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

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RRP Rule Could Be A Ticking Time Bomb For Many Contractors

Posted by Shawn McCadden on Sun, Dec 12, 2010 @ 12:35 PM

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

Topics: EPA RRP Lead Rules, OSHA Considerations, Legal Considerations, Documentation Considerations, Enforcement and Inspections