, dust-masks, plastic, nada... I think the HO, HGTV & hosts should all get fined for this if they pull this crap after 4.22. It is all being done for compensation of one sort or the other... which is how they get the Rental Property Owners.

[Leo G]

If it wasn't coming off with stripper it was likely milk paint and totally safe. But I see where you are coming from. The should show the public how it should really be done.

[J.Renza]

I stumbled across this broadcast from Mass.
Listen closely to the closing statement.
Made me want to reach through the screen and strangle this guy!

http://www.necn.com/pages/landing?blockID=195858&tagID=21150#comment_name195858

and;he states classes are optional?DUH

[Silvertree]

Contractors have had plenty of time to get ready?

And the EPA says it will train 50,000 workers in March and 50,000 in April, great, but they can only process 60 applications a day.

[ChrWright]

Question I hadn't thought of before:

Is it 200,000 certified renovators that are needed or 200,000 firms that will need certified...

I gotta think it's the latter. At the beginning of the week the epa site showed 1,800+ certified firms. Now it's up over 2,000. Where are they getting the 50,000 number from?

Anyone see a stat on tracking the number of Certified Renovators?

[Silvertree]

The 50,000 number is from an article quoting an EPA spokesperson

[ChrWright]

In other words, it's a WAG and nothing more.

$35.00

50,000

Same same.

[Silvertree]

I'll see if I can find it, she said "we will train" 50,000 in March and 50,000 in April............

[ChrWright]

See, that sounds like CRs... You can have all of the CRs you want... what about the firms who have to be certified to use them?

[Silvertree]

The number for firms is 200,000 plus, 300,000 on another article I read a few months ago.

Firms are what count, they will have less than 10,000 by the deadline, unless they are planning on getting more office help.

I have been waiting for my letter from the EPA so I can put my phone number in, they said they mailed it on the 13th, still not here.

[ChrWright]

http://www.dispatch.com/live/content/home_garden/stories/2010/03/21/dust-up-over-lead.html?sid=101

This is a pretty thorough article. Shows both sides of the issue, and this tidbit:

As of last week, according to the EPA, about 14,000 contractors had been trained nationwide - a far cry from the 236,000 the agency estimates need the training.


Also interesting:
Homes can be exempt from the restrictions if it can be proved that a home does not contain lead paint. (Only 24 percent of homes built between 1961 and 1978 used lead paint.) But such testing must be done by a certified tester and must be strictly documented.

[Silvertree]

Here is part of the problem, even when you, Sean, myself and others read and copy articles on the EPA lead rule we get numbers from 25 million homes to 80 million.

We get 6000 to 14,000 firms certified.

Varying numbers on trainers, workers, firms to date.

We get nothing but more information that contradicts itself on every read.

The EPA feels its done a great job so far?
No enforcement except for turn in other contractors.

So you see a guy on a 1959 house and you know he is not certified, you turn him in, they stop the job, and the test shows no lead.

Who pays damages for the stop work?

[Bodger]

How can it be accurate that there are only 200,000 contractors that need to be certified?

That seems incredibly low when you consider all the painters, electricians, plumbers, cabinetmakers and other trades whose work could conceivably cause them to fall under these compliance requirements.

Am I missing something? Or just overestimating the amount of tradesmen in this country. Seems like the number would be much higher.

[Leo G]

Same reason it will cost an average of $35 extra per job to comply

[Allrounder]

EPA Refutes Critics, Keeps Lead Rule on Track

http://www.paintsquare.com/news/article_news.cfm?id=3662&nl_versionid=413&trackid=6713591

Well, at least they tried....

[Bodger]

EPA Refutes Critics, Keeps Lead Rule on Track

http://www.paintsquare.com/news/article_news.cfm?id=3662&nl_versionid=413&trackid=6713591

Well, at least they tried....


Four Senators contacted, none commented. Too busy I suppose.

[J.Renza]

I had to comment on the statement where we had two years to comply and a couple other "facts":

To the statement that everyone had two years to get ready I can only add what is printed on the EPA's own web site:

Training programs . Effective June 23, 2008, no training program may provide, offer, or claim to provide training or refresher training for EPA certification as a renovator or a dust sampling technician without accreditation from EPA under §745.225. Training programs may apply for accreditation under §745.225 beginning April 22, 2009.

Since Instructors couldn't even start to apply for accreditation till April 22,2009,you now have to add the time it took to be approved,figure an approach,train employees,put out an advertising campaign,schedule classes and locations etc.......

Now,considering the fact that so many contractors are still in the dark about this because " The EPA will also be conducting public-awareness campaigns to help enforce the rule. "

This should have been done first,proving that their insistence on keeping the roll out date of April22,2010 is nothing short of an ambush on an already faltering industry.

And to this statement:
“Not everyone is going to do a job in a pre-1978 house on April 22,” she said.

This is naive and condescending showing the lack of consideration for anyone in this business.
80% of the houses in my area are pre 78',so the impact will be devastating to those that aren't certified.

Their actions,and statements like this, are further proof of
the abuse of power they so willfully endow upon us with a blind eye to actual facts.

[DaVinci]

I saw this yesterday - Ten Senators ask for delay?

http://epw.senate.gov/public/index.cfm?FuseAction=Files.View&FileStore_id=f4c0f513-9f09-41a4-b9a0-b8a1d8068244

[Allrounder]

I saw this yesterday - Ten Senators ask for delay?

http://epw.senate.gov/public/index.cfm?FuseAction=Files.View&FileStore_id=f4c0f513-9f09-41a4-b9a0-b8a1d8068244

Actually, it looks like they are just asking that the EPA do whatever they can to train everybody by the deadline.

[Eieio]

Rehberg raps EPA on lead-training rule

Recap with a little more info..


HELENA — U.S. Rep. Denny Rehberg, R-Mont., on Friday asked the White House to delay implementation of a new Environmental Protection Agency rule requiring renovators to become "lead-safe certified."

The rule, set to go into effect April 22, requires contractors working on any house or building built before 1978 to take extra precautions to minimize the potential health hazards associated with lead-paint dust or debris.

Critics of the new rule said the EPA hasn't done enough to ensure that contractors obtain the required certification by next month's deadline.

EPA officials have said the agency is on course to have enough contractors trained and certified in lead-safe work practices to meet the demand of Americans seeking to renovate their homes.

In response to Rehberg's letter, the agency released a statement Friday noting that it issued the new lead rule because "a disturbing number of America's children are still being poisoned by lead-based paint in their homes."

Lead is a toxic metal that for decades was used in common products found in and around homes. It can cause serious health problems ranging from behavioral issues and learning disabilities to seizures and death. Children 6 years old and younger are most at-risk from lead poisoning, according to the EPA. The federal government banned the sale of lead-based paint for residential use in 1978.

Rehberg led a bipartisan group of House members who urged the White House Office of Management and Budget to hold off on implementing the new EPA rule in order to give contractors more time to comply. The elected officials said the new rule is especially burdensome for contractors in sparsely populated parts of the country.

"We are concerned the EPA has not taken the steps necessary to certify the appropriate number of professionals needed to meet its compliance standards," the representatives wrote. "Of even more concern to us is the lack of opportunity home renovation professionals in more rural areas have had to receive the training the EPA lead rule demands."

More at the here:http://www.greatfallstribune.com/article/20100327/NEWS01/3270307/1002/Rehberg-raps-EPA-on-lead-training-rule

[Bodger]

This is all falling on the deaf ears of the EPA. They will expend resources on enforcement, not making it more feasible and resonable for contractors to comply.

As they say in the military: "Tough sh*t, see the Chaplain."

[ChrWright]

Where on earth do they get the 50,000 stat from?

There's no possible way that many have been trained since October.

[Dean CRCNA]

Where on earth do they get the 50,000 stat from?

There's no possible way that many have been trained since October.

See http://www.epa.gov/lead/ top right side ... green area with a yellow "New"

[Silvertree]

That's funny, their site only list 81 Certified firms for Minnesota.

Math doesn't add up does it?

Trained individuals?

[SLS-Construction]

Paul - they are talking about CLR's not firms. That's ok, they can have 250K CLR's for all I care, they will all be unemployed unless they work for a Certified Firm

[Allrounder]

RRP Predictions: Dazed and Confused at Home and in the Lumberyard

Homeowners...

*
Will become acutely aware of the true risks of lead contamination in their homes and/or the potential poisoning of occupants if work is handled incorrectly, due to EPA’s public awareness campaign.
*
Will ask their remodelers (for current or scheduled work) for proof of firm certification and training. Many may stop or delay work on their homes if their remodeler isn’t prepared.

Yeah, right. :laugh3::laugh3:

http://www.remodeling.hw.net/blogs/postdetails.aspx?BlogId=shawnmccadden&PostId=93436

[Leo G]

RRP Predictions: Dazed and Confused at Home and in the Lumberyard



Yeah, right. :laugh3::laugh3:

http://www.remodeling.hw.net/blogs/postdetails.aspx?BlogId=shawnmccadden&PostId=93436

Many HO's will stop the work so the contractor can get certified and set up to do the job the proper way. They will be willing to accept the timely delay and increase in cost of their projects. After all, it has just been found that lead is hazardous to your health. :rolleyes3:

I'm sure this is a likely scenario. :laugh3:

[ChrWright]

http://www2.timesreview.com/NR/stories/R040110_EPA_jen

Fearing a new Environmental Protection Agency lead paint rule will have an adverse impact on the home remodeling industry, Rep. Tim Bishop (D-Southampton) called for a delay Tuesday in the implementation of the regulation.

The rule, which is scheduled to take effect later this month, requires special certification for contractors remodeling homes built before 1978. While the rule was created to cut down the number of children being poisoned by lead paint in their homes, Mr. Bishop said he believes that's not the only thing such a rule will cut down.

"About 90 percent of contractors on Long Island, through no fault of their own, are not trained," Mr. Bishop said. "To impose it now when we have so few contractors both locally and nationwide who are trained to comply, and we have so many homeowners who wish to have their homes renovated, this is simply the wrong time."

more... (http://www2.timesreview.com/NR/stories/R040110_EPA_jen)

[Silvertree]

This will only get more confusing as we approach the deadline.
Poor planning from the parties involved and no clear agenda to promote will make this difficult to enforce.

[Dean CRCNA]

It has to be on this date ... it's Earth Day!?! :rolleyes3:

http://www.epa.gov/earthday/

[Bodger]

Many HO's will stop the work so the contractor can get certified and set up to do the job the proper way. They will be willing to accept the timely delay and increase in cost of their projects. After all, it has just been found that lead is hazardous to your health. :rolleyes3:

I'm sure this is a likely scenario. :laugh3:


EPA must think everyone's job is as easy and secure as their's is. Reality apparently is not a major factor in the decision making process.

And yeah, Earth Day, it's gotta be then. Cute.
Maybe December 7th would have been a more portentous choice.

[eXapath]

Stumbled across this law blog post on RRP, provides some good legal guidance for contractors wrestling with the impending EPA regulations. Be sure to read the entire post and review the suggestions for contract elements.

http://constructionlawva.com/leadbased-paint-renovation-repair-painting-program-lawimportant-legal-issues/

Hope this helps.

[nEighter]

Not sure if you guys know who PCI magazine is.. but they are like a magazine that talks about components of paint.. the chemicals and compounds that make up the paint. I asked them about 2 months ago about why they have not done a story on the RRP. I got this back from them today:

Hi Nathan, sorry it's taken us so long to see your question. I've asked my editorial team for some information for you. Stay tuned!

http://www.pcimag.com/ < check out the magazine online here

[ChrWright]

http://yosemite.epa.gov/opa/admpress.nsf/0/224fa6042fb051408525770000452c8d?OpenDocument

[ChrWright]

http://www.courant.com/business/real-estate/hc-hre-epa-lead-paint-rules-041.artapr11,0,2975642.story

[Leo G]

http://www.courant.com/business/real...,2975642.story


The Environmental Protection Agency says it has conducted studies showing that for most jobs the costs for sealing off the area, vacuuming up the dust and record-keeping should range from $8 to $167. One exception is large exterior projects that require containment of more than one story, the EPA says.



They are still clueless on the costs of this new ruling. $8 ???? WTH is going to happen for $8? That is like 8 minutes worth of time. So you are going to be able to get the plastic up in the room, tape it to the walls and floors. And then afterwords, vacuum up, swiffer the area, take the plastic down and do a lead test. All this for $8? The lead test is $15, the plastic is $8-12, I see about 2-3 hours to comply to the sealing and cleaning.

How can they keep printing this stuff?

[Silvertree]

I wish they would stop publishing that $8 to $167 figure, even pretending that's correct is out of your mind thinking.

$8? How in the hell did they come up with that?

[RCP]

“EPA has been working hard to get the word out far and wide to contractors working in older homes, schools and day-care centers that this training is available to help stop lead poisoning in children. All a contractor needs to do to be certified is take a simple one-day course.”

More here...... (http://www.paintsquare.com/news/article_news.cfm?id=3706&nl_versionid=426&trackid=0)

[Leo G]

Ya, a one day course that cost you $200 to tell you that you need to alter your way of doing business and you have to buy another $1500 worth of tools to comply and then give the EPA $300 every 5 years. They forget to mention a few of the more minor things, huh?

[Bodger]

EIGHT DOLLARS??

Like I've said before, if the EPA doesn't have a clue about what the actual added cost is, they are disseminating incorrect information to homeowners.

Other than added cost, what other inaccuracies are they spewing? Are they wrong about the extent to which lead is a danger in the first place? Is it worse than they think or less than they think.

The fine for non-compliance is $37,500, but it's only eight bucks to comply. Seems like those two numbers are way out of line.

[neolitic]

http://www.finehomebuilding.com/item/11791/ask-the-epa-about-the-new-lead-paint-remodeling-law

[neolitic]

http://www.thisiscarpentry.com/2010/04/13/hot-topic-new-lead-safety-rule/

I posted links to RC, but it seems
they didn't like that?

[Eieio]

http://www.thisiscarpentry.com/2010/04/13/hot-topic-new-lead-safety-rule/

I posted links to RC, but it seems
they didn't like that?

did they remove your comment?

[neolitic]

did they remove your comment?

I guess it didn't pass their vetting.
Chris Wright is in there now though.

[neolitic]

An e-mail in response to a
news story yesterday.
What say you?

Subject Home Contractors Brace For Lead Paint Rules:

Body:
I would hope that you would do some follow up on yesterday's story.
As they have been through out this process, the EPA is a bit loose with the facts here. "EPA officials say that's an exaggeration. The government published the rules in 2008, giving the industry two years to prepare....Rebecca Morley, executive director of the nonprofit National Center for Healthy Housing, says manufacturers and contractors have dragged their feet and didn't take the change seriously until just before the deadline. "
To the best of my knowledge, there were no certified trainers until October 2009.
There was little effort to bring training to most of the country.
Our local remodeler's association had to take it upon themselves to organize the first training in this area (Indianapolis.)
There is still little consistency in training or rule interpretation from place to place. Contractor's from the same area often come away from different classes with differing interpretations of the rules.
The agency made no real effort to educate the public about this rule, instead leaving it up to the contractors who are now in the unpleasant position of being on the receiving end of the "shoot the messenger" syndrome.
The EPA's cost estimates are completely out of touch with real world conditions.
The mere thought of what liability might attach if we were to work on any older home where lead paint has been scrapped or disturbed during prior renovations or painting without the present required level of clean up boggles the mind.
Some of the homes most in need of remediation for both lead hazards and energy conservation will now be the last ones any reputable contractor would wish to be involved with.
None of this will be of much concern to the group of contractors who are responsible for the poor reputation we all suffer for. In consideration of all this and more, it does not seem unreasonable to delay implementation of the rule until EPA has properly publicized the rule, and makes training and approved equipment and testing materials more readily available.
Thank you.

P.S. If you would like a look behind the curtains at what some of the more concerned contractors around the country think about this,
and what they are trying to do to comply....
http://www.contractortalk.com/f11/new-epa-rrp-rule-takes-effect-april-2010-all-trades-need-understand-63265/
http://www.remodelcrazy.com/forum/showthread.php?t=2035 http://www.remodelcrazy.com/forum/showthread.php?t=2879 http://www.remodelcrazy.com/forum/showthread.php?t=4016

[neolitic]

It's getting interesting over at Gary's place....
http://www.thisiscarpentry.com/2010/04/13/hot-topic-new-lead-safety-rule/

[Eieio]

It's getting interesting over at Gary's place....
http://www.thisiscarpentry.com/2010/04/13/hot-topic-new-lead-safety-rule/

I think the 3rd party testing is going to be the hangman noose for a lot of companies.. They believe it will save their hides, I believe it will put the contractor and home owner in a very unfavorable position.

[neolitic]

I think the 3rd party testing is going to be the hangman noose for a lot of companies.. They believe it will save their hides, I believe it will put the contractor and home owner in a very unfavorable position.

This one pretty much covers my concerns.....

" John Renza says:
April 15, 2010 at 5:16 am

Those considering third party testing are on the right track here since it may become mandatory. There are too many scenarios that can cost even the most careful RRP work to fail. Many older homes are already contaminated from previous renovations, and whoever does the latest disturbance will foot the bill for clean up and the liability.

Years of previous scraping, sanding, and power washing exterior surfaces has tainted the soil. Lead in the soil can be carried into a home via foot traffic, toys, pets. Days after our RRP work is done, the home can become re-contaminated.

Also, many other household items also contain lead. Plastic blinds made overseas has been proven to contain lead, as well as Christmas tree lights, and extension cords. Remember, it only takes trace amounts for failure, and the burden of proof is on us.

So, since this has been dropped in our laps, proceed with due caution. The only way to protect ourselves against the liability issue will be third party testing."

[Bodger]

I think the 3rd party testing is going to be the hangman noose for a lot of companies.. They believe it will save their hides, I believe it will put the contractor and home owner in a very unfavorable position.


How so?
I still am unclear as to why I can't tell a homeowner that they need to use a lead abatement company and have the lead removed from the areas to be remodeled prior to the start of their project. If that happens, why do I need to shell out for a class and special equipment.

I hope the EPA realizes that once the lawyers get ahold of this, people who own pre- '78 houses will have a hell of a time getting any contractor to work on their houses.

[Eieio]

The lead is there.. Even after I leave the lead is going to be there.. The testing will only confirm what I know the lead is there..

The Home onwers unless I gut the home are living in a house with lead even after I am gone..

I will take every precaution as I renovate, but they are still living in a lead house before and after I leave.

So your going to sue me for???

I am being serious here I might be missing something but I just don't see the need for testing and I am not a risk taker by any means..

[Eieio]

How so?
I still am unclear as to why I can't tell a homeowner that they need to use a lead abatement company and have the lead removed from the areas to be remodeled prior to the start of their project. If that happens, why do I need to shell out for a class and special equipment.

I hope the EPA realizes that once the lawyers get ahold of this, people who own pre- '78 houses will have a hell of a time getting any contractor to work on their houses.

I would call in the lead abatement company if they wanted to remove all the lead surfaces in their house, but not for me to renovate their kitchen and bathroom etc.

[neolitic]

The lead is there.. Even after I leave the lead is going to be there.. The testing will only confirm what I know the lead is there..

The Home onwers unless I gut the home are living in a house with lead even after I am gone..

I will take every precaution as I renovate, but they are still living in a lead house before and after I leave.

So your going to sue me for???

I am being serious here I might be missing something but I just don't see the need for testing and I am not a risk taker by any means..

Did you read the guy who's been talking
with his lawyer buddies?

[Bodger]

Did you read the guy who's been talking
with his lawyer buddies?


Yes, I did. They're gunning for the contractors already.

I still don't understand about the abatement thing.

Let's say I am bidding a kitchen remodel and I suspect lead is present. Why can I not tell the homeowner about this RRP rule, and tell them that they need to have the area tested, and the lead removed by an abatement company before the project starts.

If they did that, and I walk in there to begin my project, if the lead has been removed from the areas we are disturbing, why do I need a certification for safe handling of lead?
Is this not possible to do? If I never set foot in a pr- '78 house, I don't need a lead cert.
If I'm doing work in an area of a pre- '78 house where the lead has been removed by a licensed abatement company, why do I need a cert, and why would I do it any other way considering the liability?

[Eieio]

Did you read the guy who's been talking
with his lawyer buddies?

Yes I did, the lawyers will come one way or the other. Unfortunately most are like parasite.

[Eieio]

Yes, I did. They're gunning for the contractors already.

I still don't understand about the abatement thing.

Let's say I am bidding a kitchen remodel and I suspect lead is present. Why can I not tell the homeowner about this RRP rule, and tell them that they need to have the area tested, and the lead removed by an abatement company before the project starts.

If they did that, and I walk in there to begin my project, if the lead has been removed from the areas we are disturbing, why do I need a certification for safe handling of lead?
Is this not possible to do? If I never set foot in a pr- '78 house, I don't need a lead cert.
If I'm doing work in an area of a pre- '78 house where the lead has been removed by a licensed abatement company, why do I need a cert, and why would I do it any other way considering the liability?


What happens if they test and demo out the kitchen..

Half way through the remodel you find out a water line needs replacing and have to demo out and remove some lead based trim and plaster walls, will you call back out the abatement company again?

[Bodger]

What happens if they test and demo out the kitchen..

Half way through the remodel you find out a water line needs replacing and have to demo out and remove some lead based trim and plaster walls, will you call back out the abatement company again?


If I tell the client that's what has to be done and they have to pay for it and it keeps me completely out of the lead loop, including certification and liability, would that be a bad thing? I'm just asking.

And if I were to approach all work on pre-'78 houses this way, economically feasible or not, am I still required to be certified?

[Eieio]

If I tell the client that's what has to be done and they have to pay for it and it keeps me completely out of the lead loop, including certification and liability, would that be a bad thing? I'm just asking.

And if I were to approach all work on pre-'78 houses this way, economically feasible or not, am I still required to be certified?

No, I can't say either way, I was thinking more along the lines of project completion and job expense to the homeowners.

Might take some time and considerable expense to get it done that way

[SLS-Construction]

I think the 3rd party testing is going to be the hangman noose for a lot of companies.. They believe it will save their hides, I believe it will put the contractor and home owner in a very unfavorable position.

I just added my comment to that line of thinking - I am sure the HO's will love not being able to access that area for 3 to 5 days until the results come back

[Bodger]

I just added my comment to that line of thinking - I am sure the HO's will love not being able to access that area for 3 to 5 days until the results come back


The more I learn about this, the more I think this RRP is a pipe dream for the EPA. And non-compliance will be rampant, and the lawyers will bust out a lot of honest guys who are trying to make a living and stay legal.

In fact, if I had a choice and had plenty of other business, I wouldn't drive one nail in a house built before 1978.

[Dean CRCNA]

If I was a lawyer, I would be going after the easy money ... non-certified companies ... not certified (where it will be harder to prove).

The non-certified companies will greatly shield the certified firms

[ChrWright]

It's ALL easy money for the attorneys...

It's going to be worse if they can prove you knew what you were supposed to be doing, and didn't.

[J.Renza]

I just added my comment to that line of thinking - I am sure the HO's will love not being able to access that area for 3 to 5 days until the results come back

I haven't done the research on this yet,but wouldn't one of the
XRF detection guns solve this these time delay problems?
Is there a way they can be adjusted to just check the surfaces in
our work zone?
Both for the initial inspection and the final tests?
Or,
Also,since we are allowed by RRP to use the swabs to
test for the presence of lead residue,why can't a third party
inspection also get immediate results.
After all we're just verifying our clean up results.
Since we aren't doing abatement,and all we want to do
is cover our arses for liability reasons.
Having the third party verification would shift this liability.
This may also have some impact on any Insurance costs.

Just thinking out loud here,trying to figure a way to
soften the blow from all the added responsibilities.

We got to assume that there is some lead dust around when
we arrive at a project,I just don't want to be responsible
for cleaning up the previous contamination in areas
where we haven't worked.

[Silvertree]

There will be lots of starts and stops with the rule, I'm guessing soon after the first lawsuits we'll come up with some ways to protect ourselves.

[Leo G]

Having the third party verification would shift this liability.
This may also have some impact on any Insurance costs.



It says right in the rule that you cannot remove your liability through your contract. The only thing that will do is hold both of you liable. So the lawyers will have two avenues of revenue. :censored:

[Bodger]

The only way to remove your liability is to not touch any house with lead paint.
It's been said, and correctly, that the biggest hit contractors will take from this won't be EPA fines, it will be lawsuits. It's the perfect storm of liability, even your GL doesn't protect you in the case of most policies anyway. Mine does not.

And I've seen it stated here that it will be hard to prove, and the fact that there was lead dust before you got there will make it hard for any litigator to win. But so what? You'll still have legal fees, court dates to appear at, possible damage to your reputation through your referral pipeline. All of which costs money, even if the case is dropped or you prevail. Who has time to screw around with that just because the EPA set us up as fall guys?

[J.Renza]

It says right in the rule that you cannot remove your liability through your contract. The only thing that will do is hold both of you liable. So the lawyers will have two avenues of revenue. :censored:

I was thinking more along the lines of being held liable for existing
conditions.
As an example,lets say that the ground around a house is already
laden with lead and all your work was inside one bathroom
where all the removed material was taken out through a window
that a dumpster was parked next to.You do everything by the book.

You even covered the ground to the dumpster path so as not to
accidentally drop any "dust"in the yard.
HO sees you've taken the precautions inside and done the final dust test.
Then he asks "Don't you test the outside/"
You tell him it isn't required by RRP,but he insists,there upon finding
the old lead in the soil.
Guess what......................

I wouldn't want to be held responsible for cleaning up
the whole yard.

The same thing could happen inside in rooms you didn't even enter.
Old carpeting could have had lead tracked in over the years and
now we become the scape goat.

If the third party comes in and maps out the contaminated areas
then we can notify HO,and decide how to proceed.
Does third party inspections finding lead necessarily move the project into abatement mode?
If not,at least we have verification of existing conditions in areas we
shouldn't have to be responsible for.

If we go in and do our part without a third party,and have a hard time getting
the dust test to pass because there's lead constantly being tracked in from outside
then we're stuck.If we knew before hand the extent of the contamination,we could have refused
the project.
Then again,if we go in and finish up ,swab tests passes,third party immediately
does follow up to back up our results.

It says right in the rule that you cannot remove your liability through your contract.
I thought the whole idea of third party testing was to ensure the project was done to RRP standards. The "contract "with him is to see everything is done to these standards.
If he's a trained professional,than he would have to assume the liability since he's assuring the project is "clean" by RRP standards..NO?
Maybe I misinterpreted something here.

If you and a third party have negative tests results ,it should clear us of any responsibility
and even the best lawyer would have to think twice before trying to
bring suit without exhausting other possible causes for LBPP
If not,the first guy they should go after,I assume would be the third party inspector.

I don't know guys,this whole thing is driving me nuts,especially since
I live in the Lead Capital of the country so work is limited.

[SLS-Construction]

I haven't done the research on this yet,but wouldn't one of the
XRF detection guns solve this these time delay problems?

Also,since we are allowed by RRP to use the swabs to
test for the presence of lead residue,why can't a third party
inspection also get immediate results.
After all we're just verifying our clean up results.


J - for the first one, it is called physics (XR stands for XRay)

Second part - they might come up with something like that, but it is calling for a mandatory third party dust clearance exam which involves a lab to test said dust & amount on said samples

[J.Renza]

J - for the first one, it is called physics (XR stands for XRay)

Second part - they might come up with something like that, but it is calling for a mandatory third party dust clearance exam which involves a lab to test said dust & amount on said samples


I did a little research on the various guns available for lead testing and found one that claimed to be able to test the wipes for lead:

http://www.niton.com/Lead-Paint-Testing/Applications/beyond-lead-paint.aspx?sflang=en

If the EPA would approve of this for a final inspection,and it was used by a certified Risk Assessor,maybe it could alleviate the liability issue by providing a professional documentation of
RRP conformance.
It could help keep the lawyers at bay.

On questionable properties,in areas where lead paint may not be too prevalent,the relatively lower cost of doing the risk assessment up front may save $ and time,allowing for a more productive project.
The cost would have to be weighed against each jobs size and scope.

Just thinking out loud again,but when I leave a project I don't want to worry about
callbacks of any kind.It may help keep some of the plastic out of our landfills also.

[bconley]

The RRP is not abatement, we just have to control the dust we produce.
As long as we document the project and (take pictures) I think we will be OK.
The spirit of the law is to reduce the lead hazard not to eliminate all lead from the area.
I could be wrong but I'm not worried about any lawsuits because of this.

[Leo G]

That is where the lawyers come it. They will go through every word of the new rule and find things that are written joust so and use it to their advantage. I see this ruling as one big clusterf... There is no allowances in the ruling for a previously contaminated site. The testing is done at the end. If there is a problem, it is now yours to deal with.

[neolitic]

...... The testing is done at the end. If there is a problem, it is now yours to deal with.

That is the thing I can't get past.

[J.Renza]

This is like going in to fight a forest fire and being told
not to light any matches.

[Leo G]

This is exactly what Mr Renza is talking about. You get the job, you inherit the whole liability of everything that has occurred before you ever stepped through the door. But don't worry, $35 is gonna cover everything.

[neolitic]

This is exactly what Mr Renza is talking about. You get the job, you inherit the whole liability of everything that has occurred before you ever stepped through the door. But don't worry, $35 is gonna cover everything.

Spanky and I have been on
the same page all along.
(Won't fool me with that
"Renza" stuff again) http://i634.photobucket.com/albums/uu61/neoliticman/smilie/smilieshifty.gif

[bconley]

If you do the cleaning verification there is no testing, yet.

[Leo G]

Spanky and I have been on
the same page all along.
(Won't fool me with that
"Renza" stuff again) http://i634.photobucket.com/albums/uu61/neoliticman/smilie/smilieshifty.gif

Who you calling Spanky :smash:

[Dusty]

I wouldn't worry about it, Guys. I think it would be very difficult to prove the exact source of lead poisioning in a person. It's everywhere. In the schools, toys, lunch boxes jewelry, etc..

If there is lead on the exterior of a house, it has been probably bleeding into the soil for a long time already.

I guess the only way to truely protect yourself would be to test the HO's and their family members before and after the job.

[neolitic]

Who you calling Spanky :smash:

Spanky..........

[Bodger]

I'll see your Spanky and raise you one Gabby.....:grin:

http://i592.photobucket.com/albums/tt10/dingoff/gabby_hayes.jpg

[WarnerConstInc.]

I am requiring blood work for all my clients in pre-78 houses before and after the job.

How am I going to fudge in the extra 1800 bucks for a re-trim of a bedroom?

New base, casing, crown moulding, and some new closet doors: that will be 4800 thanks!!

[Bodger]

I am requiring blood work for all my clients in pre-78 houses before and after the job.

How am I going to fudge in the extra 1800 bucks for a re-trim of a bedroom?

New base, casing, crown moulding, and some new closet doors: that will be 4800 thanks!!


I hear you on this. Especially because I live in a nanny state which is populated by granola chomping health freaks. And lots of lawyers.

They wouldn't pay for blood tests and won't want to pay extra for special lead handling on a project. But they would sure as hell retain a lawyer.

I'm anxious to see how long it takes until we start seeing advertisement from lawyers encouraging people to litigate against anyone who has worked on their pre-'78 houses.

[bconley]

Lead doesn't stay in the blood for long it is better to have the lead level in the bones tested.
The same XRF technology for testing for lead paint can test for lead in the bones.
Just zap them with your ray gun.

[nEighter]

http://www.kmbc.com/news/23200068/detail.html

[neolitic]

Gee....
In depth reporting.
Gave it what?
A full 45 seconds?
That ought to about cover
it all.

[Leo G]

And the info that guy had was wrong. He said you MUST test for lead. He said you HAVE to have your plastic going 20' out.

Way to misinform the public

[Century Man]

The Official Online Newspaper of NAHB

April 19, 2010

NAHB Petitions the EPA to Delay Lead-Paint Work Rule

NAHB on April 5 petitioned U.S. Environmental Protection Agency Administrator Lisa Jackson to delay the Lead; Repair, Renovation and Painting Program (LRRP) rule, citing (more (http://www.nbnnews.com/NBN/issues/2010-04-19/Front+Page/5.html#))

[ChrWright]

How many times does this have to be said:

YOU ARE NOT REQUIRED TO TEST FOR LEAD.

Sheesh. These pieces burn me up. I hope to God the one I'm doing Wednesday doesn't end up with this kind of crap being emphasized.

[Leo G]

Not quite the news but a thread has been posted over in WoodWeb and again doesn't seem to be drawing that much attention. Very surprising because I know most of the guys there are in larger companies that do more than just build the cabinets. Here's the link, you can post there without a membership


http://www.woodweb.com/cgi-bin/forums/business.pl?read=651393

[neolitic]

For those of you who missed it
when the Consumer Product Safety Commission
issued the lead paint ban, (which was notkept
secret like this on) here is
some history....

http://i634.photobucket.com/albums/uu61/neoliticman/LeadPaintChart.jpg

[Bodger]

So, next year we'll need a cert for mercury?

[WarnerConstInc.]

So, next year we'll need a cert for mercury?

We will need a cert just to smoke outside and use the bbq before to long.

[Bodger]

We will need a cert just to smoke outside and use the bbq before to long.


I'm gonna move to France. You can smoke wherever you want in France and they don't give a rat's arse about lead paint. They're too busy with important issues like making sure Burkas are outlawed.

[neolitic]

I'm gonna move to France. You can smoke wherever you want in France and they don't give a rat's arse about lead paint. They're too busy with important issues like making sure Burkas are outlawed.

Better check up on that
before you buy zee ticket.

[Bodger]

Better check up on that
before you buy zee ticket.


I would, but why bother, I live in a fantasy world. :grin:

[Bodger]

Slow on the Uptake

For some reason the USA was slow to outlaw or restrict the use of lead in consumer products. A very long time ago it was discovered that if you mixed lead with vinegar that it created lead acetate. This is actually a sweetener. So, lead was used as a sweetener in wine for many years. In 1427 the use of lead as an ingredient in wine was outlawed in France and Spain. That was 500 years ago!

Lead has been used in paint for over 200 years. But, France began to restrict the use of lead in paint in 1840. The Germans did the same in 1870 and they were followed by the Australians in 1922. It wasn't until 1978 that the USA decided to act.

Freakin' frogs also banned smoking in public joints in 2008.

Okay, Afghanistan. You can smoke anywhere in Afghanistan and they don't care about lead paint.

[neolitic]

Slow on the Uptake
............
Okay, Afghanistan. You can smoke anywhere in Afghanistan and they don't care about lead paint.


http://i634.photobucket.com/albums/uu61/neoliticman/smilie/smilielaughing.gifhttp://i634.photobucket.com/albums/uu61/neoliticman/smilie/smilielaughing.gif
Just watch where you walk.
They don't always care too much
about legs either... http://i634.photobucket.com/albums/uu61/neoliticman/smilie/smilieblink-1.gif

[neolitic]

At least NPR mentions that there
might be more costs involved than
EPA wants to admit.

http://www.npr.org/templates/story/story.php?storyId=126172267

BTW:
They did this story 2 years ago.

http://www.npr.org/templates/story/story.php?storyId=89266072&ps=rs

[Dean CRCNA]

Glen Beck (FOX News) did a section on the EPA. If you ever have seen Glen Beck ... you can imagine the hole reaming that was taken place :)

[Bodger]

Amazon knows all about the RRP and is there to help us with "hassle free compliance" : :grin:

I got this e-mail this morning. I'm assuming anyone who has ever bought a tool from Amazon also got one.

Amazon.com: Be Compliant with New EPA Lead Renovation Laws

Dear Amazon.com Customer,
As a valued customer, you might be interested in hassle-free compliance with new EPA-mandated legislation passed April 22, 2010. The new law requires contractors and other small entities to be certified to renovate or perform work on pre-1978 facilities due to the risk of lead poisoning. You may be interested in tools and supplies from ZipWall , which can help ensure safe and compliant work practices. To learn more about the new law, please refer to the EPA Regulation Summary .

[neolitic]

Have you seen this?
http://www.leadprotools.com/

At least they know how to reach us.

[Eieio]

Have you seen this?
http://www.leadprotools.com/

At least they know how to reach us.

I looked at it 7 times

[ChrWright]

Have you seen this?
http://www.leadprotools.com/

At least they know how to reach us.

Damn. She really knows what she's talking about.

I feel like those people understand me.

[Bodger]

I looked at it 7 times

Have you seen this?
http://www.leadprotools.com/

At least they know how to reach us.

Damn. She really knows what she's talking about.

I feel like those people understand me.


She has what we need. :rolleyes3:

I wonder when we'll start seeing the lawyers advertising.

[neolitic]

One would wish that she
were "compliant."

[afkama]

I wasn't impressed. she didn't have the right safety gear, no Tyvek suit, no respirator.
Not only that, but her tools were woefully inadequate for demolition work.

[ChrWright]

"You NEED what we have, and we HAVE what you need."

[Bodger]

"You NEED what we have, and we HAVE what you need."


You sho' do baby!

[neolitic]

I wasn't impressed. she didn't have the right safety gear, no Tyvek suit, no respirator.
Not only that, but her tools were woefully inadequate for demolition work.

I'm sure your wife is proud.

[afkama]

I'm sure your wife is proud.

My reply wasn't influenced in any way by my recent discovery that members of my staff and my wife have been reading these posts.

How could you insinuate such a thing?

[orson]

For those of you who missed it
when the Consumer Product Safety Commission
issued the lead paint ban, (which was notkept
secret like this on) here is
some history....

http://i634.photobucket.com/albums/uu61/neoliticman/LeadPaintChart.jpg

Either there's a typo in the 1962 category or I need to go back to basic math class.

[nEighter]

Not sure if you guys know who PCI magazine is.. but they are like a magazine that talks about components of paint.. the chemicals and compounds that make up the paint. I asked them about 2 months ago about why they have not done a story on the RRP. I got this back from them today:



http://www.pcimag.com/ < check out the magazine online here

haha!!! Woot!

http://www.pcimag.com/Articles/Breaking_News/BNP_GUID_9-5-2006_A_10000000000000809538

[neolitic]

http://jlc-media.com/portal/wts/ccmcBDcx4baqit-8aRmFq6iQgcAkf

[Bodger]

http://jlc-media.com/portal/wts/ccmcBDcx4baqit-8aRmFq6iQgcAkf


$59K vs. $6500. That's a lot to have to sell to an HO. Hell, if the guy is only half right, that's a lot to sell.

I don't see how we are supposed to sleep at night after doing a few dozen pre-78 homes. Seems like a lot of lit fuses to me.

[WarnerConstInc.]

http://jlc-media.com/portal/wts/ccmcBDcx4baqit-8aRmFq6iQgcAkf

Dang, they are souting off some big numbers there.:laugh3:

[Leo G]

They are saying by putting on the Tyvek suit you are cutting your daily 8 hour production which is normally 6 hours down to 2 hours.

I think that is a bit extreme. I think cutting it down to 4.5 hours would be more realistic. But I have never worn one, so I can't say for sure.

[Bodger]

Dang, they are spouting off some big numbers there.:laugh3:


Yeah, and they probably aren't far off if everything gets done by the book and documented.
Further proof that the EPA doesn't have any idea how this actually gets done, who is affected by it and how. I've sen some giant C/Fs come out of the government in my day, but this is one for the record.

Not to mention the fact that I'd bet not 5% of the contractors that this applies to have done a damn thing to get certified yet.

[neolitic]

I don't think those guys have
any better grip on this than we do.
They're just stabing in the dark too.
Just thought it interesting to see
how others are talking about it.
The threads at CT seem to be dissolving
into political polemics.

[Eieio]

I don't think those guys have
any better grip on this than we do.
They're just stabing in the dark too.
Just thought it interesting to see
how others are talking about it.
The threads at CT seem to be disolving
into political polemics.


I agree 100% with you Neo. funny enough I don't think any of them has done a RRP job to date..

[Bodger]

I don't think those guys have
any better grip on this than we do.
They're just stabing in the dark too.
Just thought it interesting to see
how others are talking about it.
The threads at CT seem to be disolving
into political polemics.

I know, I've lurked and read few a times. And some of you guys call ME an RRP whiner! :grin::grin:


Dang you Neo...I had to hit Dictionary.Com and look up the word polemics.

[neolitic]

I should have looked up dissolve! http://i634.photobucket.com/albums/uu61/neoliticman/smilie/smilielaughing.gif

I hate this lap top key board.
I hope Kiddo has repaired and
recovered my old lumbering beast soon.

[neolitic]

http://www.andersenwindows.com/servlet/Satellite/Builders/Page/Builders_Detail/1271070138949?adsrc=PV0510_Lead

http://rm-media.com/portal/wts/ccmcm0cygCaqiuquaRsbD6iQmzuUc

[Dean CRCNA]

HR 5177
Delay certain final rules of RRP

http://www.govtrack.us/congress/bill...bill=h111-5177

[neolitic]

HR 5177
Delay certain final rules of RRP

http://www.govtrack.us/congress/bill...bill=h111-5177

Broken link......

[afkama]

http://www.scribd.com/doc/30928321/U-S-House-H-R-5177-via-MyGov365-com

[nEighter]

so what is that good for? a couple months then?

[Leo G]

July 5th I think.

[Bodger]

July 5th I think.

What year.

[Leo G]

1862


This year wise ars.

[orson]

JLC thread was an interesting read.

As with most information with this rule the end result is just confusion.

I have no idea how I'm going to tackle compliance and what work practices I'm going to implement.

Sometimes it makes me want to crawl in a hole and stay there. :surrender:

The one clearly useful thing I got out of it was this: http://www.demobags.com/default.aspx

[neolitic]

http://www.dealer.org/files/EPA_Delay_Announcement_6_18_10.pdf

There still seems to be
a bit of ambiguity here....

[RCP]

http://www.dealer.org/files/EPA_Delay_Announcement_6_18_10.pdf

There still seems to be
a bit of ambiguity here....

Ya think! What a joke, they are going to delay enforcement, those poor squads of Enforcement Officers, what will they do now?:rolleyes3:

[neolitic]

Like as if there were any
"enforcement squads" anyway.

[neolitic]

If I'm reading that right,
they want you to use the RRP
guidelines for the work, but
they aren't going to bust you
for not taking the classes yet.

[Bodger]

Top notch enforcement, that's all there is to it.