--- title: "EPA Report Card: How well are they doing with the RRP Rule?" description: It is almost two years now since the EPA RRP Rule went into effect. I offer my own report card on how I think the EPA has performed so far image: https://www.shawnmccadden.com/hs-fs/file-16118596-jpg/images/report_card-wr.jpg --- [![Shawn McCadden](https://www.shawnmccadden.com/hs-fs/hub/81069/file-1539748069.jpg)](https://www.shawnmccadden.com/) # Welcome to RRPedia Your Interactive Resource for EPA RRP Information ## ![RRPedia logo](https://www.shawnmccadden.com/hs-fs/file-1549005086-jpg/images/RRPedia_Logosmall_-wr-1.jpg)Looking for accurate information about the EPA RRP rule? RRPedia has 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](https://www.shawnmccadden.com/using-and-contributing-to-rrpedia-/) *before using or contributing to RRPedia.   --- # You Can Browse For RRP Topics By Using The Tags List To The Right ## [EPA Report Card: How well are they doing with the RRP Rule?](https://www.shawnmccadden.com/rrpedia/bid/76580/EPA-Report-Card-How-well-are-they-doing-with-the-RRP-Rule) Posted by [Shawn McCadden](https://www.shawnmccadden.com/rrpedia/author/shawn-mccadden) on Sun, Apr 01, 2012 @ 05:00 AM - [Tweet](https://twitter.com/share) ## **EPA Report Card:  How well are they doing with the RRP Rule?** ![Effectiveness of RRP Rule](https://www.shawnmccadden.com/hs-fs/file-16118596-jpg/images/report_card-wr.jpg?width=203&height=135&name=report_card-wr.jpg)   Many news outlets and politicians have been using report card scores to express how well they think people, government policies and regulations are performing.   Several politicians, government employees and even our president have provided their own self assessment scores as well.  It is almost two years now since the EPA RRP Rule went into effect.   I thought I would offer my own report card on how I think the EPA has performed so far in four areas regarding the RRP Rule.  EPA is welcome to offer their own self assessment score.   ### **Subject: Outreach about the rule** EPA has claimed to have done extensive outreach to consumers and the regulated community.  They list a variety of methods used and places where ads and announcements were placed.   **Report Card Score: D-** ![EPA RRP outreach results](https://www.shawnmccadden.com/hs-fs/file-16113947-jpg/images/outreach-wr.jpg?width=168&height=112&name=outreach-wr.jpg)In reality what they have done has not been effective.  Either the message is not effective, the placement is not effective or both.  According to a [survey done by Professional Remodeler magazine](http://www.housingzone.com/codes-and-standards/lead-paint-rules-costing-remodeling-jobs-raising-prices-remodelers-say) 65% of remodelers surveyed estimated that less than 10% of their potential clients are aware of the rule.  Only 5 percent think more than half of homeowners know about it. On a recent webinar with EPA Officials Regarding RRP Public Awareness and Enforcement Efforts hosted by NCHH, I asked EPA officials if they were doing any tracking to check the actual effectiveness of their outreach efforts.  They are not.  Essentially the answer was that EPA is not a professional marketing organization and has no way of tracking results.   But they said they will be doing more outreach… ** ** ### **Subject: Getting Firms Certified** EPA requires all firms doing renovation, repair and painting work on homes built prior to 1978 become EPA Certified Firms before performing or offering to perform such work. **Report Card Score: F** ![Number of EPA certified firms](https://www.shawnmccadden.com/hs-fs/file-16118543-jpg/images/report_card_with_f-wr.jpg?width=204&height=153&name=report_card_with_f-wr.jpg) Before the rule rule came into effect EPA stated; ***"There are approximately 211,000 firms estimated to become certified to engage in renovation, repair, or painting activities."*** As of posting this blog EPA’s web site claims that EPA has certified 97,746 firms (118,885 firms including those approved by authorized states).  According to a [report by the Joint Center for Housing Studies at Harvard University](http://www.jchs.harvard.edu/research/publications/new-decade-growth-remodeling), the most recent government census showed more than 650,000 businesses received a majority of their revenue by providing remodeling services in 2007 and that number does not include the large number of part-time, semi-retired, and “moonlighting” contractors reporting gross revenues of less than $25,000.   I think we also know there are many illegally operating contractors as well that did not make it into the census count.  [![Number of remodeling contractors](https://www.shawnmccadden.com/hs-fs/file-16117710-jpg/images/remodeling_contractors_by_payroll_status-wr.jpg)](http://www.jchs.harvard.edu/research/publications/new-decade-growth-remodeling) Admittedly not all remodeling companies work on pre-1978 homes.  However, there are many other business types other than remodelers who disturb lead paint.  One example is exterminators.  According to [Exterminator.com there are over 20,000 extermination companies in the US](http://www.exterminator.com/companies/).  Others who would need to become certified include landlords, property management firms, banks that own foreclosed properties, housing authorities, cities/towns and municipalities. (According to [Google answers](http://answers.google.com/answers/threadview?id=509183) there are 18,443 cities, towns, villages, and other such governing groups in the United States, not including any island areas other than Puerto Rico) I am sure you could list other business and entity types that would fall under the rule.  My best guess is that EPA has only certified about 10% of the firms that should be certified and has completely misjudge the number of firms affected by this rule. As a side note, I contacted EPA to find out how many workers have become Certified Renovators so far.  I was told they are still trying to decide how to count them… ** ** ### **Subject: Enforcement** There are 12 states that have taken over the rule so far.  That leaves 38 states plus American Samoa, District of Columbia, Guam, US Virgin Islands and Puerto Rico under administration and enforcement by EPA.  **Report Card Score: F** ![RRP Violations](https://www.shawnmccadden.com/hs-fs/file-15724854-jpg/images/1-finger-wr.jpg?width=79&height=120&name=1-finger-wr.jpg)So far EPA has only published one violation since the rule came into effect in April of 2010.  On the other hand the state of Massachusetts took over the rule in July of 2012 and has [published over 20 violation enforcements to date](http://www.mass.gov/lwd/labor-standards/dls/news-articles/enforcement-actions.html). Though not confirmable facts, one commenter on a LinkedIn discussion claimed “there are only 37 Certified Firms in Maui County when there are 1,500+ Licensed Contractors and double to triple unlicensed contractors”. Industry insiders report EPA has been doing RRP investigations.  EPA claims we will hear more about violations and enforcement very soon.   ### **Subject: Protecting children and others from lead poisoning due to renovations**  “The purpose of the Renovation, Repair, and Painting (RRP) Rule is to minimize exposure from lead-based paint dust during renovation, repair, or painting activities. This is a key effort in reducing the prevalence of childhood lead poisoning, particularly lead poisoning caused by housing contaminated by renovation activities. This will also minimize exposure to older children and adults who are also adversely impacted by lead-based paint dust exposure.”  [(From EPA Web site) ](http://toxics.supportportal.com/link/portal/23002/23019/Article/22990/What-is-the-purpose-of-the-Renovation-Repair-and-Painting-RRP-Rule)  **Report Card Score: Incomplete** ![Is RRP effective, is RRP working](https://www.shawnmccadden.com/hs-fs/file-15766584-jpg/images/incomplete_puzzle-wr.jpg?width=159&height=119&name=incomplete_puzzle-wr.jpg)It is a fact that lead is poisonous and RRP activities can cause poisoning. However, EPA does not know how many children were actually poisoned by RRP activities before the rule came into effect.  If you check any of the data it refers to RRP activities as the “likely source” of lead poisoning, not “the cause”.   That being the case, EPA has no way to know if the RRP rule is making a difference or not.  It is ‘likely” that it is helping.  But, without knowing where EPA started and where we are now that the rule has been in place for almost a year, EPA has no idea if what they have been doing is effective enough and or if or where it can improve effectiveness within the rule.  Unfortunately, the rule may also be causing more children to be poisoned than before the rule came into effect, because of EPA's inability to adequately enforce it.  As reported in this [press release](http://www.free-press-release.com/news--lead-the-new-four-letter-word-1325450441.html?goback=.gmp_2090129.gde_2090129_member_103396823), to keep costs down, consumers are hiring non-certified firms to work on their homes and the required lead safe-practices are not being used.  Also, contractors are reporting that some realtors and insurance adjusters are falsely telling consumers that the rule does not apply at their homes based on location and or for the work they are having done.  All of this has fostered an underground economy of contractors taking advantage of purposely ignoring the rule to keep prices down and improve their ability to sell jobs.   **How do you think EPA has been doing with the RRP Rule so far?  Consider using the comment area below to offer your own subjects and report card scores.** ** ** Topics: [Effects of the RRP Rule](https://www.shawnmccadden.com/rrpedia/topic/effects-of-the-rrp-rule), [Statistics](https://www.shawnmccadden.com/rrpedia/topic/statistics), [Opinions from Renovators](https://www.shawnmccadden.com/rrpedia/topic/opinions-from-renovators), [Health Effects of Lead](https://www.shawnmccadden.com/rrpedia/topic/health-effects-of-lead), [Authorized States](https://www.shawnmccadden.com/rrpedia/topic/authorized-states), [Firm Certification](https://www.shawnmccadden.com/rrpedia/topic/firm-certification), [Enforcement and Inspections](https://www.shawnmccadden.com/rrpedia/topic/enforcement-and-inspections), [Violation Reports](https://www.shawnmccadden.com/rrpedia/topic/violation-reports) [![cs-ye-234x16](https://www.shawnmccadden.com/hs-fs/hub/81069/file-1553381212.gif)](http://www.copyscape.com/duplicate-content/) ### Subscribe to RRPedia by Email and get notified about new postings as soon as they happen! ### Are You Documenting Yor Crew's Compliance With The RRP Rule?  [![download free RRP checklist](https://no-cache.hubspot.com/cta/default/81069/dd6aace9-6cb0-4ad2-a55a-09846d7f5b5e.png)](https://cta-redirect.hubspot.com/cta/redirect/81069/dd6aace9-6cb0-4ad2-a55a-09846d7f5b5e) ### Still Using a Yellow Pad for Your Estimating? 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[Worker Training (15)](https://www.shawnmccadden.com/rrpedia/topic/worker-training) ### I just wanted to say thank you for your efforts to keep us informed.  *"Thank you again for the hundreth time for keeping a vigil on this business nightmare. Your site is one of the best resources we have to stay on level ground"*  **Christian Peter**   *"I am quite impressed with all the confusion out there at Shawn McCadden’s clear and concise voice that continues to help contractors and those involved in this industry truly understand the rule. His efforts should be applauded."*  **Christopher Wagner, LBPFiles**   *"RRPedia is an accurate and contractor friendly interpretation of the very complex and confusing EPA RRP rule"* * * *"Thanks for taking the time to write the blog.  It's about the only place one can go to get some serious info on this dreadful subject"*   *"I would like to begin by thanking Shawn for all of his postings and education that he has been sharing with the remodeling industry. He has personally been extremely helpful in guiding me through various interpretations of the RRP rule, his advice and knowledge are priceless."* **Michael A. Mahoney*** * ### Suggest or Contribute a RRPedia Topic ### Want a Simple Summary of the EPA RRP? #### 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.](https://www.shawnmccadden.com/epa-rrp-summary-for-remodelers-by-shawn-mccadden/)  You can also download it if you want your own copy. ### Add this widget to your Web page, blog, or social networking site. A widget is a CDC.gov application that displays the featured content directly on your web page. Click the buttons to see the next tip to prevent lead poisoning.