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Eieio
March 15th, 2010, 06:59 PM
Shawn McCadden

On the RRP, Practice BEFORE the Game!



What would your clients think if they knew you were practicing lead-safe remodeling for the first time on their home?

Assuming that implementation of the EPA’s RRP (Lead: Renovation, Repair, and Painting) rule is not delayed, you must begin using lead-safe work practices on pre-1978 homes starting April 22. I know of only a few remodelers that have actually tried the work practices required under the rule.

If you’re among the vast majority of remodelers who have not practiced the required work practices, most likely you’ll be using the WAG (wild-ass guess) method come April 22. As a result, you’ll be subjecting your business to serious risks and many liabilities. I suggest you ask yourself these questions now:

*How will you build accurate RRP-related costs into estimates for work that you sell now but complete after the law takes effect?

*How will you know that your field employees really learned what to do and how to do it at the RRP training? Did they pay attention in class? Was the instructor effective?

*How will you placate homeowners who are alarmed at watching your employees, donned in white suits, “practicing” new skills for the first time at their home? What about the neighbors who see the caution tape and lead-hazard signs surrounding an exterior project?

*Will you be confident that your employees will Hepa-vac themselves clean every time they leave the work area?

*Will the tape you bought to fasten the plastic to the wall actually keep the plastic in place so no dust falls behind it or migrates into adjacent rooms?

*In doing exterior work, will your employees effectively contain dust or debris to protect the shrubs, flowers, and mulch surrounding your clients’ homes?

*Is your staff prepared to deal with contaminated water pooling on exterior containment plastic as a result of spring rainstorms?

*Can your staff clean effectively enough to then verify their work? Will they know how to document their methods and results?

More at Remodeling online (http://www.remodeling.hw.net/blogs/postdetails.aspx?BlogId=shawnmccadden&PostId=93298)

Bodger
March 15th, 2010, 07:15 PM
I'm guessing maybe 10% of the contractors with the proper certification will pull this off to actually meet the standards. Especially those who leave the usual troop of morons to do the work.

The lawyers are going to have a field day with this in a couple of years. I wonder how many HOs are going to get their homes tested right after the contractor is finished but not yet fully paid, and if lead is found, forget about the final payment.

Then stand by for BOHICA and Associates LLP.

Containing lead dust run-off in a rainstorm on exterior work? Give me a break.
I might just build cabinets from here on out and chuck this nonsense altogether.
Guaranteed, sued or fined or both eventually.

SLS-Construction
March 15th, 2010, 07:22 PM
Well if he needs the practice, doesn't know how his employees act when he isn't around, etc... maybe he should quit and become a consultant - oh wait, my bad, he is one

So if I read this right, I should practice for free on an existing clients house where I didn't plan for this, instead of someone's house where I planned for and "SWAG"ed it?

Oh & my guys won't look like there was an anthrax scare at the house, unless we are doing plaster demo - but that's just normal

Eieio
March 15th, 2010, 07:26 PM
Eventually every company and their guys will have to try out these methods and get a game plan intact to handle the RRP Rule.

So I am assuming he is trying to prepare his company for game day.

I actually like the idea of a practice run(s) and have tried it myself a few times.. I have Job that will start before the April 22nd deadline and plan again to give a run through to see what works and what needs to be modified..

I think its a good idea..

Century Man
March 15th, 2010, 07:55 PM
I recently sold a window job and asked the homeowner if we could use her job as our test model. She readily agreed and we will do our measure and lead test this Wednesday and in 2 weeks have an install using the procedures outlined in the RRP rule.

SLS-Construction
March 15th, 2010, 07:56 PM
Fair enough Rory - here was my .02 I added to his blog posting

So let me get this straight - I should practice for free on a house before April, instead of simply following the regulation on a house that I budgeted for?

I should wonder if my employees listened in class, or will follow directions - nope, they know better & even though I trust them, I still will verify it (and not in a practice session with me there)

Might I suggest instead that you have a refresher class with all the CLR's on your staff to make sure everyone is one the same page --- How about during that meeting you create a "Toolbox" meeting paper with all the lessons required for training your regular employees that they (the employees) can sign off on for "compliance"

The moon suits - are you sure you read and understood the EPA REGULATION? Do you know the OSHA regulations? There are very few times when a moon suit would even possibly be required to be worn.

Speaking of the regulation - you might be careful with which version you are reading - the one on the EPA site is outdated & marked with a spider web which means "Note: EPA no longer updates this information, but it may be useful as a reference or resource." --- The correct version which they point you to is on the E-CFR site

Paperwork - employees or owners don't fill it out --- it is the assigned CLR that is responsible & I would make sure whomever that is understands it & can fill it out properly

Define the scope so you don't get blamed? Yeah good luck with that... The only thing that really needs to be beefed up in most contracts is that by EPA or State regulation that the HO, pets, friends, etc... are not allowed past the tape / barriers into this area until it has passed the cleaning verification stage.

Dusty
March 16th, 2010, 02:03 AM
Just curious. How many of you have your real estate and valuables hidden away in a Trust or another form of asset protection?

PA Woodbutcher
March 16th, 2010, 07:27 AM
I'm currently working on a house built in 1892 and am "practicing":laugh3:

Scheduled to take the CR course next month, but amtrying to be as clean as possible and using the little tidbits that I have picked up here as a base.

Documentation will be a whole new ballgame though.