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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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RRP Rule Could Be A Ticking Time Bomb For Many Contractors

Posted by Shawn McCadden on Sun, Dec 12, 2010 @ 11:35 AM
  
  
  
  
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RRP Rule Could Be A Ticking Time Bomb For Many Contractors:

RRP Time bombThe New Renovation Repair and Painting Rule could likely be a ticking time bomb for many renovators who are ignorant of, intentionally ignoring and or not following all of the many requirements of the rule.   The reason I say this is because of the documentation and record keeping requirements of the RRP Rule.  Renovators should keep in mind that under the rule the required documentation for each RRP project must be stored and made available for inspection for up to 3 years after the completion of the project. The EPA and or states that have taken over administration and enforcement of the rule won’t be limited to finding active violations of the rule on jobsites.  They will also be able to use the required documentation to determine whether renovators were complying with the rule on all projects completed in the three years preceding an inspection.   Check out this list of six ways non-compliance and a lack of documentation could affect your business

RRP ComplianceI had a conversation with one remodeler about the serious risks non-compliance can have for a renovator’s business.  His opinion was that the risk of being caught was dependent on “how legal” the remodeler is in the way he/she operates the business.  My opinion is that being legal is not measured on any kind of graduated scale.   You are either operating the business legally or you are not.   I think both EPA and OSHA agree with this logic. 

In regards to RRP and OSHA compliance, either organization has the absolute ability to decide that you are in compliance or not.   If you are not in compliance you are guilty and subject to fines for all violations.   One saving grace, for those who are trying to be legal but may not be all the way there yet, is the fact that EPA has provided its enforcement officers with guidelines to determine fine amounts.  The Consolidated Enforcement Response and Penalty Policy (ERPP) sets forth guidance for EPA officials to use in determining the appropriate enforcement response and penalty amounts for violations resulting from failure or refusal to comply.  OSHA has similar guidelines for their field inspectors.

If you are looking for forms and signage to help you with comply with the EPA RRP rule, I recommend you check out what The Lead Paint Forms Store has to offer.   They offer a complete assortment of multi-part carbon forms, signage and checklists to assist you and your employees with RRP compliance

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Comments

Friday I coming back from an inspection and noticed a prominent contractors trucks (3) parked around a window job in progress. Snow was coming later so he had 3 crews tearing out and replacing double hung windows in a home built before 1940. Now this company is an active member of NARI and NAHB, I have seen them at meetings, the owner was on the board of directors for one of the groups. There was no eveidence of RRP compliance, this was a full tearout of old windows, including the trims and casings. They were scrambling to get it done before the bad weather hit and this parrt I understand, but the non compliance and especially from a prominent and well respected business makes me wonder if enforcement will cover all companies, not just the luckless individuals who get caught. Our industry is too far apart to have this rule be equitable, and that's one of the problems, the other problem is that even many of the good guys think this rule is skewered. We have a long way toi go before having the RRP rule taken seriously. Paul Lesieur
Posted @ Sunday, December 12, 2010 2:32 PM by Paul Lesieur
BOOM! 
 
Headline in the your local newspaper two years from now on 12/15/2012;  
 
Local Contractor Fined By EPA For RRP Violations:  
 
A local contractor was just fined $37,500 last month for a kitchen and addition renovation project completed in December of 2010. 
 
The EPA RRP Lead Law went into effect on 4/22/2010. In the law the EPA ingeniously installed a documentation requirement that required contractors to maintain and keep records for three years. This EPA requirement allows the agency to go back and enforce the regulation retroactively for three years. The contractor must keep records of practices he used to comply with the law and he must show proof that he gave the homeowner a Renovate Right Brochure that is designed to educate the homeowner about the dangers of lead and the practices that are required.  
 
The contractor, John Smith of ABC Kitchens in Anytown, USA did not have the required documentation. In this case the EPA assumed he did not use lead safe practices even though in our interview with him he told us he did. 
 
John Doe from the EPA said "that when the law came out we didn't have the ability to enforce due to budget constraints and manpower. However due to the documentaion requirement we can go back up to three years to make sure contractors were in compliance. If they have no documentation it is obvious that they did not comply with the regulation. Now that we have consistent funding and more people to enforce we will be able to catch up with contractors who thought they could get away with not complying two years ago. We owe this to contractors who certified their companies, trained their employees and followed the law in 2010. We only wish we could have done more sooner."  
 
 
 
Your local reporter 12/15/2010
Posted @ Sunday, December 12, 2010 2:57 PM by mark the coach
Tough to think that the EPA and OSHA will come down on small business people up to 3 years after the fact to enforce rules that often are overkill and misleading.  
 
Many small business people already feel victim to the federal government. If the federal government goes totally Republican in 2012 do you really think it will come back to small business people on work done in 2010 or 2011? Paul is more on track with reality than the second poster.
Posted @ Sunday, December 12, 2010 3:53 PM by Totally compliant
I hope they consider re-writing the law to clear a lot of things up. If republicans takeover maybe we will have a more business friendly environment. However, is it worth taking the risk? I met the EPA in their office in Boston with Shawn and they said this possibility can occur. So for now I would not want to take the chance that the EPA after taking two more years of criticism they may utilize the documentation mechanism written into the law.
Posted @ Sunday, December 12, 2010 4:10 PM by mark the coach
Paul, I find it very disappointing that a NARI member, a previous board member at that, is operating illegally and putting both his employees and his customers at risk to lead exposure. Of course both your and my assumption is that there was lead at the job site or it was not tested to prove otherwise. Not knowing if the jobsite was tested does make assuming he was in violation risky. Perhaps a good way to deal with such uncertainty would be to include RRP requirements on building permit applications so the public can view them to know whether the lead-safe work practice should be required or not.
Posted @ Monday, December 13, 2010 8:10 AM by Shawn McCadden
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