EPA RRP Questions Answered

Everyone still has a lot of questions about implementing the new EPA RRP (Renovate, Repair, and Painting) lead rules. We’re trying to help you find the answers.

Mark Paskell of the Contractor Coaching Partnership provided us with a PDF of the EPA’s most recent answers to contractor questions, as of March 18, 2010. Here is a link to the PDF file.

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2 Responses to “EPA RRP Questions Answered”


  1. 1 Bill Wine March 11, 2011 at 8:53 am

    Mark,

    Below is a letter that I’ve sent to all 100 US senators regarding this idiotic money grubbing power grab on behalf of the EPA to “protect the children”.

    Bill Wine/
    Historic Restorations

    Letter:

    Senator,

    As a professional remodeler in the business for over thirty years, I am shocked at the passage of the RRP rule by the EPA.

    Background in a nutshell: The EPA has issued a rule, effective April 22, 2010 that requires only EPA trained & certified professionals to perform work on the nations pre-1978 homes. Anyone caught in violation of this rule will be fined $37,000.00 per day per occurrence. Although many professionals have been trained and certified thus far, most are STILL unwilling to subject themselves to these debilitating fines imposed by the EPA for even the slightest infraction.

    Personally, I am outraged about these new regulations and likewise I am deeply concerned about the future of my career.

    I’m all for “playing it safe” when it comes to dangerous material, but this is nothing but legalized extortion on the part of the Federal Government.

    I took a class to obtain my EPA certification for “lead-safe” practices. But many other business owners and remodelers who attended this class stated they would steer clear of the pre-1978 buildings, just as a precaution. Running the risk of being penalized by fines this debilitating is very intimidating and simply not worth the hassle. This comes at a time when remodelers are clamoring for what little work there is just to provide for their families. And our dear president has the audacity to proclaim the number of “green” jobs he’s creating to make homes more energy efficient, while the EPA lies in wait for a contractor to jump on this perceived opportunity.

    My own business has been struggling to survive this recession. With these new rules in place, it’s better for me to close up shop for good to find another line of work altogether.

    I think it is an outrage that our government would turn against it’s own people and use lead, asbestos or any other man-made material as a means to extort money from its citizens. If the EPA is so concerned about this issue, then why aren’t THEY cleaning up the lead and other hazardous material from our homes and businesses?

    Homeowners of pre-1978 homes are just now beginning to grasp what this means for them in regards to costs of repair & maintenance, not to mention loss of property values as they attempt to market a home that is registered with the EPA as contaminated by lead.

    As of now, several professionals in this industry are circumventing this issue by several means: One is to completely avoid homes that are considered “target” housing. (1978 and older) Another is telling homeowners that they need to perform all of the demolition & removal of contaminated material from the jobsite before they (the remodeler) will come into the picture. Another is performing the work without any building permit so as not to raise any suspicion regarding the work performed. This is only the beginning.

    All of these scenarios will only subject MORE people to the hazards of lead dust, not less. This whole RRP fiasco will only cause the opposite of their stated goals.

    I’m personally telling my clients to perform the demo themselves, so they’ll end up saving thousands of dollars in labor and documentation costs and thus avoid having their home registered as a contaminated site.

    Over time, homebuyers will opt to purchase only homes built after 1978, to avoid all of the unnecessary headaches of the pre-1978 homes, thus rendering the latter homes near worthless. This will be great news for downtown historic districts that are already suffering from the ills of long-term neglect, coupled with this lackluster economy.

    My gripe with you and other “representatives” is that you have failed to represent those of us who make up this industry that is vital to our nations economy and recovery. You have failed to represent the best interest of homeowners whose homes are built in 1978 and older. (The value of our real estate is probably more important than the price of gold) You have also failed the women & children whom this rule is aimed to protect due to the fact that run-down apartments and inner city housing will continue to deteriorate all across this country due to the fact that no serious & professional contractor will be willing to risk bankruptcy to work on these older properties. Thus raising the lead exposure levels on those who need the most protection from this hazardous dust.

    Historic preservation is rapidly becoming a thing of the past.

    I, like many others in my field, will abandon my past profession for something new.

    I hope you take this as a dose of reality, it’s been my reality since this all started.

    Bill Wine/
    Historic Restorations
    Woodstock, Virginia

    Phone: 540-459-8455

  2. 2 Bill Wine March 11, 2011 at 9:02 am

    Mark,

    I’ve read some of your answers on the PDF file. You’re doing everyone an injustice by stating that compliance costs are as follows:

    EPA estimates that the costs of containment, cleaning, and cleaning verification will range from
    $8 to $167 per job, with the exception of those exterior jobs where vertical containment would
    be required.
    In addition to work practice costs, your costs will include training fees, certification fees,
    equipment costs, and labor costs. The costs include:
    • Training costs to individual renovators working in pre-1978 housing or child-occupied
    facilities who must take a course from an accredited training provider (cost is set by the
    training provider; estimated to be about $200 for a 5-year certification).
    • Certification costs to firms to obtain certification from EPA ($300 fee to the U.S.
    Treasury for a 5-year certification. This fee is required by law to cover program
    administration).
    • Costs of equipment (for example, plastic sheeting, tape, HEPA vacuums and tool shrouds
    – the equipment varies by job).
    • Costs of labor (for example, the time required to perform cleaning and cleaning
    verification).

    If you know anyone who is willing to do the above for the dollar amount stated, please send them to me! Then again, I may be in violation of labor laws and minimum wage requirements.

    I’m certain you’ll not respond to me, as I am taking a stand for common sense and for property rights!


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