Bill's Building Blog

LeadCheck record-keeping forms

Keeping records for all RRP jobs is imperative. And it needn't be difficult if you're organized.

LeadCheck, one of the few test kits recognized by the EPA for testing for lead on wood and metal, makes available a full set of record-keeping forms. 

Download the full set of record-keeping forms

News — 'Lead-safe' certification a must for contractors

From The Poughkeepsie Journal:

Michael Shultz, owner of Millbrook Electric in the Town of Washington, says he carries a test kit to determine if lead-based paint is present before he starts a job. / Lee ferris/poughkeepsie Journal

See the whole story

LeadCheck still not approved for lead testing on drywall and stucco

Last year, I reported that LeadCheck swabs would soon be approved by the EPA for lead testing on drywall (sheetrock), plaster and stucco (in addition to wood and metal).

Unfortunately, that has not yet happened. Below are the EPA-approved test kits for various materials. Note that the State of Massachusetts administers its own program.

See the full EPA announcement

EPA fines painting company $32,508 for violating lead law, failing to inform homeowners of lead-paint dangers

Press release from the EPA:

(Seattle – April 6, 2011) College Works Painting, a company operating in Oregon, has agreed to pay $32,508 penalty for alleged violations of the federal pre-renovation rule. The U.S. Environmental Protection Agency alleged that the Irvine, California based company violated the federal pre-renovation rule while renovating nine properties in Portland, McMinnville, and Hillsboro, Oregon. 

The federal Pre-Renovation Education Rule requires painters, contractors, carpenters, property-management companies and others involved in remodeling or renovation of pre-1978 housing to provide home owners and occupants with an EPA Renovate Right lead hazard information pamphlet. In 1978 lead was banned from paint used for housing.

This pamphlet educates home owners or occupants on how to minimize exposure to hazardous lead dust that is often generated during sanding, cutting, demolition or other renovation activities. The pamphlet also provides resources for more information about lead and minimizing lead hazards.

The violations in this case took place during renovation work done in 2008.

College Works failed to establish and maintain records necessary to demonstrate compliance with Toxic Substances Control Act regulations, according to the EPA. College Works has corrected the violations and is now in compliance with EPA’s Pre-Renovation Education Rule.

“Families have a right to know about possible lead health hazards around the home,” said Rick Albright, Director of EPA’s Office of Air, Waste and Toxics in Seattle. “By reading the Renovate Right pamphlet families can learn how to avoid hazardous lead dust during renovations.”

Lead-based paint can be on walls, ceilings, woodwork, windows, or even floors. When lead-based paint on these surfaces is chipped, sanded, or scraped, it breaks into tiny, barely visible pieces that children can swallow or inhale. Even small repair and renovation jobs, including repainting projects, can create enough lead dust and chips to harm children.

Lead poisoning is a silent disease that can cause serious health consequences for children because of its detrimental effects on both physical and mental development. Nearly one million children in the country are affected by elevated lead levels.

For copies of the Federal pamphlet, Renovate Right, the Federal Rule, or information on the hazards of lead paint, call 1-800-424-LEAD or via the Internet at: www.epa.gov/lead.

Video Q&A — What building practices are prohibited when doing RRP jobs?

Hot Question: How much will it cost contractors to comply with the Renovation, Repair, and Painting (RRP) Rule?

From Bill Robinson and Train2Rebuild

EPA RRP Question — How much will it cost contractors to comply with the Renovation, Repair, and Painting (RRP) Rule?

RRP Answer — From the EPA:

In order to comply with the RRP rule, renovators will incur costs for EPA certification and costs to take a training course from an EPA-accredited training provider, as well as for supplies needed in order to carry out the required lead-safe work practices designed to reduce exposure to lead dust from renovations.

Firm Certification and Training Costs: The rule requires renovation firms to become certified by EPA or an EPA-approved state RRP program in order to perform renovation, repair or painting activities for compensation in target housing or child-occupied facilities. EPA is required by law to charge firms a fee that covers the government’s cost of administering the program. Firm certification is valid for 5 years. The fee for most firms is $300, which is equivalent to a cost of $60 per year. 

See all costs here

Most frequently asked questions about the EPA's RRP Rule on working around lead-based paint

From Bill Robinson and Train2ReBuild

Do you have a lot of questions about EPA's newly enacted RRP Rule? You are not alone.

Listed below are questions most frequently looked up on the EPA's website. Click on the links to find out the answers.

1. How much will it cost contractors to comply with the Renovation, Repair, and Painting (RRP) Rule?

2. Is it a violation of the Renovation, Repair, and Painting Rule (RRP) for a homeowner to hire a firm that is not certified?           

3. Who is covered by the new Renovation, Repair, and Painting (RRP) Rule?   

4. Do test results from a certified renovator using an EPA recognized test kit (40 CFR § 745.83) become an official part of the lead-based paint testing record for that house thus negating the need for a certified lead inspector or certified lead risk assessor to conduct the inspection in that area of the house? Can a certified renovator conduct a complete lead-based paint inspection and give the property owner as an inspection report?

5. If I mist and HEPA vacuum the plastic sheeting used by my firm for interior containment, can I move and re-use plastic sheeting on the same day and job?

 

D-Lead test kit trial by Bill Robinson

Half a million renovators now certified under EPA's RRP Rule

From Bill Robinson and Train2Rebuild

NAHB — After a somewhat slow start because of a lack of certified trainers and training facilities, the U.S. Environmental Protection Agency has now certified more than 511,000 trained lead-safe renovators and 64,000 remodeling firms to date, putting them in compliance with the Lead: Renovation, Repair, and Painting rule enacted earlier this year, agency officials told NAHB during a meeting at the National Housing Center on Nov.  4.

The agency also reported that it has stepped up its campaign to inform consumers of the need to use certified remodelers when remodeling homes built before 1978.

Read the whole article at www.nbnnews.com

Q&A: Does the EPA RRP Rule apply if an old space has never been painted?

From Bill Robinson and Train2Build

Question: Does the Renovation, Repair, and Painting (RRP) Rule apply where no paint at all is present, such as in a 100-year-old unfinished basement?

Answer: No.The RRP Rule applies to activities that result in the disturbance of painted surfaces.Where there is no paint to disturb, the RRP Rule does not apply.

See more about EPA RRP

Photo Source: Young House Love

Q&A: Can EPA RRP records be kept only on my computer?

Question: Under the RRP Rule, can the required records and documentation be stored electronically rather than as paper copies?

Answer: Yes. The renovation firm is responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of 3 years following completion of the renovation. The RRP Rule does not specify the format in which records must be kept.

Search for more RRP Q&A

Tomorrow — Free lead-based paint webinar from EPA

The United States Environmental Protection Agency (EPA) is holding a series of webinars focusing on its new Renovation, Repair and Painting (RRP) lead-based paint rule.

The webinar Thursday, Oct. 28, focuses on how the rule applies to participants in the deconstruction and historic preservation industries. The webinar starts at 3 p.m. Eastern time and is designed to run for 90 minutes, including a question-and-answer period.

 

Those interested in finding out more about the Oct. 28 EPA webinar or registering for it can visit https://www1.gotomeeting.com/register/558759305.

 

According to the EPA, the webinar offers information on several topics, including:

• An overview of the RRP rule;
• New changes to the RRP rule;
• Compliance with the RRP rule; and
• Enforcement of the RRP Rule in Region 5.

The Oct. 28 webinar also addresses how the rule affects those in the deconstruction and architectural salvage sectors and is designed “to facilitate more informative information-sharing during the Q&A [portion],” according to the EPA.

via www.cdrecycler.com

Product Review: D-Lead for EPA RRP jobs

Here at Train2Rebuild, we finally received the sample D-Lead test kits from Esca Tech Inc. the new boys in town for testing lead in homes built before 1978.

Previously, we had LeadCheck but it is not approved by EPA for testing on drywall and plaster.

D-Lead does have the EPA approval for testing on drywall, plaster and ferrous metal. And since D-Lead does not rely on a red color change, it will work on red, pink and black paint. As you may know, LeadCheck is not approved to test for lead on those colors.

My goal here is to use both D-Lead and LeadCheck to test for lead in the same area of an old, painted wooden door.

As you can see above, the D-Lead test kit comes with several components:

• Solution bottle 1
• Solution bottle 2
• D-Wipe towels
• Sample catch trays
• Scoring tool
• Cleaning rod
• Razor blade
• Waste disposal bag

Plus, you get an instruction manual — which is mildly confusing — in English and Spanish.

The first instruction is to read all of the instructions. What a concept. And I reccomend you do read those instructions, paying special attention to the safety guidelines.

After reading all the instructions, I used the D-lead test on an exterior porch door in a home built in the 1940s. It is easy enough:

• Take a sample with the sampling tool
• Place in Test Bottle 1
• Shake for 10 seconds
• Add 5 drops from Solution Bottle 2
• Give it  a shake for 10 more seconds.

According to the instructions the results should appear in 3-10 minutes.

Here is the test bottle after 10 minutes: 

What do you think? If no lead is present, the solution will remain clear. If the level of lead is under the limit that requires RRP practices, the solution will be lighter in color than the color strip on the bottle. If the solution's color matches or exceeds the color strip, lead is definitely present. I found this color a little ambiguous. Is it less than the color strip? Or equal to it?

And here is a comparison with LeadCheck, used on the place where I carved out my sample for D-lead:

This is quite clear: the red means lead.

So you gotta ask yourself, which do you prefer? LeadCheck is easy and quick but does not work on drywall and plaster. And it does not work on red, pink and black paint.

D-Lead takes a little longer and the color change leaves a little to your color sensitivity. However, it does work on drywall, plaster and ferrous metals, as well as all colors of paint.

Plus, it is still not clear how available D-Lead will be in the coming weeks.

The good thing is there is competition in the lead testing market and that can only be good for certified renovators.

In the coming days, I will try this out on other surfaces and I'll show it to my next RRP class to get their opinion and get back with you on how it all shakes out. Stay tuned!

Dispatch from Bill Robinson at Train2Rebuild

D-Lead record keeping form for EPA RRP projects

In every EPA RRP-compliant project, part of the process involves keeping excellent records of what you tested and the results. This is called "protecting your assets."

D-Lead — one of the two testing kids approved by EPA for RRP jobs (along with LeadCheck), and the only one authorized for testing for lead on plaster, stucco, sheetrock/drywall — has provided a record keeping form. 

The two pages of the form are below (click to enlarge), or you can download the two-page form in PDF from D-Lead.

More D-Lead downloads:

D-Lead® Paint Test Kit Product Literature

D-Lead® Paint Test Kit Instruction Manual (English)

D-Lead® Paint Test Kit Instruction Manual (Spanish)

Buy your EPA RRP lead supplies all in one place

The cost for the supplies needed to comply with EPA's RRP Rule are not all that expensive. We're talking lead testing swabs for about 5 bucks, plastic sheeting, painter's tape, nitrile gloves, a respirator, protective coveralls, and things like that. 

Your biggest expense will likely be a HEPA vacuum for cleaning up.

What could be more expensive than the stuff itself is the staff time needed to gather it all together. And that's why various retailers have done the work for you.

Protective Products has a special section populated with items needed for RRP-compliant jobs.

See the RRP products here and below:

.	SKU #	Qty.	Description	Unit Price
	NHV-02		HEPA Lead Vacuum 2 Gallon	$324.90
	NHV-10		HEPA Lead Vacuum 10 Gallon	$489.90
	NHV-CB6		Collection Bags (6pk) for NHV-02 & NHV-10	$12.90
	NHV-DFB		Dacron Filter Bag for NHV-02 & NHV-10	$16.90
	NHV-MIF6		Micro Impaction Filters (6pk) for NHV-02 & NHV-10	$16.90
	NHV-HF		HEPA Filter for NHV-02 & NHV-10	$159.90
	NHV-RBB		11" Rotary Beater Brush Carpet Tool w/Wand	$49.90
	PC-5-1X		Non-Woven PP Coveralls with boots and hood 5 per package 1X	$10.90
	PC-5-3X		Non-Woven PP Coveralls with boots and hood 5 per package 3X	$11.90
	PC-5-5X		Non-Woven PP Coveralls with boots and hood 5 per package 5X	$12.90
	R-N100-5		N100 Respirators 5 per package	$29.90
	NG-50-M		Nitrile Gloves 50 pair M	$10.90
	NG-50-L		Nitrile Gloves 50 pair L	$10.90
	NG-50-1X		Nitrile Gloves 50 pair 1X	$10.90
	WS-2-W		Coroplast Lead Work Area Warning Signs (2) White 12" x 18"	$18.90
	WS-2-Y		Coroplast Lead Work Area Warning Signs (2) Yellow 12" x 18"	$18.90
	BT-4-180		Blue Masking Tape 4" x 180'	$14.90
	YT-4-90		Yellow Cloth Tape 4" x 90' x 9 mil	$9.90
	LBT-300		Lead Hazard Barrier Tape 3" x 300' x 1.8 mil	$6.90
	LW-90		Lead Safe TSP Wipes 90 wipes - 8" x 12"	$29.90
	LCS-8		LeadCheck® Swabs - 8 Pack	$24.90
	DL-PTK24		D-Lead Paint Test Kit	$58.90
	LSV-BR1		Lead-Safe Training Video	$68.90
	P6-11-50		Poly-Film 11' x 50' / 6 mil*	$31.90
*Not shown on this page – go to the Poly-Film page for more sizes. 11’ width allows compliance with EPA and HUD Lead-Safe RRP rules.

 

Q&A: Must my firm be EPA RRP certified if the subcontractors are certified?

Question: As a general contractor, we subcontract the entire renovation job to other companies rather than using our own employees. Under the Renovation, Repair, and Painting (RRP) Rule, does my firm need to have a certified renovator at the site?

Answer: Not necessarily. All firms performing renovations, including general contractors, must ensure that all individuals performing renovation activities on behalf of the firm are either certified renovators or have been trained by a certified renovator.

A firm acting as a general contractor may satisfy this requirement by hiring another certified firm that also takes responsibility for ensuring that all individuals performing the renovation activities are either certified renovators or have been trained by a certified renovator.

With respect to assigning a certified renovator who is responsible for any OJT and regularly directing other workers, a firm acting as a general contractor my satisfy this requirement by hiring another certified firm that in turn assigns a certified renovator to the job. However, this does not discharge the general contractor's liability to ensure compliance with the RRP Rule.

See more at ZipWall

RRP and Lead —'It takes as little as a grain of salt to poison a kid' — Kansas City Star

From the Kansas City Star:

Eight-month-old Oskar Ryan-Garrard did not eat paint chips. He didn’t swallow or suck on lead-laden toys either. He simply moved about his early 1900s Westport home and like any baby put his fingers and feet in his mouth. Then an optional blood draw showed a dangerously high level of lead.

A risk assessor found lead-leaden dust on the windowsills of Oskar’s home and on the floor and porch where he plays. Oskar’s dad is a house painter, and lead was on his work clothes, too.

“It takes as little as a grain of salt to poison a kid,” said Shannon Steinbauer of the Kansas Healthy Homes and Lead Hazard Prevention Program in Topeka.

And that grain of salt can find its way into any home: paint, residue from a parent’s occupation or hobby, everyday products.

See the whole story www.kansascity.com

Lead poisoning kills 400 children in Nigeria

KANO, Nigeria — Lead poisoning has killed more than 400 children under the age of five as a result of contamination from illegal gold extraction in northern Nigeria, an international aid agency said on Tuesday.

The children died over the last six months in several villages in Zamfara state, where lead-rich run-off from illegal gold mining has entered the soil and water supply, said Medecines Sans Frontieres (Doctors Without Borders - MSF).

"Based on the record of fatalities from lead poisoning, more than 400 children have died in the last six months," said El-Shafii Muhammad Ahmad, MSF project director in Zamfara.

"But we in MSF believe the figure is much more than that," he told AFP by telephone.

Preliminary findings by UN experts on the contamination in Zamfara state, which were released on Tuesday, said that "growing amounts of children are dying from lead poisoning."

Elisabeth Byrs, a spokeswoman for the UN office for the Coordination of Humanitarian Affairs, told AFP in Geneva that more than 3,000 children lived in seven affected villages in an area of high-intensity wildcat gold mining.

Byrs said many parents were afraid to come forward when their children fell ill, or mistook symptoms including convulsions with malaria.

Read the whole story www.google.com

Is lead-safe remodeling worth it? Four perspectives

From Popular Mechanics, the new EPA RRP Rule from four perspectives: contractor, regulator, consumer advocate and homeowner:

As of April 22, 2010, federal law requires that all U.S. contractors be certified to work with lead-based paint in homes, child-care facilities and schools built before 1978. Details of the new RRP (Renovation, Repair and Painting) rule appear in a brochure, “Renovate Right,” which contractors must give homeowners before work begins. The law requires certified renovators to be on-site to ensure that employees follow specific practices to prevent lead contamination. These include posting warning signs, taping up heavy plastic to contain the work area, minimizing dust by wet sanding, then cleaning with a HEPA vacuum and a wet mop. Certification takes 8 hours of training by an EPA- or state-accredited provider and costs from $200 to $400 per trainee. Not every employee of a remodeling firm needs to be certified, but the firm itself pays a $300 fee to obtain EPA certification. Contractors failing to comply could get hit with a civil penalty of up to $37,500 per incident, per day.

Contractor’s Perspective: “Even though it costs money, I actually think it’s a good idea,” electrical contractor and master plumber Pat Porzio says. “But of the 40 people in our training class, I was one of few who thought that.” Porzio estimates the law will add $500 to $1500 in labor costs, depending on the job’s size. The EPA estimates that the cost for containment, cleaning and verification will range up to $170 per job.

See all four perspectives at www.popularmechanics.com

Secret Video — Is this an EPA RRP lead violation?

Here's a YouTube video of what may be a violation of the EPA's new RRP rule. The rule on controlling the spread of lead-tainted dust is now being enforced with fines up to $37,500.

Watch this shaky video, then read the comments from the poster of the video and let me know your thoughts.

Here's the text accompanying the YouTube video:

83 Park Street Rockland Maine October 11 2010
Project started within the last week.
No EPA or HUD Lead Safe Practices Slowing these guys down.
Section 8 Housing Children under 6,
There are strollers and childrens toys in the backyard covered in Lead Dust, 
No steps were taken to contain the chips or dust that extends out onto the public sidewalk that is a favorite place to walk with strollers and toddlers..

No attemps of any sort of cleanup at the end of the day.

Once the Tenants start testing positive for lead poisoning this should get interesting..

Your thoughts?

EPA RRP lead-safe class with The Prince's Foundation apprentices

This week I had the pleasure of teaching the RRP certification class to a group of apprentices who are learning traditional building crafts thanks to Prince Charles and The Prince's Foundation For the Built Environment.

As you can see, these young folks are having fun in the class, as young folks are wont to do. This program is being co-sponsored by the highly esteemed Preservation Resource Center in New Orleans.

You know, I could have fun doing this every day of the week. If you have any young or young-at-heart people who need RRP certification, please let me know.

NEW Train2Rebuild DVD
On-the-Job Training: RRP Lead-Safe Practices

D-Lead test kits now available in some Home Depot stores

We've all been waiting for D-Lead test kits to become available and now it's happening. The kits are important for EPA RRP work because they are recognized by EPA as a method for determining the absence or presence of lead in drywall and plaster.

The first test kit to be approved by EPA, LeadCheck, was not recognized by EPA for testing for drywall and plaster (though that will reportedly happen soon) and was pretty much limited to painted wood and ferrous metal surfaces.

NEW Train2Rebuild DVD
On-the-Job Training: RRP Lead-Safe Practices

But while D-Lead was formally recognized by EPA about a month ago (which will save Certified Renovators the trouble of having a third-party test for lead in drywall and plaster), the test kits were not widely available. That is changing.

Here is an update I got today from George Laidlaw, sales coordinator for ESCA Tech, the Milwaukee company that makes D-Lead:

The initial shipments of 6 test kits have been delivered to the Home Depot and are being distributed to individual stores at this time.  Some stores have the kits available at this time and we expect the remainder of the stores to have stock in the next few days.

The first 24 test kits will ship to ESCA Tech, Inc. distributors the week of October 4.  Many of our distributors are taking preorders for the 24 test kits at this time.  A complete list of ESCA Tech distributors can be found at our website http://www.esca-tech.com/lptk/Distributors.php

Both kits are now in regular production and moving ahead we do not anticipate any backorders at this time.

See D-Lead test kit literature in PDF

 

___________________________________________________________

—— NEW DVD ——

BILL ROBINSON TRAINS 
YOUR CREW IN RRP 
LEAD-SAFE PRACTICES $79.00  

 

 

MORE INFO 

 

 

 

 

9 states administer their own RRP program

Here's a little-known fact: the EPA can authorize individual states to administer their own RRP program, and indeed 9 state have thus been authorized.

Those states are:

Wisconsin (Lead Safe Wisconsin)

Iowa (Iowa Dept. of Public Health)

North Carolina (Public Health in North Carolina)

Mississippi (Dept. of Environmental Quality)

Kansas (Kansas Healthy Homes)

Rhode Island (Dept. of Health)

Utah (Utah Dept. of Environmental Quality)

Oregon (Lead Poisoning Prevention Program)

Massachusetts (Labor and Workforce Development)

Want your state to get its own program? Contact your state's lawmakers and let them know. Here is the PDF application form for that.

 

Tips on training workers in EPA RRP lead-safe practices

As you know, as an EPA RRP Certified Renovator, it's your job to train your crew in RRP lead-safe practices.

As an accredited EPA RRP trainer, I'd like to offer a few training tips:

1. First, conduct a training session to cover all the aspects of the lead-safe practices. My new DVD, of course, will come in handy for that. The first training could be an hour watching the DVD, followed by hands-on experience setting up an actual RRP job.

2. After that, during your regular morning tailgate training sessions, review one of the important aspects of set up, personal protective equipment and clean up. 

3. Try having one individual describe best practices for one of those topics. The reason is that the best way to learn something is to teach it. They will learn it better, as well as teachng others.

4. Have someone point out a good work practice going on in the company currently, and then have someone else point out a work practice that could use improvement. When I've done this, the workers get very enthused and engaged. They take ownership.

Remember, while the Certified Renovator certificate must be renewed every five years, there is no expiration date on jobsite training. So it's important that you, the Certified Renovator, keep that up do date.

 

Ask Bill: How do I find an EPA RRP class?

Ask Bill with Bill Robinson

Question: I want to become a Certified Renovator. How do I find an EPA RRP class?

Answer: I have a few suggestions:

1. Do a Google search on: EPA RRP classes (your state). There's a bit of a cottage industry happening with firms and trainers offering classes, so all the information is not necessarily compiled all in one place. This will give you a wide-ranging set of options.

2. Check out the handy directory on the ZipWall website. You just enter your state and a list of providers comes up.

3. Go to the National Center for Healthy Housing and see the array of classes offered through them.

4. Send me an email and let's discuss some options. As an accredited RRP trainer, I've taught hundreds of contractors, business owners and others. I don't want to seem immodest, but I get rave reviews for my ability to make this somewhat dry information a lot more interesting. And when you hire me to provide your RRP training, you get an outrageous deal on my new DVD: On-the-Job Training: RRP Lead-Safe Practices.

RRP Myth #2: Complying with EPA's RRP rule will cost tens of thousands of dollars per project

The myths surrounding the EPA RRP rule are astounding. But once you take the training to become a Certified Renovator (and watch my DVD on training jobsite workers), you see pretty quickly how simple and basic the whole process can be.

According to the EPA, as reported on the ZipWall website, costs for containment, cleaning and cleaning verification range from $8 to $167 per job (with the exception of exterior jobs that require vertical containment).

When companies report that these costs will put them out of business, you have to wonder about the financial stability of such a company. And I'm not making light of that. These are tough times.

But most savvy contractors will add the extra $100 or so onto the bid and explain to homeowners the benefits of containing lead-poisoned dust within the house. It's actually a selling point.

Your biggest expenses from job to job (on older homes and certain other applications) will be:

lead-test swabs
plastic sheeting
painter's tape
nitrile gloves
protective coveralls
signs
caution tape
wet wipes

As you can see, none of this stuff is overly pricey. 

Big-ticket items you'll use over and over again include:

N-100 respirators
a HEPA vacuum

If you want to use dust-creating power tools, you'll use those attached to a HEPA vacuum to collect the lead-tainted dust.

Here are some tips on keeping the costs down:

• Determine the amount of supplies you'll need for each job. Establish guidelines in advance.

• Have all your supplies on the jobsite before the job begins. As with any project, sending someone out to the store for forgotten items is highly unprofitable.

• Shop around for the best prices on plastic, coveralls, respirators and other items. 

• Buy your lead test swabs in bulk and avoid heading to the big box store for a box of 8.

• Check out the offerings at Protective Products, which has a whole section on RRP supplies.

• Consider using a ZipWall system for efficient vertical containment.

Ask Bill: Rumors about the EPA's RRP Rule

Question: I hear so many rumors about the EPA's RRP Rule. Some say compliance will put me out of business. Some say compliance will cost thousands of dollars extra to replace one window. Where do I find out the facts?

Answer: That's a great question. Yes, you'll see a lot of rumors about the new lead-safe rule that are not based in fact. Your first line of defense against confusion will be to take an RRP class and become a Certified Renovator.

Of course, an 8-hour class cannot answer every single question or confusion that arises. To do your research, and not rely on third parties that may have motives other than educating you, I suggest you turn to the EPA's own Frequently Answered Questions. 

This list of RRP FAQ was updated Aug. 23, 2010.

Here are some questions and answers from the list:

Question: I thought lead-based paint had been phased out. How many homes still contain lead-based paint?

Answer: HUD’s National Survey of lead and Allergens in Housing estimated that 38 million permanently occupied housing units (40% of all housing units) in the United States contain some lead-based paint that was applied before the residential use of lead-based paint was banned in 1978. “Housing units” include single-family homes, manufactured housing, and multi-unit dwellings like apartments. Vacant housing, group quarters (e.g., prisons, hospitals, and dormitories), hotels, motels, and other short-term housing, military bases, and housing where children are not permitted to live (e.g., housing designated exclusively for the elderly and those with zero-bedroom units) are not included in this number. More information on these statistics is available from HUD.

Question: When testing a work area, does one spot-test kit suffice for any single component? What if a component's surface area is extensive (i.e. a large wall)?

Answer: The certified renovator is only required to use one spot test kit for each component, even if the surface of the component is extensive (e.g., a large wall).

Got an RRP question for Bill? Click here

RRP Price Check — Where to find the best prices on LeadCheck Swabs

For Certified Renovators testing for lead, here is a helpful survey of online prices for 8-packs of LeadCheck testing swabs (as of Sept. 26, 2010):

Home Depot — $24.94

Lowes — $24.94

Amazon — $21.24 + $5.38 shipping

Protective Products — $24.90 + $7.95 shipping

Check4Lead.com — $18.95 + $8 shipping (approx.)

Lab Safety Supply — $26.70 + $11 shipping (approx.)

48-Pack

Lead Paint EPA Supply — $113.70 + $9 shipping

Other LeadCheck distributors

RRP Myth #1 — LeadCheck is the only lead-testing kit approved by the EPA for RRP work

The Myth: LeadCheck is the only lead-testing kit approved by the EPA for RRP work.

The Truth: There are actually two kits approved by the EPA for RRP work, plus the kit developed by the State of Massachusetts. All must be used by Certified Renovators.

The two kits are made by LeadCheck and D-Lead. The latter works on stucco, drywall and plaster. But, the company is having hard time filling orders and says its  product will be available retail this month or next, and in bigger contractor packs in October.

See LeadCheck website

See D-Lead website

See EPA Website

See the whole story

Q&A: Can I teach my crew RRP lead-safe practices?

Q: Can I teach my crew how to do RRP lead-safe practices?

A: From Bill Robinson, an EPA Certified Renovator and EPA-accredited trainer (certified through NCHH):

Yes, you can train your own crew how to do RRP lead-safe practices but only if you are a Certified Renovator yourself and you provide hands-on practice. That means you have taken an 8-hour RRP certification class, done the hands-on activities, and passed the test.

Indeed, the firm or contractor must be a Certified Renovator in order for the company to work on homes built before 1978 and other applications, including day care centers. (See the RRP rule explained here)

For a fuller answer to this question, consider this direct quote from the EPA-HUD publication titled: "Lead Safety for Renovation, Repair, and Painting":

A Certified Renovator must provide lead-safe work practices training to non-certified workers so those workers can perform assigned tasks safely. This training can be provided  by the Certified Renovator on-the-job or in the classroom, provided adequate hands-on practice is available. This training could also be conducted by a third party, although the instructor must be a Certified Renovator.

So you can either provide the training yourself or have a third party instructor do the training, provided they are a Certified Renovator and you provide some hands-on practice.

If you find that training your crew is too difficult or too time-consuming, I have produced a DVD RRP training program specifically designed for on-the-job workers that you can play to your crew, and then follow it up with hands-on practice. As I am both a Certified Renovator and an EPA-accredited (certified through the National Center for Healthy Homes), I am a qualified instructor for your crew.

Read more about the DVD training program for on-the-job workers