Lead-Safe seminars

[ceknight]

Sorry, don't have time to read back through the entire thread but noticed several questions about whether the 6 sf rule applies to the entire project or a particular room.

From the EPA's rule: "The requirements apply to renovation, repair or painting activities. The rule does not apply to minor maintenance or repair activities where less than six square feet of lead-based paint is disturbed in a room or where less then 20 square feet of lead-based paint is disturbed on the exterior." (my italics)

More than you ever wanted to know available at: http://www.epa.gov/lead/pubs/renovation.htm


No question of whether I needed to do it, all of my customers live in pre-1978 houses. Consider me Certified, Trained, and $500 lighter,

 

[dmagyar]

How insurance plays into this

How insurance plays into this

I didn't notice if any of the other posts has raised the question but I think we can all see the implication regarding being certified then being sued later by the HO. My question is how are our respective insurance companies going to deal with that likelyhood? I know the one I've got now doesnt' necessarily want me doing electrical work let alone Lead paint abatement. Guess where our rates will go after we're certified. IMHO this sounds alot like the mold fiasco of a few years ago.

 

[e57]

I think that this is a very relevant question. It seems that sanding 6 Sq' is a whole lot worse than cutting out a 6'x6' hole.

Well maybe - we can all advocate that each state come up with it's own program, and make sure that law makes sense...

EPA Authorized State Programs
EPA has the authority to authorize states, tribes and territories to administer their own RRP program that would operate in lieu of the EPA regulations. When a state, tribe or territory becomes authorized, contractors and training providers working in these areas and consumers living there should contact the appropriate state, tribal or territorial program office. Currently the following states have been authorized by EPA: Wisconsin, Iowa, , North Carolina and Mississippi .
Top of Page
Information for States and Tribes
EPA headquarters has developed guidance documents to assist states and tribes that are applying to EPA for authorization to manage their own lead renovation, repair and painting programs (PDF) (122 pp, 257K).

 

[shockin]

I haven't taken the class yet but I have talked to others that have. I was under the impression that while it applies only to home older then '78, it applies to ALL commercial as they are still using some lead paint in comercial to this date.

Can someone confrim this?

Thanks

 

[Philip Barr]

I haven't taken the class yet but I have talked to others that have. I was under the impression that while it applies only to home older then '78, it applies to ALL commercial as they are still using some lead paint in comercial to this date.

Can someone confrim this?

Thanks

This isn't a confirmation but from what Ive read the only "commercial" sites effected by this rule would be daycares. It's all about the children.

 

[dmagyar]

My insurance agent just called warning me about the EPA and lead.

My insurance agent just called warning me about the EPA and lead.

For the coverage mandated by being lead certified adds another $750.00 minimum to whatever coverage you already have. He mentioned that as an "lead" expert you'll be one of the deep pockets that some think are fare game. For the $750.00 you get the first $1,000,000.00 of toxic coverage.
If you haven't taken the classes yet it might be a good idea to at least talk with your insurance company.

 

[e57]

And what changed in the work you do? Cut brandnew sheetrock with a painted surface in a building with a foundation poured prior to '78 - before 4/22 - you have one insurance rate - afterwards you get another???? The risk that changed is the Fed EPA... And thier $35,700 fine for a little dust... >98.5% of which is sheetrock and plaster... (the amount of "paint" is nothing - and even less than that will be lead paint - if any at all)

Anyone changing thier mind about a more sensible state law instead yet?

 

[c2500]

The fine is up to $32,500 per offense.

The 6sqft rule is EPA. If you do HUD work it is 2 sqft.

You, as a certified RRP guy can do a lead check test on the paint. No lead, no problem.

If I take one gram of lead dust (a sugar or equal packet for reference) I can contaminate a large house. The max allowed lead is 40 micrograms per sqft on floors. 250 micrograms/sqft sills and 400 micrograms/sqft window troughs.

What everyone needs to understand is that even if you don't disturb the square footage, you still must work lead safe. So, go on out and buy that $400-$600 True HEPA vacuum. And no, that HEPA filter on your wet/dry vac does not count and will generate lead dust.

For those that disagree, consider this...

you go cut in a few old work boxes while Bubba's replacement windows changes out several windows in a pre 1978 house. Neither you nor Bubba work lead safe. Little Johnny ends up with an elevated blood lead level. Mom and Dad get a lawyer. Bubbas windows disappears, and you being a good electrician have insurance. Guess who pays? The lawyer would crucify you. You mine as well accept the fact that in the coming months every ambulance chaser is going to jump on the lead band wagon.

Class....$195 includes certification.
Firm certification $300 with the EPA

I went on and took the lead inspector class...$595.
I can move forward and take the federal test if I want. More $$$$$

If you add a HEPA vac to the mix you are going to be out $1000 or more. The alternative is no pre 1978 house work. The firm must be certified and one person has to be certified for pre 78.

Remember, if your employees use respirators, there is a big OSHA can of worms lurking out there.

c2500

 

[c2500]

I haven't taken the class yet but I have talked to others that have. I was under the impression that while it applies only to home older then '78, it applies to ALL commercial as they are still using some lead paint in comercial to this date.

Can someone confrim this?

Thanks

It is for daycares or child occupied facilities. COF means one child has 2 visits per week for 3 hours each visit and a cumulative time there of 60 hours in a year.

There are some provisions for commercial that have not been determined yet...we have 2 years or so before those hit.

c2500

 

[PetrosA]

One of the rules as it was explained to me should go over REALLY well with homeowners - once the plastic is up and a section of house is blocked off, the homeowner is not allowed access to it at all, for any reason. Imaging getting your kitchen remodeled and not being able to answer questions while the project is under way because you're not allowed into your own kitchen. Beauuuutiful lawmaking.

And the best part of it all? The disposal of the drop sheets, trash bags etc. - they go into the regular trash in taped up bags just waiting for the bulldozer tracks to come along and rip it all open in the landfill. Sweet.

 

[e57]

Oh this thing is littered with vague information and lots of cost and risks. And thats what I have a problem with... I'm not sure how many people saw this comin' but I wasn't one of them.... And been firing some emails to a few other guys who just now heard of it - and we're all wondering how serious or how fast we need to react to it. Thursday?!?!? "Earth Day"

 

[goldstar]

The panic is already starting to set in. EC's as well as plumbers, tin knockers, painters and carpenters are signing up for for lead safe courses and getting certified. In the last month lead-safe classes have filled up to the point of saturation here in NJ. You'd be lucky to get into any classes at any price. Even Mike Holt has jumped on the bandwagon and started publishing newsletters warning that you must be certified.

What everyone needs to understand is that even if you don't disturb the square footage, you still must work lead safe. So, go on out and buy that $400-$600 True HEPA vacuum. And no, that HEPA filter on your wet/dry vac does not count and will generate lead dust.

Add to this the test instrument that will probably cost you upward of $1K, add to this the time to installing plastic and taping it off on all those pre 1978 jobs, add to that taking down the plastic and disposing of it properly, add to that the cost of cleaning up with a damp mop or swiffer several times, add to that the additional cost of insurance premimums, etc. Many are coming out and warning of the implications and consequences of non-compliance but no one from the EPA or States are coming out to answer specific questions like who bears the ultimate responsibility on jobs where more than one contractor is disturbing ceiling or wall space.

For those that disagree, consider this...

you go cut in a few old work boxes while Bubba's replacement windows changes out several windows in a pre 1978 house. Neither you nor Bubba work lead safe. Little Johnny ends up with an elevated blood lead level. Mom and Dad get a lawyer. Bubbas windows disappears, and you being a good electrician have insurance. Guess who pays? The lawyer would crucify you. You mine as well accept the fact that in the coming months every ambulance chaser is going to jump on the lead band wagon.

I don't disagree with this one bit. Lawyers use the shotgun approach in law suits. They'll go after anyone who has insurance or $$$. This is going to be a mess until the EPA straightens it out. If you think EC's are cutting each others throats over jobs now wait until you start competing over these jobs. We'll be turning each other in for non-compliance to local authorities on a regular basis.

 

[e57]

The panic is already starting to set in. ~

Add to this the test instrument that will probably cost you upward of $1K, add to this the time to installing plastic and taping it off on all those pre 1978 jobs, add to that taking down the plastic and disposing of it properly, add to that the cost of cleaning up with a damp mop or swiffer several times, add to that the additional cost of insurance premimums, etc.


~~~~ This is going to be a mess until the EPA straightens it out. If you think EC's are cutting each others throats over jobs now wait until you start competing over these jobs. We'll be turning each other in for non-compliance to local authorities on a regular basis.

Panic is right... I just looked into classes last week - hesitated and four months worth are full in the cheapest closest location, and two months on the next best - 3 weeks to a place moderately priced and 2 hours away is what i just got into...

As far as testing goes - I was tooling through the maze of EPA sites of the last few days - and apparently - This one is "certified" (and apparently the only one - if not the only of it's kind - ADVERTISED on the EPA website with tax-payer dollars I might add.... ) I've seen the 'gun' on 'this old house' and not sure if it is EPA approved.... (???)

And I have serious doubt of the Fed EPA sorting anything out with contractors - they clearly are federally paid tree huggers who see us as the enemy and care little about what is left in our deep pockets.... :roll: In my infinite amount of time late at night, I was browsing through the comments about the fees cost of compliance and it certainly seems that way...

I also do not see the State (or at least mine - who has a hands off approach right now) or City/County governments getting involved - That said - who does get the call for enforcement???? (I'm lookin'....) I'm sure 1800-law-suit knows...

But what you do get out of it... Free Advertising along with your $300 registration.... $250+ Class, and enormous hassle....

 

[WinZip]

Goldstar I agree 100% with it being a cash cow for the feds and driving up costs. They are pencil pushers in cubicles that need to justify their jobs.What's next, mercury in t stats, fiberglass insulation,glue in plywood etc. ? We will be dressed like astronauts with mobile test labs trailered behind the truck. In NJ when you go into business they should give you a leaflet that says on page 1 "don't do anything" and on page 2 it says "if you did something you better get a lawyer".

My god I had one heck of a laugh reading whats posted above LMAO...

 

[Rockyd]

Originally Posted by revolt
Goldstar I agree 100% with it being a cash cow for the feds and driving up costs. They are pencil pushers in cubicles that need to justify their jobs.What's next, mercury in t stats, fiberglass insulation,glue in plywood etc. ? We will be dressed like astronauts with mobile test labs trailered behind the truck. In NJ when you go into business they should give you a leaflet that says on page 1 "don't do anything" and on page 2 it says "if you did something you better get a lawyer".

My god I had one heck of a laugh reading whats posted above LMAO...

The lawyers keep at it, and they'll need protection from fast lead from contractors...

 

[e57]

More mis-information - and being put out to the general public...

This NPR radio story got all the 'players' they took what little time to muster... A lead training provider who says 'we're draggin our feet the laws been around since '08' (I certainly didn't know...) - and a over-achiever contractor looking to scare the bejesus out of everyone by pointing to "Lead Abatment" guidelines instead of the guidelines of the RRP "Renovation" aspect of the law....

 

[GUNNING]

grrrrr......

grrrrr......

My class was Wednesday but got bumped to Thursday. Not sure if the check and paperwork to the EPA was an application or a signed sealed and delivered admission of guilt for not being registered with them before the 21.
Did a job today with a Dude that showed up in a pickup and pulling a trailer. He did cabinetry and plumbing while I was there. Like he is really worried about the Feds. Nice truck and matching trailer though. No lettering to clutter up the custom paint job.

 

[e57]

My class was Wednesday but got bumped to Thursday. Not sure if the check and paperwork to the EPA was an application or a signed sealed and delivered admission of guilt for not being registered with them before the 21.

Hey - cool "Earth Day" (Yeah you thought it was a weird date to start a legal dead-line)

Maybe you'll get a special treat?!?

Anyway I wouldn't sweat being late - the 250,000+ of us out there are in line behind you.

I looked up classes and there was a class available on the 22nd on this last Friday - on this Monday the next 12 classes filled up...

 

[c2500]

One of the rules as it was explained to me should go over REALLY well with homeowners - once the plastic is up and a section of house is blocked off, the homeowner is not allowed access to it at all, for any reason. Imaging getting your kitchen remodeled and not being able to answer questions while the project is under way because you're not allowed into your own kitchen. Beauuuutiful lawmaking.

And the best part of it all? The disposal of the drop sheets, trash bags etc. - they go into the regular trash in taped up bags just waiting for the bulldozer tracks to come along and rip it all open in the landfill. Sweet.

This is not a big deal. It goes into the lined landfills as opposed to C&D. SO the lead dust will stay trapped.

c2500

 

[c2500]

Add to this the test instrument that will probably cost you upward of $1K, :

There is not test instument required for RRP. You use the little lead check pencils...a few bucks each or cheaper in bulk. You simply have to document the test.

Now if you are a certified lead inspector or lead risk accessor...more training than RRP, you can use an XRF machine to test for LBP. This machine starts around $9000 for a refurb and I understand gets into the $60,000 range. It uses a radioactive source that dies in 9-15 months and must be re-sourced for $3000-$5000 depending on who made it.

The other choice is lab testing via destructive paint chip sampling, but once again only a Lead inspector or Risk acessor can do the sampling.

c2500