RRP RULES ARE OVER THE TOP: This is my reply to a reply from DC when I asked for info on HEPA vacuums
DC thinks the RRP rules are BS.
DC,
I agree with your opinion. As much as I think that the EPA is a necessary regulatory agency, I feel that the RRP rules are ridicules. Trying to follow them is often very impracticable, and at times simply unrealistic. I further believe that people should have the right to opt out under certain conditions, as it was in the original EPA rules. What this boils down to, all things being equal, is that those of us who sincerely follow the present RRP rules are going to have higher job cost, and therefore are more likely to lose a bid as compared to those contractors who do not follow the law. All that aside, I feel that the RRP rules are over the top. Unfortunately, for most of us, we struggle to make an honest living and do not have the big bucks to pay lobbyist to fight on our behalf, or have the money to make large “donations” to the campaign coffers of the politicians who ultimately write the laws or who have influence over the regulatory agencies. Perhaps a forum at sites such as this would allow us to voice our opinions collectively to our respective legislators.
All responses are welcome.
Replies
I mentioned in your earlier post on HEPA vacs............
that FHB had sent me an email re: lead safe practices etc. That email takes you to a page that contains several links to stories and documents pertaining to the new EPA lead safe rules and procedures.
I also mentioned that even with the continued discussioin there's often disputed information given out.
Well, I took a look at some of the links from that email. It didn't take long to find one statement that has me confused. It's in the aticle by Martin Holliday ( https://www.finehomebuilding.com/PDF/Free/Lead-Paint-Contractors-Guide.pdf ) on page four. Here he seems to say that while a sole proprietor (one of us with no employees) needs to be trained and certified, there's no need to apply for and pay the 300.00 fee to the epa to have your company registered.
In class I asked specifically if as a sole prop. I needed to register with the EPA. The answer our trainers gave was YES. Besides being THE certified renovator, I also needed to register with the EPA.
This is from the EPA's pamplet:
How Does a Firm Become Certified?
Firms must apply to EPA for certification to perform renovations or dust sampling. To apply, a firm must submit to EPA a completed "Application for Firms," signed by an authorized agent of the firm, and pay the correct amount of fees. To obtain a copy of the "Application for Firms" contact the NLIC at 1-800-424-LEAD (5323) or visit
http://www.epa.gov/getleadsafe.
What Are the Responsibilities of a Certified Firm?
Firms performing renovations must ensure that:
1. All individuals performing activities that disturb painted surfaces on behalf of the firm are either certified renovators or have been trained by a certified renovator.
2. A certified renovator is assigned to each renovation and performs all of the certified renovator
responsibilities.
Wonder which one is right?
After all these yrs working in pre '78 homes, I should sink like a stone from all the lead I've ingested. However I am willing to comply with the directives put forth by the EPA because of the possible damage that I could be a part of. To defy these rules is just not right. If the claim is made that lead is of no hazard to young children and pregnant women and that is proved to be true, then I could understand pushing for change in the law.
> If the claim is made that
> If the claim is made that lead is of no hazard to young children and pregnant women and that is proved to be true
But of course that claim has been proved to be false many times over.
About you sinking like a stone, as I should as well ....
I have been doing renovation and repair work for over 25 yrs. on pre `78 houses, as you should sink like a stone, so should I; however, I made it a point to have my blood check for lead and the results came back negative. Granted, I have not sand blasted or burned paint off of houses, but I certainly have had my fair share of dust from demoed walls with lead paint as well as dust created by sawing painted wood. I'm not trying to suck this stuff in, but there is no doubt that I have.
As for pregnant woman and young children: I have no desire to cause harm to anyone and I agree that if there is evidence, and I assume that there is, that painting and renovation practices need to be modified in areas where there is a reasonable threat to these individuals or to the enviorment then so be it. That said, there are limits to practicability. I think that people in there own homes that do not have this type of risk should be able to opt out. In addition, there are times when it is simply impracticable to follow the rules. Example: Working on the exterior of a house three stories up in 95 degree heat with 95% humidity in the sun in a tyvek suit with booties. Is this realistic! Oh yes, lets add the ground tarping to catch the paint chips, this is assuming that bushes are not in the way, and then add in a little wind. How practicable is this?
Look, we can all give examples where the RRP rules would and would not work. My bottom line is that at a minimum, people should be able to opt out and I should be able to opt out of having to use wear a tyvek suit.
"the results came back
"the results came back negative."
Maybe yopu should clarify what that means
How can you have a negative amt of lead in your blood? How about in your bones?
Everyone has some amt of lead in their system. I suspect that you mean that you tests show that your lead content is below what is considered allowable ( not safe, but allowable) for an adult.
Same levels that are allowed for adults are in the red zone for kids!
I guess I could say my lead level tests are negative too, because they are just a hair under what would put me into the red zone.
Opt-Out
[quote]" My bottom line is that at a minimum, people should be able to opt out and I should be able to opt out of having to use wear a tyvek suit".
You do have the option to opt out.
You have the option to not have to work on homes built before 1978. :)
Tyvek suit.
I don't believe a worker is compelled by the RRP Rules to wear the protective clothing.
Nor the mask.
OSHA might have something to say about that, but unless they've changed the wording since I took the class, the suit is there to keep the contaminants from going home with you.
The mask needs to be NIOSH100, but again I remember no mention of it being required to be worn..
And I suppose to be sure of this I should do some remedial reading.
The new EPA stuff is to protect the HO and kids. it is OSHA to protect the worker. About all EPA says is that the guy has to remove his outer so he doesn't track the lead thru the rest of the house or home to his family.
the guy has to remove his outer
See, now I'll have to go read the rules again. Don't remember seeing that in there either.