From Bill Robinson and Train2Rebuild
RRP Question — Is it a violation of the Renovation, Repair, and Painting Rule (RRP) for a homeowner to hire a firm that is not certified?
RRP Answer — From the EPA:
The Renovation, Repair, and Painting Rule (RRP) does not impose requirements on homeowners, unless they are performing renovations in rental space. However, the hired firm would be in violation of the RRP Rule if it was uncertified and performing a covered renovation.
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.
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.
