EPA RRP...... my day in certificationville.

[iwire]

Instructor at Cont Ed class said the 6 square feet is per room, was he correct?

I do not know the answer to that.

But I do know 6' feet is just a square a little less than 2'-6" on each side and I am not sure how I would handle it if I accepted a job that I figured would stay under 6 sq ft but once I was into the job things went badly so I would have to exceed 6 sq ft to complete the job.

Would I stop and tell the customer I cannot complete the work and they will have to hire a company that is certified or would I ignore the rule and expose the company I work for to a large fine?

 

[Rewire]

I am interested to know of all of these reasons, can you tell us a few?

It just seems a busy residential service company would be running into this law almost daily.

In my position I have refused to do a number of jobs because of this law and we are not in the residential business.

First reason you dont need it would be you work in post 1978 homes next reason is if you are not renovating. We do alot of work that does not require disturbing paint.

 

[Rewire]

Instructor at Cont Ed class said the 6 square feet is per room, was he correct?

when I had the class it was 6 sq/ft interior and 20 sq ft exterior

 

[kwired]

The EPA lead rule requires certification if you disturb 6 square feet of wall. This comes out to 92 single gang cut-in boxes @ 9.3 SQ. in. per box if you do precise cuts, about 86 boxes if you do sloppy cuts. Of course, a two gang box is equal to 2. But if you are cutting in ceiling boxes, then you need to subtract 11 sq. in. for each one. So for a typical re-wire of a pre 1978 house: the limit is 15 ceiling boxes and 52 cut-in boxes. I am not counting where you blow holes in the plaster due to slight miscalculations. Exterior boxes are included if they are in painted surfaces. Conclusion: If you are adding a few outlets, wear a mask and use a HEPA vacuum to protect you and your customer. If you are re-wiring entire houses get an EPA certificate and charge an EPA abatement fee.

Just working in presence of lead containing materials and lead abatement are two completely different tasks. Working where lead is present is nothing more than properly managing that lead if it is disturbed, abatement is when actual removal of the lead is the main goal of the work being done.

 

[stevenje]

when I had the class it was 6 sq/ft interior and 20 sq ft exterior

According to my Joint EPA-HUD Student Manual (EPA-740-R-09-002) (Feb 09) Decision Logic Chart - Flow Chart 1 - following page 3-7 page 1 of 8.

It states:

"Work consists of only minor repairs or maintenance that disturbs less than 6 square feet of painted surfaces per room for interior activities or less than 20 square feet of painted surface for exterior activities."

 

[Rewire]

According to my Joint EPA-HUD Student Manual (EPA-740-R-09-002) (Feb 09) Decision Logic Chart - Flow Chart 1 - following page 3-7 page 1 of 8.

It states:

"Work consists of only minor repairs or maintenance that disturbs less than 6 square feet of painted surfaces per room for interior activities or less than 20 square feet of painted surface for exterior activities."

dug our my book and found it. I guess the instructor misspoke. You still need to be certified even if you disurb less than 6 sq ft.

 

[norcal]

So what happens to homeowners doing work on their home? My house was built in 1943 & almost all woodwork dates from 1980 onward, all doors, trim,siding, has been removed, & replaced, interior, & exterior,with the exception of a couple of closets. I see this as a sticky question with a lot of ways to get in hot water.

 

[Fulthrotl]

So what happens to homeowners doing work on their home? My house was built in 1943 & almost all woodwork dates from 1980 onward, all doors, trim,siding, has been removed, & replaced, interior, & exterior,with the exception of a couple of closets. I see this as a sticky question with a lot of ways to get in hot water.

homeowners can do their own work without certification.

only people doing this for money... need the cert.....

get out the 80 grit and have a party!

 

[kwired]

So what happens to homeowners doing work on their home? My house was built in 1943 & almost all woodwork dates from 1980 onward, all doors, trim,siding, has been removed, & replaced, interior, & exterior,with the exception of a couple of closets. I see this as a sticky question with a lot of ways to get in hot water.

homeowners can do their own work without certification.

only people doing this for money... need the cert.....

get out the 80 grit and have a party!

Correct, HO can do what they want. When someone is hired to do work that creates this lead dust the intent of the law is to protect those living in the space - especially children that seem to be even more vulnerable to effects of lead dust.

If owner doesn't want to follow proper protective procedures who are they going to blame other than themselves for exposure?

Now lets complicate things, owner is doing a lot of rennovation, tearing up walls, doors, trim, etc. that all contains lead. Then he hires you to do some wiring. He has not taken any lead safe precautions, how are you as a paid contractor supposed to manage any dust you make even though it is nothing compared to what he has already done? He very well may still have an obvious dust mess that you are stirring up just walking around the place.

 

[renosteinke]

Here's how it looks to me:

The rules apply to ALL residences built before 1978, even if there was never any lead paint, even if everything that might have had lead paint has been replaced, etc.

The procedure is the same .... provide the paperwork, test, do the work as the test results suggest.

The only way to avoid this is to have a separate lead assessment performed - certified testing and remediation contractor, not just the RRP - and have the place certified as either being 'lead free' or as having all lead "encapsulated."

It seems that, for all practical purposes, the only way to 'encapsulate' is to put up vinyl siding.

As I said earlier .... I think the result will be that no legitimate contractor will touch any house built before 1978.

The suggestion to 'ambush' the noncompliant guy at the end of the job? That's nothing new .... you can already do the same thing if the guy lacks all necessary licenses; no court will enforce the contract. Ditto for permits, etc. Yet, it seems that folks are quite happy to hire illegal contractors, and honor their contracts with them.

Nor, for that matter, is anyone going to work witout getting a substantial deposit. Here the practiceis half in advance, half on completion.

 

[Rewire]

Correct, HO can do what they want. When someone is hired to do work that creates this lead dust the intent of the law is to protect those living in the space - especially children that seem to be even more vulnerable to effects of lead dust.

If owner doesn't want to follow proper protective procedures who are they going to blame other than themselves for exposure?

Now lets complicate things, owner is doing a lot of rennovation, tearing up walls, doors, trim, etc. that all contains lead. Then he hires you to do some wiring. He has not taken any lead safe precautions, how are you as a paid contractor supposed to manage any dust you make even though it is nothing compared to what he has already done? He very well may still have an obvious dust mess that you are stirring up just walking around the place.

First you need to be a certified lead renovator. If you are disturbing less tghan 6 sqft per room then other than a dust mask for your protection you dont have to apply the rules.

 

[stevenje]

dug our my book and found it. I guess the instructor misspoke. You still need to be certified even if you disurb less than 6 sq ft.

I think it is a common misconception. I was told the same thing from the CCB (Construction Contractors Board) enforcing agent here in Oregon. Even the basic lead RRP handout he passed out was wrong.

True or not, I was also told than you needed to be certified just to give a bid on a project that has the lead paint issue . I haven't read the statute if there is one.

 

[kwired]

First you need to be a certified lead renovator. If you are disturbing less tghan 6 sqft per room then other than a dust mask for your protection you dont have to apply the rules.

Not certified, so I don't know for certain, I was certified under some old rules at one time, as well as a little common sense tells me that even if disturbing less than 6 sq ft, you should make some effort to contain your lead containing debris, might not require as thorough of an effort as is required if disturbing more than 6 sq ft.

In other words don't place a 4000 cfm fan right next to where you are cutting in that outlet box to clear the dust away as you cut the hole, maybe a vacuum is a better idea, even if it is not one designed for containing lead dust.

 

[Fulthrotl]

Not certified, so I don't know for certain, I was certified under some old rules at one time, as well as a little common sense tells me that even if disturbing less than 6 sq ft, you should make some effort to contain your lead containing debris, might not require as thorough of an effort as is required if disturbing more than 6 sq ft.

In other words don't place a 4000 cfm fan right next to where you are cutting in that outlet box to clear the dust away as you cut the hole, maybe a vacuum is a better idea, even if it is not one designed for containing lead dust.

most shop vacs are indoor leaf blowers. they are worse than nothing at all.

you are better off with no air movement, and wiping up with a damp cloth
afterwards. noncompliant, but better than the leaf blower.

lead dust, obviously, settles... an hour or two, and it's on the ground...
the asbestos word, can stay airborne for days....

so, in common sense land, far away from certificationville, a real hepa vac,
with certification, right next to whatever is cutting, is going to take care of
the problem pretty well... a piece of plastic 6' square put underneath to get
any strays should be good enough.

it isn't good enough in compliance land. it is what it is. my menu of flat rate
charges now has a "EPA mandated lead paint control" item for $400.

that's the basic charge. i explain that the federal government, those same
people who brought us 300 lb. auto bumpers and oil import quotas, had a
bright idea. this is my cost to comply with it, without markup.

i explain that failure to comply, leaves one or both of us open for a fine
not to exceed $37,500 per violation. i'll further explain that they can find
another electrician who isn't certified, who will do the work without proper
procedures, and they probably won't get caught.

it's their choice. i've reached the point where i really don't care what they do.

in the last week, i've picked up 4 service changes. all of them are pre '78.
all my service changes went up $200 to pay for having to deal with this BS.

it's pretty simple... i will have a prep day, and go do all four of the stucco
removals on one day... out comes the fein tool, cut the stucco where i want
it, bag it, and clean up. zip poles at an angle, and plastic from the eaves to
the ground.

then one service per day. i've done two in one day, and that day ended at 9 pm
under a quartz light... one a day is sufficient.

so, five days work, $10,400 gross. i can live with that.