--- title: "RRP Rule: Is it a Sheep in Wolf's Clothing?" description: The EPA's RRP rule has been an enigma to deal with. What I envisioned as game changing regulation has turned out to be a sheep in wolfs clothing. image: https://www.shawnmccadden.com/hs-fs/file-15768985-jpg/images/joe_levitch_cropped-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 ## [RRP Rule: Is it a Sheep in Wolf's Clothing?](https://www.shawnmccadden.com/rrpedia/bid/78371/RRP-Rule-Is-it-a-Sheep-in-Wolf-s-Clothing) Posted by [Shawn McCadden](https://www.shawnmccadden.com/rrpedia/author/shawn-mccadden) on Wed, May 23, 2012 @ 05:00 AM - [Tweet](https://twitter.com/share) ## **RRP Rule: Is it a Sheep in Wolf's Clothing?** #### **![Joe Levitch](https://www.shawnmccadden.com/hs-fs/file-15768985-jpg/images/joe_levitch_cropped-wr.jpg?width=154&height=151&name=joe_levitch_cropped-wr.jpg)** #### **One Person’s Opinion:** This is a guest blog submitted by Joe Levitch of [Levco Builders](http://www.levcobuilders.com/) to express his opinion.  Joe is a remodeling contractor and he is also a Licensed Lead Inspector, Licensed Risk assessor  and the owner of [Lead Locators](http://www.leadlocators.net/), a lead inspection firm in Boise Idaho. He comments and contributes to RRPedia quite often.  If you would like to express your opinion or offer something of value for RRPedia visitors let me know.   ### ![Is RRP a Sheep in Wolf's Clothing?](https://www.shawnmccadden.com/hs-fs/file-16125113-jpg/images/sheep_in_wolf_clothes-wr.jpg)**** ### **Wolf in Sheep's Clothing?** It has been 2 years now and the EPA's RRP rule has been an enigma to deal with. What I envisioned as game changing regulation has turned out to be a sheep in wolfs clothing. I expected a year of educating the public through infomercials and campaigns, Then some head turning enforcement. Sadly I was and have been consistently disappointed. I expected my fellow remodelers to understand intuitively that the old days of dusty demolition were over and adopt the new rules, but there I go again over estimating my industry. ### **Resistance to change seems to dominate** Turns out remodelers like everyone else wants to do as little as possible and get by. Change is painful I suppose, most would rather spend energy disputing scientific facts than getting their act together and incorporating lead testing and LSWP into their SOP'S. I have talked till blue in the face about the federal law and the mandate that RRP imposed back in April of 2010 but in my little hamlet of Boise Idaho there has been no known enforcement. I do see a trend however in the industry. We are getting a few more requests to verify contractors are using Best Practices when LSWP is in process. I am also getting an up tic in the number of test requests for lead testing, so the news is not all bad. ![OSHA Lead in Construction](https://www.shawnmccadden.com/hs-fs/file-16113742-jpg/images/osha_logo-wr.jpg?width=187&height=101&name=osha_logo-wr.jpg)   There have been a few reports of fines, but they are not close to home or particularly relevant to the remodeling industry. Most are for failure to use the Renovate Right Booklet. OSHA has become a bit more worrisome to contractors than it used to be. Their requirements are far more burdensome and onerous. I seriously doubt many remodeling firms are in compliance with their rules. ![Lead Awareness Committee](https://www.shawnmccadden.com/hs-fs/file-15776257-jpg/images/most_boring_day-wr.jpg?width=333&height=249&name=most_boring_day-wr.jpg) ### **Contractors are "Leaded-Out"** I still sense a general disdain for the RRP rule along with general confusion, but a reluctant sluggish move towards compliance. I set up a Lead Awareness committee for my NARI group and after an enthusiastic push to get everyone up to date and compliant, I was told to back off with the education and speakers " We are a little leaded-out right now" I have had no problem explaining to my clients that lead testing saves money. Perhaps it is just the delivery I use? Doing leaded work has been difficult. I can see how one can develop heat exhaustion or worse in little or no time. Monitor your folks for hydration and schedule cooling off time. ### **On testing and the Opt-Out** I am saddened by remodeling organizations asking congress to repeal RRP or allow opt out. It is a huge step backwards. Having swabs check for lead in drywall and plaster was a foolish thing to allow too. I read that there is a 98% false positive when used in this way. That is why the EPA could care less. [(Click here for clarity on false positives)](https://www.shawnmccadden.com/rrpedia/bid/45007/NAHB-Article-Regarding-EPA-Lead-Test-Kits-Could-Be-Misleading-To-Some) The swabs test for the presence of lead. We don't need to do LSWP unless there is over 1mg/cm 2.  3M is laughing all the way to the bank, homeowners and contractors alike are using LSWP unnecessarily in many cases now. ![XRF Gun](https://www.shawnmccadden.com/hs-fs/file-16142078-jpg/images/xrf_gun_on_baseboard-wr.jpg?width=171&height=129&name=xrf_gun_on_baseboard-wr.jpg)My advice to every remodeler is to find a company with an XRF that can do a test and produce a report that can be used as a tool to deal with lead above the regulatory limit. Get fluent in using LSWP. Check each other to make sure no one is poisoning their clients or their pets and lets be professional about it. My company has teamed up with some painters that are certified firms and have done testing on all proposed renovations on all pre '78 homes. Many of them are leaded, most have only a few components that require LSWP. We have also had tiles tested and found a many of them to be leaded in a very high percentage. I believe tile should be assumed to be leaded and demolished with care. ### **Let's do the right thing** In closing I applaud those that have incorporated RRP into their business. The EPA has been looking into new ways to track compliance and performing enforcement. I encourage those that are resisting change to get on board before the EPA fines you, or worse, you make someone sick.  Ask those of us that are dealing with the rule how we have managed and let's set ourselves apart from our competition by doing the right thing. Topics: [Opt Out Related](https://www.shawnmccadden.com/rrpedia/topic/opt-out-related), [Guest Blogs](https://www.shawnmccadden.com/rrpedia/topic/guest-blogs), [OSHA Considerations](https://www.shawnmccadden.com/rrpedia/topic/osha-considerations), [Opinions from Renovators](https://www.shawnmccadden.com/rrpedia/topic/opinions-from-renovators), [Lead Test Kits and Testing](https://www.shawnmccadden.com/rrpedia/topic/lead-test-kits-and-testing), [Enforcement and Inspections](https://www.shawnmccadden.com/rrpedia/topic/enforcement-and-inspections) [![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.