Read this Johnny-RRP compliance field tested by Cape Cod Remodeler-

Watch out for lead
Watch out for lead

By John Clark Cape Cod Kitchen and Bath

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 6×8 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.

Editors opinion:

This will add time and costs to target housing home improvements. How much depends on the job and I have read 1% increase by one company owner and up to 15% cost increase by an professional abatement contractor.

It will depend on the job. One thing we do know for sure is that homeowners strapped for cash will be averse to it and that the vast majority of contractors nationwide will not be ready, many will not comply at all.

Loan officers, realtors and other associates are mostly uninformed of the EPA rule and its not mentioned to homeowners at any of the Big Box stores.

Be ready for some suspicion and anger  when you explain this to the average homeowner, if you send them to the EPA site it will say EPA testing determined added costs would be $35 per job, when you say you need $500 or $5000 more depending on the scope of work its your number against the EPA number. This will provide some interesting exchanges at first.

Good luck my brothers and sisters and may the force be with you.

Paul Lesieur/ Remodel Crazy


  1. Thanks Paul. This is a helpful account of the new rules in action!

    Our company is prepping for LEAD certification shortly. While we want to comply with any mandated licensing and safety laws, I agree with your conclusions that many if not most homeowners will try to get around them by hiring an uncertified contractor. We see it all the time in our market, Philadelphia. I even get calls from buyers who want us to skip permits or similar. Imagine!

    The only way to avoid this is with enforcement from the city and state. Personally I will be putting my phone on speed dial to our local L&I to report noncompliant projects I may see when I am driving around to our many projects. I hope other compliant contractors do to.

    We have seen that when the city and real estate agents get behind efficiency standards for city sale homes, the market is interested in these “cafe’ standard” properties. They will even pay a little more for a home thats safer and cheaper to run.

    The same can happen for lead safety standards and licensing IF the state, professionals like realtors and big box outlets, city etc. all support these new standards we are meant to comply with.

    Keep sending these tales from the front lines and thanks again.

    • Hello Diane and nice to see your still around and offering your opinion.

      At the least the lead rule will be a challenge. Its already proven to be a divisive subject.

      The reporting of non compliant contractors is tricky business and something that should be discussed as a group, my feelings about that are too strong to see clear on whether I can do that or not.

      Last night I talked to a friend from the Remodelers Council, his daughter and mine are best friends, he also said he will not comply, citing government bull**** and blah, blah. I couldn’t turn this guy in, so how could I turn in JoeBob who I don’t know and not turn in JimBob who I do know.

      I don’t like having this as a choice.

  2. Nowhere in the rule does EPA require suits, much less any particular type. That’s OSHA’s domain.

    Further, “tile” unless painted, does not constitute a “painted surface” and would not be part of this rule either.

    Who taught your class?


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