EIEIO
April 8th, 2010, 03:35 PM
Surprise, Surprise. More Unanticipated Consequences of the RRP
By: Shawn McCadden
By now, most remodelers are selling work that will not commence until after April 22, the start date for the EPA’s RRP rule (Lead: Renovation, Repair, and Painting). If this is true for you, be sure to include the RRP’s additional costs – more documentation, extra materials, additional time requirements – in your estimated direct costs and your marked-up selling prices. These costs will be highest during the transition but will level out and become predictable as you gain experience.
As the RRP draws closer, every week seems to reveal additional considerations for remodelers and other industry stakeholders, including homeowners, inspectors, and local governments.
Inspector Eye-Openers
Last week, for instance, I attended a meeting of the Massachusetts Federation of Building Inspectors. Three EPA officials from the Boston area were there, as were two representatives from the Massachusetts Department of Occupational Safety. James Bryson, EPA’s RRP coordinator for Region 1, gave a brief overview of the rule, and it was clear that many of the building inspectors in attendance were hearing about the rule for the first time. They seemed taken back by its realities and likely impact on their jobs as inspectors and their budgets.
So then I gave the inspectors something else to think about.
How, I asked, would they handle on-site inspections while projects are in containment and potentially hot with lead? Would they be willing to put on the white suits and booties before entering the posted work areas, and would they Hepa-Vac themselves clean before they left? And did they know that they would need to bring their own white suits and booties, as remodelers wouldn’t want to risk providing them due to the potential for liability in the case of “costume failure”?
Quite a buzz of conversation followed. Most inspectors indicated they would not enter a contained area and would likely require proof of cleaning and cleaning verification prior to inspecting pre-1978 properties going forward.
If this ends up being the case, remodelers, plan to beef up your estimates (and adjust your schedules) to include multiple clean-up and containment setups.
More at Remodeling Online (http://www.remodeling.hw.net/blogs/postdetails.aspx?BlogId=shawnmccadden&PostId=93759)
By: Shawn McCadden
By now, most remodelers are selling work that will not commence until after April 22, the start date for the EPA’s RRP rule (Lead: Renovation, Repair, and Painting). If this is true for you, be sure to include the RRP’s additional costs – more documentation, extra materials, additional time requirements – in your estimated direct costs and your marked-up selling prices. These costs will be highest during the transition but will level out and become predictable as you gain experience.
As the RRP draws closer, every week seems to reveal additional considerations for remodelers and other industry stakeholders, including homeowners, inspectors, and local governments.
Inspector Eye-Openers
Last week, for instance, I attended a meeting of the Massachusetts Federation of Building Inspectors. Three EPA officials from the Boston area were there, as were two representatives from the Massachusetts Department of Occupational Safety. James Bryson, EPA’s RRP coordinator for Region 1, gave a brief overview of the rule, and it was clear that many of the building inspectors in attendance were hearing about the rule for the first time. They seemed taken back by its realities and likely impact on their jobs as inspectors and their budgets.
So then I gave the inspectors something else to think about.
How, I asked, would they handle on-site inspections while projects are in containment and potentially hot with lead? Would they be willing to put on the white suits and booties before entering the posted work areas, and would they Hepa-Vac themselves clean before they left? And did they know that they would need to bring their own white suits and booties, as remodelers wouldn’t want to risk providing them due to the potential for liability in the case of “costume failure”?
Quite a buzz of conversation followed. Most inspectors indicated they would not enter a contained area and would likely require proof of cleaning and cleaning verification prior to inspecting pre-1978 properties going forward.
If this ends up being the case, remodelers, plan to beef up your estimates (and adjust your schedules) to include multiple clean-up and containment setups.
More at Remodeling Online (http://www.remodeling.hw.net/blogs/postdetails.aspx?BlogId=shawnmccadden&PostId=93759)