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This DVD, produced by Chris Zorzy, contains great time saving solutions for complying with the RRP Rule.   Chris shares a variety of containment strategies that will help keep your jobsites clean, reduce job costs and meet RRP requirements

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Shawn has reviewed these forms, helped the provider enhance the forms and recommends them as a great option for those who want to use paper forms to document compliance with the EPA RRP rule.

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Shawn McCadden has created an EPA RRP Summary for Remodelers.

"Hi Shawn, Nice RRP write up on the website.   I've already forwarded a link to it to a number of local builder types."  

Click here to go to the summary.  You can also download it if you want your own copy.

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Welcome to RRPedia
Your Interactive Resource for EPA RRP Information

Looking for accurate information about the EPA RRP rule?

RRPedia RRPedia logohas been created by Shawn McCadden to help remodelers and others affected by the New EPA Renovation Repair and Painting Rule. 

Please read RRPedia Use and Contribution Information before using or contributing to RRPedia

Be sure to Read Shawn's Remodeling Magazine Blogs about the EPA RRP Rule.  Click here to see a list

Keep checking back.  Information about a wide range of RRP-related topics will continue to be added. 

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EPA Softens stance on Firm Certification to allow work to continue

Posted by Shawn McCadden on Fri, Apr 23, 2010 @ 02:26 PM
  
  
  
  
Add to delicious  delicious  
  

Please read RRPedia Use and Contribution Information before using or contributing to RRPedia

In a letter dated 4/20/2010, the EPA announced that it does not intend to take enforcement actions against firms who applied for the required firm certification before April 22, 2010 and are just waiting for their paperwork.  

EPA RRP Firm LogoThe RRP Rule requires that firms be certified with the EPA before offering or performing work that falls under the rule.  This fact is clearly stated in the rule and further explained in the FAQ section of the EPA website.   The rule also says that the EPA has up to 90 days to process firm applications.  Apparently, even though many businesses will be required to follow the RRP rule in its entirety, the EPA can decide which part(s) of the rule they will follow, or not.  In the letter, the EPA justifies not following the requirements of the RRP Rule in regards to the firm certification requirement as follows:

"The certification requirement is important to making sure that firms are protecting children and other residents while renovations are ongoing, but EPA does not wish to disrupt ongoing renovations for those firms that submitted applications on time."

The letter indicates that EPA expects to review all firm applications filed by April 22nd by June, although they did not specify by when in June.  

The letter also makes it clear that the EPA will be enforcing theContractor confused about EPA RRP Rule changes work practices and training requirements.

Click here to see which companies in your area are on the EPA's certified firms list  

On another note, the EPA did announce that the opt-out provision would be phased out and that it is proposing to add third party dust wipe testing.  The change in the rule regarding the opt-out will become effective 60 days after publication in the Federal Register.  Click here for more on the opt-out and the proposed dust-wipe testing.

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Comments

Great Site Shawn. Had it not been for Hammer Magazines coverage on the issue - I would not have been aware and certified in time. I appreciate Hammer having passed along your site as well. All the best!
Posted @ Saturday, April 24, 2010 5:50 AM by Debbie
Thanks for organizing and maintaining this website, Shawn. It is a great resource. 
 
So as of 4/26/10, it seems thatL 1) MA has taken over the admin. of the EPA RRP program in MA, 2) the "opt-out" clause is still available but will be "phased out" (no one knows when yet), and 3) we CAN use lead test swabs to self-observe for the presence of lead AND we do not have to report a positive result to the State. 
 
Have I got this correct? Thanks.
Posted @ Monday, April 26, 2010 8:14 AM by Jonathan
Jonathan, 
 
You are not correct. MA has not taken over administration of the rule. They have published emergency regulations to the central register, but have to certify with the EPA before taking over administration. In addition, there is a 90-day period when the public can comment on the law. If it is not finalized after 90 days, the law expires and then the state has to start the process over.  
 
At this point I would act as if the opt-out does not exist, but I would be interested in Shawn's point of view on that issue. 
 
You are right about #3. Contractors can currently do their own cleaning verification.
Posted @ Monday, April 26, 2010 9:25 AM by Andrea Goldman
Andrea, thanks for the clarification. I am not clear on #3. Yes, I understand that certified contractors with certified field staff can do their own cleaning verification. But can certified staff also perform the lead test swabs to determine if lead is present before work begins to verify it lead safe practices need to be followed?
Posted @ Monday, April 26, 2010 9:48 AM by Jonathan
 
 
Jonathan: 
 
As Andrea indicated, MA has not taken over administration or enforcement of the RRP, yet. For the latest on what I have been able to find out about that check out the "MA RRP Updates" tag on this page and read the 4/21/10 post. I will post more info on this topic as I get it. 
 
It is my understanding that the opt-out will be phased out 60 days after it is posted to the Federal Register. 
 
Yes, a certified renovator can use EPA approved test kits to test for lead. The info does not have to be sent to the state, but you do have to give any results of that testing to the person who contracted for the renovation within 30 days of the completion of the renovation. 
 
Posted @ Monday, April 26, 2010 10:15 AM by Shawn McCadden
Do even the one man companies have to register as a firm with the EPA ?
Posted @ Tuesday, April 27, 2010 9:00 AM by David
Yes David, there are no exceptions.
Posted @ Tuesday, April 27, 2010 9:31 AM by Andrea Goldman
David: There actually is an exception. All companies do not need to be certified firms. If you are a subcontractor, working for and being paid by a certified firm, you do not need to be a certified firm. If you offer to contract services other than to a certified firm, you do need to be a certified firm. I hope this helps.  
 
Posted @ Tuesday, April 27, 2010 10:04 AM by Shawn McCadden
Shawn is absolutely right. If you are the GC, you have to be certified as a firm. If you are doing the work, you have to be a certified renovator, or receive on the job training by a certified renovator for your given task. Just keep reading Shawn's blog. The information is all there.
Posted @ Tuesday, April 27, 2010 6:23 PM by Andrea Goldman
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