Question:
I am a small painting contractor and want to take the lead workshop being offered by the city of San Diego. They say I need to register my company with the EPA RRP before taking the class. Can you tell me what I should do first? Thanks Jim

 

Thanks for your message.   You are in a tough spot.  It might not make you feel any better, but you are in the majority of contractors who have been blindsided by this new rule.

You can do either first.  You do not need to be a EPA Certified Renovator before applying for Firm Certification.  Firm applications can take up to 90 days to process and, according to the rule,  starting April 22^nd you are not supposed to offer, sell or perform work on homes build prior to 1978 unless you are a certified firm.

Here is what I suggest:

• 1. Go to the EPA RRP Info page on my website and find the link to download the firm application. Fill it out and send it in ASAP along with the required $300.00 fee.
• 2. Take your Certified Renovator class as soon as possible.
• 3. Request and download the RRP Summary I offer on the EPA RRP Info page of my website. This will give you a good overview of what you will need to be aware of and consider.
• 4. Down load and read the EPA Brochure titled; Small Entity Compliance Guided to Renovate Right.  Read the guide from cover to cover.   It is a great summary and will give you a big picture understanding of the rule and how it will affect your work and your business practices. 
• 5. Read the actual rule; including the amendments and the preamble. This too is available as a link on the EPA RRP Info page of my website
• 6. In addition to the work practices, you will need to understand the new business responsibilities and how they will affect your business practices; including sales, contracts, estimating, scheduling and subcontractor relationships, just to name a few.
• 7. Make a list, get the help you need for the things you cannot do or get yourself, and start working your list.
• 8. If you have a headache already, take a few Advils now...

I hope this helps.  Keep checking back on this site.  I am continuously adding new info as I find it.   Be careful where or who you get your info from.  There is a lot of mis-information going around out there.

Understanding the costs associated with EPA RRP work will help you price this work to keep it as profitable as non-RRP work. Costs usually include job-specific materials, labor, and general supplies (like poly and tape) that may or may not be assigned to a particular job. It's important to job cost for several reasons. First, you want to be sure you're not just making money, but making enough money to cover the costs of that job, plus that job's fair share of overhead, plus that job's fair share of profit. Can you really afford to accept a lower profit margin on RRP jobs? What are the implications for your overall profit if this happens? What about profit-sharing? If your profit-sharing or bonus plan depends (as it should) on achieved gross margins, is it fair to under price RRP jobs and then pass along your loss in the form of reduced profit sharing? If you have one lead carpenter who's your certified renovator, supervising RRP jobs is going to take up most of his time. Should his profit-sharing or bonus be reduced because of this? So be sure that you price your RRP jobs according to a plan in which the true costs in materials and labor are represented. If you do, your achieved gross margin shouldn't suffer as a result of your decision to work on RRP projects.

Note:  This information was contributed by Melanie Hodgdon of Business Systems Management.

Contractors who have made the decision to embrace the new EPA RRP Rule requirements can gain two benefits from creating a system to track time required to perform EPA RRP-related tasks.

First, to price a job, it's important to understand the difference (as measured by employee labor hours) between replacing a window on an RRP Rule job compared with replacing a similar window on a non-RRP Rule job. For example, requiring workers to log time spent on RRP-specific activities such as setup (including taping), removal, and cleanup (including disposal and testing) will provide valuable information for estimating and pricing purposes,

Second, collecting information on time spent on RRP Rule-related tasks can help prove that the right personnel were present at the right time on an RRP targeted project. Other than running a webcam at the jobsite (a potential can of worms!), what better way to prove that your certified renovator was present to supervise during designated times than by providing an auditor with time-based reports designed to demonstrate your compliance?

The challenge will be to set up your time tracking system so it's easy to use and (more importantly) will easily generate the reports that will support you in the face of an audit. The EPA isn't going to hang out at your jobsite; if they go after you, they'll get you in your office. The more detailed and compelling the reports you provide, the more competent and professional you'll look. The more professional you look, the less likely they'll be to nitpick.

Note:  This information was contributed by Melanie Hodgdon of Business Systems Management.

Despite the fact that the EPA passed the RRP lead-safe practices law back in 2008, the word didn't get out very effectively. As a result, the EPA RRP Rule caught many contractors unprepared and scrambling to get themselves certified by the April 22, 2010 deadline. Many companies are focusing on compliance (pamphlet acquisition and distribution, company certification, RRP training, acquisition of dust containment materials and HEPA Vacs), but fewer have thought about how the new law may affect daily practices. For example, a company that's not using daily time cards may find it difficult to quantify changes in the amount of time required to complete work according to the RRP regulations. Failure to understand exactly how much additional time it might take a crew to perform a task can lead to underestimating. Underestimating can lead to under pricing. Under pricing can lead to a cash flow crisis in an already challenging economy. Consistent under pricing can lead to financial failure. On the other hand, documenting time spent on a job (particularly those blocks of time associated with RRP compliance) can not only help with estimating future jobs, but provide a CYA support system.

Note:  This information was contributed by Melanie Hodgdon of Business Systems Management.