Welcome to RRPedia
Your Interactive Resource for EPA RRP Information

RRPedia logoLooking 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 before using or contributing to RRPedia.


You Can Browse For RRP Topics By Using The Tags List To The Right

NARI Letter to Senate about RRP Rule Speaks to Contractor Concerns

Posted by Shawn McCadden on Wed, Dec 08, 2010 @ 10:23 AM

NARI Letter Submitted to Senate about RRP Rule Speaks to Contractor Concerns


NARI and RRPIn a recent letter submitted to the US Senate, NARI Executive Director Mary Busey Harris did a great job advising the EPA of critical concerns legitimate remodelers have about the EPA’s creation, enforcement and administration of the RRP Lead Rule.   The letter points out that law abiding professional remodelers are particularly challenged by two considerations having to do with the additional costs related to the current rule as well as the proposed dust wipe amendment.  Here is an excerpt from the letter:


"Currently, EPA estimates that more than 500,000 individuals have been trained on how to comply with LRRP. Despite EPA’s training success, we are witnessing two disturbing trends that threaten our livelihood and potentially endanger homeowners and children.

First, the cost increase for remodeling projects done in full compliance with EPA regulations is causing homeowners to hire unlicensed contractors or to do construction work themselves. This situation endangers children who may be exposed to lead caused by unsafe work practices.

Second, EPA is expected to finalize the “clearance” portion of the LRRP rules this July. NARI is concerned that EPA will lack sensitivity towards the impact pricing has on hiring licensed and certified contractors. The rules, if finalized with overly burdensome requirements, may drive up costs and exacerbate the problems we are currently witnessing – driving more homeowners towards unlicensed or unethical contractors."


RRP ChallengesIn the letter Harris points out that NARI would like to work with the Committee on Small Business & Entrepreneurship to “reiterate to EPA the impact LRRP is having on remodelers and to facilitate a better dialogue on how EPA can implement the LRRP rules in a small business-friendly way”  She further goes on to suggest that;  ”With the Committee’s help, remodelers and EPA officials can work towards solutions that will better inform homeowners of lead hazards, penalize unlicensed or unethical contractors, and reduce the exposure of children to lead from construction activities”

Thumbs upI commend NARI for reaching out to work with government officials regarding the EPA RRP Lead Rule in a constructive and thoughtful way.  I hope the Senate and the Committee on Small Business & Entrepreneurship will embrace NARI’s offer.  The remodeling industry and remodelers need their voices to be heard.  Even more important, EPA needs to listen if the RRP rule is to be effective and our government is truly interested in protecting America’s children as well as professional remodelers from the negative effects of the underground economy.

Topics: EPA RRP Rule Updates, Effects of the RRP Rule, Enforcement and Inspections

Jury Awards Nearly $21M in Baltimore Lead Paint Case.

Posted by Shawn McCadden on Thu, Oct 07, 2010 @ 10:49 AM

Jury Awards Nearly $21M in Baltimore Lead Paint Case.

Lead Paint law suit award

If you have been concerned about the legal risks and liabilities due to the RRP rule your concerns may be well founded.  Although very brief and lacking details, this Associated Press article from the Washington Examiner is probably very bad news for renovation contractors and landlords:


Associated Press
10/06/10 10:50 PM EDT

BALTIMORE — A Baltimore City jury has awarded a 23-year-old woman nearly $21 million after finding she suffered lead poisoning while living in an apartment owned and maintained by the Housing Authority of Baltimore City.

Attorney Brian Brown says the $825,000 in economic damages and $20 million in non-economic damages awarded Wednesday is one of the largest he has ever seen, but it will likely be reduced because of the state's $350,000 cap on non-economic damages.

Baltimore Circuit Court Judge Alfred Nance will determine, within the cap, how much Marie Carter will get in non-economic damages.

The case was based on circumstantial evidence because the property had been demolished before it could be tested for lead paint. Brown says Carter's IQ was diminished by 10 points, to 89, which is below average.


Information from: The Daily Record of Baltimore,

Read more about this from Dolan Media including comments from the lawyers involved in the case

There are some interesting comments on the Baltimore Sun web site

Topics: Effects of the RRP Rule, Legal Considerations, Health Effects of Lead, Info for Landlords

Banks And Lenders Are Starting to Find Out About the EPA RRP Rule Too

Posted by Shawn McCadden on Thu, Sep 30, 2010 @ 08:00 AM

Banks And Other Lenders Are Starting to Find Out About the EPA RRP Rule Too.

Foreclosure signBanks have started to figure out that the costs and liabilities related to the EPA RRP rule can dramatically increase their costs and risks.  Banks that own foreclosed properties have quickly discovered the additional costs they will incur when repairing and or renovating these properties just so they can sell them.  Under the RRP rule, landlords need to become certified firms and use certified renovators when working on their properties.  Banks who take possession of pre-1978 properties need to do the same and or only hire certified firms to perform the work for them.  As a result of the RRP rule, many pre-1978 foreclosed homes are now worth less than they were valued prior to the April 22, 2010 date the new EPA RRP rule took effect. 

Upside down mortgageBanks are also more likely to end up with additional foreclosed properties due to the RRP rule.  For struggling pre-1978 homeowners and investors, perhaps already upside-down on their mortgages, the additional repair and maintenance costs related to the EPA RRP rule may be just one more reason to justify letting their properties go to foreclosure.  Finding out about the potential additional drop in equity value in the property due to the EPA RRP rule may become a second reason to let upside down properties go to foreclosure.

Approved or RejectedAs mentioned above, banks have already started to become aware of the EPA RRP rule due to foreclosures.  They are also using this knowledge when considering loans.  If loaning money to home buyers for purchases and or to property owners for renovations, banks will likely want to know if a pre-1978 property contains lead and if it does how it might affect the value of the home.  A home needing significant repairs or maintenance after purchase will likely have a much lower value if the work will fall under the EPA RRP rule.  Such scenarios might have a few different effects ranging from requiring more money down, higher interest rates, lower appraised value of the property as compared to the selling price and or ultimately denying to loan money on the property. 

Topics: Effects of the RRP Rule, Shawn's Predictions

Home Inspectors Will Help Spread The News About The EPA RRP Rule

Posted by Shawn McCadden on Fri, Sep 24, 2010 @ 08:04 AM

Home Inspectors Will Help Spread The News About The EPA RRP Rule

ASHI LogoIf home buyers aren’t aware of lead paint or the implications of buying a property that has or may have lead paint, a good home inspector may likely provide such knowledge. 

In April this year I did a presentation about lead and the new RRP Rule for the New England Chapter of the American Society of Home Inspectors (ASHI New England).  Ironically, the meeting was scheduled for Earth Day, the same day the RRP rule went into effect.  At this meeting I informed the inspectors not only about the required EPA RRP lead –safe work practices, but also about the health effects of lead and the required documentation that home owners should receive on completion of a renovation if the property was built prior to 1978.  The inspectors were quick to connect the dots between identifying recent renovations and suggesting to the buyer that they ask the seller for a copy of these documents.

In my experience, home inspectors, particularly ASHI members, are typically a very detailed and knowledgeable group of professionals who seek to constantly increase their knowledge.  In fact, to maintain their membership in ASHI, members are required to obtain continuing education credits.  Home inspectors separate themselves from their completion through their knowledge and expertise and use these advantages to better serve their clients.  Home buyers have home inspections performed prior to a purchase as a way to not only identify the condition of a home, but to also identify any health and or safety issues the home may have. Good home inspectors should have knowledge about the EPA RRP rule and will share this information with their clients.

ASHI Home InspectorHome inspectors will help cause compliance with the EPA RRP rule in a few ways.  First, they will likely make home buyers aware of the fact that if built before 1978, the home may likely contain lead paint.  The only way to verify if lead paint is present is to do a lead test.  Inspectors can suggest their clients ask the seller if the home has been tested and if it has to obtain a copy of the required lead inspection report.  Next, if the home does have lead, or it hasn’t been tested, inspectors should inform the buyers that any renovations to the home would need to be done using lead-safe work practices.  This will have two effects.  The first would be to let the buyer know that lead-safe work practices are required should they be planning any renovations after purchasing the home.  Second, and most critical, would be to verify that any recent renovations done at the home were done using lead-safe work practices and to verify this by making sure who ever did the work did it in compliance with the EPA RRP requirements.  Again, requesting a copy of the required documentation will be the best way a buyer can confirm how such renovations were completed.

Home Owner paintingAdditionally, if the work was done by the home owners themselves, or perhaps was done illegally by a non-complaint contractor, the only way to find out if the work may have contaminated the home with lead would be to have the home tested by a licensed lead inspector.   This is likely to create heartburn for both the seller and the realtors involved in the sale.  Federal disclosure rules about lead require that if a home is tested, the required lead test report must be disclosed to any buyer or anyone planning to rent or lease the property.  Failure to do so would result in serious legal liabilities for the seller and also for the realtor should the realtor be aware of the testing.  If the seller refuses to allow testing, the buyer may just walk away from the purchase and has the legal right to do so.  


As the above described scenarios take place during real estate transactions, I predict home owners, home buyers and realtors will all become more and more aware of the EPA RRP rule.  Each, and for their own reasons, will likely become frustrated and or disappointed.  All will share their frustration and disappointment with someone else.  Its only human nature to do so.  This will result in spreading the word about the EPA RRP rule and will contribute to the reporting of violations and the enforcement of the rule by either the EPA and or those states that have assumed administration and enforcement of the rule.

Topics: Effects of the RRP Rule, Legal Considerations, Shawn's Predictions, Info for Landlords, Lead Test Kits and Testing, Enforcement and Inspections

Property Values and Equity Will Drop as a Result of the EPA RRP Rule

Posted by Shawn McCadden on Tue, Sep 07, 2010 @ 01:26 PM

Property Values and Equity Will Drop as a Result of the EPA RRP Rule

Price reducedHome buyers, investors and realtors will likely drive awareness about lead and the new EPA RRP rule up.  But, at the same time, such awareness will drive the values of pre-1978 properties down.  If unaware of the additional considerations of risks, liability and costs related to the RRP, realtors will likely walk into a hornet’s nest. 


Some home buyers and investors use realtors acting as buyer brokers to assist them when purchasing property.  If making buying decisions based on property pricing and the costs related to bringing the properties they purchase up to par with their desires, these buyers will not be happy if they are blindsided by the RRP rule.  These buyers will also be very unhappy, and may consider legal options, if they feel their realtor should have advised them about such considerations during the buying process. 

No lead paintA buyer’s willingness to purchase a property that contains lead will definitely be effected as a result of the RRP rule.  First, once word gets out, the health risks of lead paint and related liabilities will cause many buyers to bypass any consideration of pre-1978 properties.  As the supply goes up, the prices of these properties will go down.  Also, investors won’t like the added costs of owning such properties, particularly if the value of those properties is less likely to increase over time as compared to properties without lead.   This too will lower property values to a point where the value of certain properties may only be in the land they sit on, less the cost to get rid of the original lead infused structure.

As a result of the RRP rule, I predict home sellers and realtors will get into uncomfortable negotiations with buyers, and as a result, even some challenging conversations between themselves.  Let’s just say the asking price for a pre-1978 property is $280.000.  I picture scenarios where a buyer will make two different offers for that property.  One offer will be close to the buyer’s asking price, say $270.000.   But, the offer will be conditional upon testing the home for lead to confirm no lead is present.  The second offer will be much lower, say $240.000.  The second offer will reflect the additional costs and risks the buyer feels they will be assuming if the home does have lead and or the seller isn’t willing to allow testing for lead.  In the negotiations, realtors will likely become the punching bag, as buyers and sellers typically never interact, but rather the realtor acts as the middleman.  If the seller is first finding out about lead and the RRP as a result of the offer, as mentioned above, that seller might not be happy with their realtor either.

Realtor LogoAs a side note, realtors as a whole are typically much more professional and proactive than contractors.  The majority of them are also dues paying members of one single, well funded and very powerful trade association that represents their interests.  I predict that once a good number of realtors catch wind of and understand how the RRP will affect their industry; their association will be working to modify the rule in their favor.  This might be of benefit to renovators, but just as easily, it might not.

Topics: Effects of the RRP Rule, Legal Considerations, Shawn's Predictions, Health Effects of Lead, Info for Landlords

Contractors and Subs Doing EPA RRP Work Will Need to Work Things Out

Posted by Shawn McCadden on Fri, Sep 03, 2010 @ 01:50 PM

Renovators And Their Trade Partners Will Need To Work Out And Agree On Who Will Do What

Confused RenovatorMany contractors seeking to comply with the new EPA RRP rule are reporting concerns and challenges about finding trade partners who are willing to operate in compliance.  Many renovators have told me that their trade partners have flat out refused to get their businesses and workers certified.  Others have said their trade partners have committed to do so but have been slow to get it done due to the related costs.  This has become quite an opportunity for some trade partners who have become certified and are marketing their certifications and services to general contractors. Several are actually offering to sub-contract the set-up, containment, demo, clean-up, cleaning verification and all related and required documentation for general contractors.

A surprise to me, but also a no-brainer, was one electrician’s comment that he was having problems finding general contractors to work for who were in RRP compliance.  Just as general contractors need to find new compliant trade partners to work for them, many trade partners are finding they can no longer rely on the volume of work they got in the past from contractors if those businesses choose to operate illegally.

Liability risks may also drive compliance.  Renovators and their trade partners will need to work out and agree on who will do what.  Here are a few examples:

  • Renovate Right PamphletWho will take care of the notification requirements and documentation of same before the job begins?  Under the rule, either can do so, but the business under contract with the property owner must maintain the required documentation.

  • If a trade partner or his employees are not certified renovators, will the renovator take on the responsibility of training and supervising the trade partner and or his employees?  If so, at what level of risk? And, will either business’s insurance company allow such a relationship in the future?  

  • Who will create the required renovation checklist?

  • Who will make sure the homeowner and or tenant receives a copy of the required renovation checklist after completion of the work? 

  • In Massachusetts, who will maintain the required log documenting who comes in and out of the containment area during the course of renovations?

Finger pointingThe first time a RRP fine is accessed for a violation the finger pointing will start, causing one or both businesses to get serious about certification and compliance.  The first time a renovator is sued by a client or neighbor as a result of the actions of a trade partner, the tactics used by the lawyers will cause both businesses to have a new and different outlook on RRP compliance, insurance coverage amounts and indemnification clauses.  Attorney Mike Sams of Kenney & Sams, P.C., told me that failure of a business to be properly certified under the RRP rule on its own is evidence of negligence should a homeowner or insurance company take the contractor or trade partner to court.  Taking this a little further, a contractor hiring a non-certified trade partner might also be considered negligence if that trade partner is allowed to work unsupervised.

IRS LogoTo confuse matters even further, under their definition of the difference between an employee and an independent contractor, the IRS says that a contractor cannot supervise the work or workers of a sub contractor.  Doing so might result in the IRS labeling the sub contractor as an employee. If this were to happen it could trigger addition payroll taxes and workers compensation costs for the general contractor.

Topics: Effects of the RRP Rule, Production Considerations, Subcontractor Considerations, Legal Considerations, Shawn's Predictions, Insurance Considerations, Notification Considerations, Compliance Options, Documentation Considerations, MA RRP Lead Rules, Enforcement and Inspections

Insurance Companies Rethinking Coverage Due to EPA RRP Rule

Posted by Shawn McCadden on Thu, Sep 02, 2010 @ 01:26 PM

Insurance Companies Will Be Rethinking Coverage and Premiums Due to EPA RRP Rule

RRP Insurance folderMany liability insurance policies do not cover lead poisoning or contamination.  Renovators should be sure they are working with an agent who is up on the EPA RRP rule and should sit down with their agent to review their coverage needs and options.  Tom Messier, with Mason and Mason Insurance, tells me that insurance companies are starting to become aware of the RRP rule.  Insurance is all about risk. The greater the risk, the higher the cost of insurance will be.


RRP LogoIncreased risk of liability due to lead awareness as well as the government mandated certification requirements are likely to affect a renovator’s ability to get a policy as well as the premium charged by carriers who offer coverage.  Tom told me he predicts that existing policies will not be renewed unless a renovator can show they are certified firms and use certified renovators to oversee the work their company performs.  He also predicts insurance carriers will start requiring the insured’s proof of compliance with the rule as well as proof of compliance and insurance coverage for the trade partners the insured renovator works with.  Tom stressed that this would be for both liability as well as workers compensation insurance coverages. He said that even if they are self-employed, insurance carriers will likely require all trade partners have their own workers compensation policies as a way to prevent injured or poisoned trade partners from claiming against the general contractor’s policy. 

Also Tom warns, just as many insurance companies now review the contracts contractors use with customers and trade partners before offering or renewing a policy, Tom predicts carriers will be asking to see completed copies of the required RRP documentation used by contractors.   I asked Tom what renovators should do to protect themselves and be sure they can maintain coverage going forward.  Tom’s response; “Document, document, document!!!” 

Apertment for rent signOne other area that will likely be of concern is lead coverage in policies for landlords who own pre-1978 properties.  Here too, compliance with RRP rules and documentation of work practices used for renovations and repairs will likely become required conditions of obtaining and keeping coverage.  The EPA RRP rule may also cause an increase in insurance coverage on properties built prior to 1978, for landlords and maybe even home owners.

Topics: Effects of the RRP Rule, Subcontractor Considerations, Shawn's Predictions, Insurance Considerations, Documentation Considerations, Info for Landlords, Firm Certification

Nervous Neighbors Will Keep EPA and MA RRP Renovators On Their Toes

Posted by Shawn McCadden on Wed, Sep 01, 2010 @ 01:17 PM

Uninformed and Nervous Neighbors Will Keep RRP Renovators On Their Toes

Awareness about lead and the potential effects of lead poisoning may not yet be prevalent with the public, but it will quickly increase.  Renovators need to deal with this reality in a proactive way.  Training and firm certification are great first steps.  But, renovators will need to do much more to protect their businesses from potential challenges and liabilities triggered by an uniformed public.


EPA Sippy Cup ad

First, the EPA’s public awareness campaign has already begun.  The campaign warns people of the dangers of lead, but does little to make them aware of the RRP rule, the need to work with renovators who are certified in lead-safe work practices, and or how to find a certified firm to oversee work on the homes they live in.  So, in effect, the campaign warns the public but leaves them basically ignorant of their options. (Click on the sample ad to the left to view in full size)


Lead sign with skullSecond, the warning signs and barriers required to be put in place around exterior and common area containment areas will have a similar effect of raising concern.  Unless properly educated about their options and about lead-safe work practices, neighbors and the parents of children attending child occupied facilities will again suffer from ignorance about lead.  Many will likely react out of fear.   This fear may potentially result in reporting a renovator and causing an inspection, even if the renovation work is being done within compliance. 


GuiltyRemember, as a business you are guilty until you prove yourself innocent at your own expense.  An OSHA and or RRP inspector will likely be able to find at least one violation of some rule if they show up at one of your jobsites.  Some inspectors may even feel it is their obligation to find a violation.  The cost to defend yourself might be as high as the cost of any fines, so even if you win you lose. In Massachusetts, the Department of Occupational Safety (DOS) is already collaborating with OSHA regarding what to do if either finds a violation that should be referred to the other.  Oh, and don’t forget those neighbors who have a bone to pick with your customer, have nothing else to do all day, and or are just plain paranoid.


Topics: Effects of the RRP Rule, OSHA Considerations, Legal Considerations, Shawn's Predictions, MA RRP Lead Rules, Enforcement and Inspections

Doing EPA RRP Work? OSHA Will Be Watching For You.

Posted by Shawn McCadden on Tue, Aug 31, 2010 @ 09:00 AM

Compliance With and Enforcement of the RRP Rule Will Be Assisted By OSHA Inspectors

OSHA LogoIn addition to the OSHA rules contractors should already have been aware of related to worker safety, the EPA RRP rule has added yet additional OSHA concerns for renovators.  One for example is working on a surface covered with plastic. OSHA considerations related to working on plastic are not part of the curriculum delivered during the required EPA certified renovator training. Due to the absence of this information, the EPA is essentially leaving it up to renovators to become aware of such considerations on their own.  Once aware, renovators must seek out the information they need and adjust their work practices accordingly to avoid fines from OSHA should they get randomly inspected.   Or worse, have a worker accident. 

keep right wrThis begs a few questions.  First, were the authors ignorant of such considerations?  Asked another way, does the left hand know what the right hand is doing?  Is this another example of a breakdown in communication between very significant departments of our government charged to look out for our best interests?  A second question might be; did the authors of the EPA RRP rule leave this information out of the rule for a strategic purpose?  Perhaps this is just one more way to force small independent businesses out of the construction industry in favor or labor unions. 

In one of his recent blogs, RRP certification training provider and business coach, Mark Paskell of The Contractor Coaching Partnership, shares a real life story about a contractor who was visited, at the same time, by both an OSHA inspector as well as an inspector from the Massachusetts Department of Occupational Safety (DOS).  (Massachusetts has assumed administration and enforcement of the RRP rule from EOPA)  In the blog Mark describes the battle that took place between the OSHA inspector and the DOS inspector about the use of plastic on the jobsite. Check out the blog to see which inspector retreated. 

Warning SignOf bigger concern should be the distribution of misinformation at the certified renovator training.  For example, using the sample signage included in the EPA approved training manual (required to be posted outside contained work areas), might just get you in trouble with OSHA.  First off the RRP rule requires the use of a “warning” sign, but the sample sign is a “caution” sign.  OSHA considers a warning sign to be a stronger message than a caution sign, and has rules dictating when and how to choose one versus the other. 

Also, if you have employees, the sample sign in the manual will not meet OSHA requirements either.  Employees must be told what they are being warned about on such signs, in this case lead, and the signs must also instruct the employees not to smoke, eat, or drink in a work area assumed to contain lead.  Check out this article by Dick Hughes of Excellence in Safety for a list of other OSHA requirements left out of the RRP rule. 

The RRP is challenging enough to comply with.  Contractors putting their heads in the sand about OSHA requirements and compliance are taking a huge risk.  I am planning on taking some OSHA training classes to learn more about what contractors must need to be aware of and what they will need to do to avoid risking violations and fines.  I will post information about this subject to RRPedia in the future.   If you have not done so already, you can subscribe to RRPedia at the top of this page.   Subscribers will be notified by e-mail as soon as new articles are posted.

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.

Topics: RRP in MA, Effects of the RRP Rule, EPA RRP Lead Rules, OSHA Considerations, Shawn's Predictions, Certified Renovator Training, Containment Considerations, Enforcement and Inspections

Delegated States Likely Better Prepared To Enforce EPA RRP Rule

Posted by Shawn McCadden on Fri, Aug 13, 2010 @ 11:35 AM

Delegated States Likely Better Prepared To Enforce EPA RRP Rule

Several states around the country have assumed administration and enforcement of the EPA RRP rule and others are also thinking of doing the same.  EPA actually offers money for the states to use to investigate the practicality of doing so.  As this happens each state must create its own rule which is at least as strict as the EPA rule in order to get approval to do so from the EPA.  This will lead to confusion for many renovators. 

EPA RRP EnforcementVariances in the rule requirements, from the EPA RRP rule and also from state to state, will make it difficult for renovators to understand the differences and keep up with amendments made by each entity.  Renovators working in more than one state many have to become certified firms in each state they operate in and or also with the EPA.  Are renovators better off if their states write a better thought out rule?  Would renovators be better served if there was just one well written rule for everyone to follow?   I predict that confusion may likely contribute to violations and fines for these renovators. 

MA DOS LogoIn July of this year Massachusetts took over administration and enforcement of the RRP rule.  The Massachusetts Regulations, written by the Massachusetts Department of Occupational Safety (DOS), include many of the OSHA related considerations left out of the EPA RRP rule and the EPA required certified renovator training.   As a result, Massachusetts contractors are quickly becoming aware of the already existing OSHA considerations related to working with lead.  For example, the Massachusetts firm licensing application includes a requirement that a written respiratory protection and worker health and safety program evidencing compliance with the Massachusetts RRP rule and OSHA medical monitoring requirements be submitted with the application.  This will force businesses to have such a program in place before they can be licensed to do RRP work.   The requirement will also serve to dictate what the business must have in place should they be inspected by either the DOS or OSHA.   I predict the need for OSHA related training will increase dramatically as contractors become aware of violations and fines levied against their peers.

MA DOS InspectionThe MA DOS has also started conducting on-site inspections.  Though most inspections are triggered by citizens reporting suspected violations, the DOS is also out in the field and is stopping by renovation projects as they come across them.   In one of his recent blogs, RRP certification training provider and business coach, Mark Paskell of The Contractor Coaching Partnership, shares a real life story of a painter who was visited by DOS after a neighbor next door to one of his projects called the DOS with concerns about soil contamination.  The contractor was in compliance and made out fine, but the DOS left him with a message and asked that he would share it with others.  "Tell every contractor you know we're out there enforcing. Tell your friends, your neighbors, other contractors you know, suppliers and trades. We are here and we will enforce the new law"

NOTE: EPA has authorized nine states to administer their own RRP programs: Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah and Wisconsin.

Topics: RRP in MA, Effects of the RRP Rule, MA RRP Licensing, OSHA Considerations, Shawn's Predictions, Authorized States, Work Practices, MA RRP Updates, MA RRP Lead Rules, Personal Protection, Enforcement and Inspections