Fulthrotl
~Autocorrect is My Worst Enema.~
- Occupation
- E
pulled the EPA certification for lead renovation today. 8 hour class.
informational note: i'm neither singing the praises nor damning the
thing, nor do i care if you have a cert, or a vacuum, or a 'tude
about the whole thing. it's none of my business what you do.
this is just so you are not blindsided by something you didn't
even know about. ignorance is not an excuse, it's an expensive
luxury. willful disobedience, is a prohibitively expensive luxury.
it's a federal statute so it affects all of us, however, it's extra
special in california.... i'll mention the flavor of the koolaid in
california... if you can deal with it, you can deal with anything.
pre '78 construction.....
you don't test for lead in the paint, you assume it's there and act accordingly.
IF YOU DISTURB IT AT ALL... *AT ALL*, you need to have the certification,
or be trained by someone who does have the certification. this does not
make you certified, you are simply performing tasks under the certificate
of another person.
this can amount to.... cutting in can lights, switches, plugs, breaking
out stucco around a panel, anything that involves disturbing existing
paint.
a certificated person must work for a registered company. the company
must have a certificated person during set up, tear down, and to do both
training uncertificated people, and certify compliance with the RRP provisions.
penalties for violation of this can be based on ability to pay, but there
is a cap of $37,500 per violation, per day.
caps on penalties vary depending on the occupancy.
you can be reported for violating this federal statute by EPA inspectors,
building inspectors, customers, private citizens, anyone.
anyone at all.
refusing to allow an inspector on the premises, defaults to a maximum
fine, to the property owner.
there is a procedure for containment, and the use of an approved hepa
vac, not a shop vac with a hepa filter. i'll not bore you with the details,
as it doesn't matter what you do if you don't have the certification.
costs to do this:
class $265 (varies from 175-350)
business registration $300
shop vac $713.31 (i'm partial to the festool product line, so i went with that, plus extra bags.)
so the day was $1,278.13 + $12 for a fuddruckers burger (ordered swiss cheese, cost extra)
that's the cost of doing it.
the cost of not doing it seems to be in the range of $2,500 ~ $9,000, based on what seems
to be available info.
the record fine in so calif was $880,000.
the most severe punishment is a house flipper who is currently serving three years on terminal island.
the federal government didn't take his money, they took him.
what's the chance of getting caught? i had half a dozen high end painters and refinishers who work
newport coast, back bay, costa mesa, etc. in my class today... the gold coast, it's called.
there are three EPA inspectors working that area, three more in south bay of LA, that have been working
stings for 4 months now... they drive around in older neighborhoods, looking for painters, plumbers,
electricians, and spot checking.
they are handing out citations. enough to scare a lot of folks into a hotel meeting room on a thursday.
two electricians, three plumbers, several cabinetmakers, and the rest finish carpenters and painters.
if you don't have the cert, or have been task trained by someone on the job, who's information shall
be kept on the jobsite, and you are disturbing paint, you are fair game.
at least now you can make an informed decision. i didn't have any idea until i read about it here.
informational note: i'm neither singing the praises nor damning the
thing, nor do i care if you have a cert, or a vacuum, or a 'tude
about the whole thing. it's none of my business what you do.
this is just so you are not blindsided by something you didn't
even know about. ignorance is not an excuse, it's an expensive
luxury. willful disobedience, is a prohibitively expensive luxury.
it's a federal statute so it affects all of us, however, it's extra
special in california.... i'll mention the flavor of the koolaid in
california... if you can deal with it, you can deal with anything.
pre '78 construction.....
you don't test for lead in the paint, you assume it's there and act accordingly.
IF YOU DISTURB IT AT ALL... *AT ALL*, you need to have the certification,
or be trained by someone who does have the certification. this does not
make you certified, you are simply performing tasks under the certificate
of another person.
this can amount to.... cutting in can lights, switches, plugs, breaking
out stucco around a panel, anything that involves disturbing existing
paint.
a certificated person must work for a registered company. the company
must have a certificated person during set up, tear down, and to do both
training uncertificated people, and certify compliance with the RRP provisions.
penalties for violation of this can be based on ability to pay, but there
is a cap of $37,500 per violation, per day.
caps on penalties vary depending on the occupancy.
you can be reported for violating this federal statute by EPA inspectors,
building inspectors, customers, private citizens, anyone.
anyone at all.
refusing to allow an inspector on the premises, defaults to a maximum
fine, to the property owner.
there is a procedure for containment, and the use of an approved hepa
vac, not a shop vac with a hepa filter. i'll not bore you with the details,
as it doesn't matter what you do if you don't have the certification.
costs to do this:
class $265 (varies from 175-350)
business registration $300
shop vac $713.31 (i'm partial to the festool product line, so i went with that, plus extra bags.)
so the day was $1,278.13 + $12 for a fuddruckers burger (ordered swiss cheese, cost extra)
that's the cost of doing it.
the cost of not doing it seems to be in the range of $2,500 ~ $9,000, based on what seems
to be available info.
the record fine in so calif was $880,000.
the most severe punishment is a house flipper who is currently serving three years on terminal island.
the federal government didn't take his money, they took him.
what's the chance of getting caught? i had half a dozen high end painters and refinishers who work
newport coast, back bay, costa mesa, etc. in my class today... the gold coast, it's called.
there are three EPA inspectors working that area, three more in south bay of LA, that have been working
stings for 4 months now... they drive around in older neighborhoods, looking for painters, plumbers,
electricians, and spot checking.
they are handing out citations. enough to scare a lot of folks into a hotel meeting room on a thursday.
two electricians, three plumbers, several cabinetmakers, and the rest finish carpenters and painters.
if you don't have the cert, or have been task trained by someone on the job, who's information shall
be kept on the jobsite, and you are disturbing paint, you are fair game.
at least now you can make an informed decision. i didn't have any idea until i read about it here.
hmy:
