As I have mentioned in another thread, the new rules - in effect for a year now - have not only reduced the size of the disturbed area to 2 sq. ft TOTAL for the job, but also require barriers, HEPA vacs, certification, lead testing, recordkeeping, etc.....
I know it's hard not to rant about regulations, but it's also important to make a real effort -- as a business potentially affected by those regulations -- to understand them as clearly as you can and clear up any misconceptions that might stand between your opinions and the truth.
As mentioned in the other thread, for instance, the EPA rule has not changed -- RRP doesn't kick in unless you're disturbing 6sf or more of interior painted surface per room.
Also important to note that you are not required to perform lead tests, either. If you simply treat every potentially-qualifying job site as if lead is present and practice full containment, you don't have to test for anything but a clean surface at the end. You CAN test for lead if you want (and if your customer agrees), and if you're lucky and don't detect lead you can use the test as a way of working around the full containment.
Nor is it enough for you to be working for a 'certified' GC .... YOU need to have your papers in order.
This is true, and will become a bigger issue as time goes on. Alliances between compliant and non-compliant trade partners will dissolve as enforcement steps up and liability suits get filed. You need to not only cover your butt, but you need to make sure your GCs are covering their butts, too. There will be liability suits.
I'm getting differing opinions as to the test kits you can buy at the hardware store.
This is covered by EPA guidance:
http://www.epa.gov/lead/pubs/testkit.htm
There's some dispute as to what is a "HEPA" vacuum.
Well, there's not much dispute about what a HEPA vac is
, but there is an issue in that the EPA only published vacuum guidance instead of an actual standard. So they told everyone that a standard canister-style vac with an add-on HEPA filter wouldn't cut it, but they didn't tell us which vacs were OK. The mfrs are catching up, though, and are getting more certified (by letter from EPA) HEPA vacs on the market.
And yes, they're expensive. Mine set me back $650. But you do get to write the tool off...like I did, just a few hours ago while working on my taxes.
Anyway, enough of the technical points, my real point is that everyone needs to stop screaming about this and they need to get informed properly. Screaming won't do any good, this is the future and it is now. And literally everything you really need to know is covered in EPA guidance, available online. The actual facts of compliance are not that horrible -- some would say a conscientious tradesperson should already have been employing most of the jobsite diligence already. Yeah, there's recordkeeping, but manila file folders are cheap and it's not really that much paper. Yeah, the certification costs money and so does the training, no one likes that but we all ought to be used to jumping through regulatory hoops and writing off the costs of doing business by now. That's how we got where we are, right?
