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06-18-2010, 10:45 PM #1
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And so it comes to pass .................
Well, there has been some breathing room made for enforcement of the RRP lead rule
http://www.dealer.org/files/EPA_Dela...nt_6_18_10.pdf
philIt's better to try and fail, than fail to try.
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06-19-2010, 08:07 AM #2
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Re: And so it comes to pass .................
Thanks Phil.
Now we can continue polluting our customers, at least until the end of the year !
Yippie !
;-)Chuck
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06-19-2010, 08:12 AM #3
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Re: And so it comes to pass .................
This is all getting confusing to me, I just received an email from my RRP training organization that Mass. may be taking over the RRP Rule. So I guess in Mass, if they take over the RRP Rule, the delayed EPA enforcement dates will not be applicable? How is one to know this? The email states:
On April 6th, the Commonwealth of Massachusetts filed Emergency Regulations to takeover the governing of the new EPA RRP rule. These Emergency Regulations are currently 'in effect'; however, they are not being enforced. The Commonwealth has until late June to amend their filing and formally submit it to the EPA or the Emergency Regulations will expire on July 6th (90 days after their initial filing).
This decision is due within 2 weeks and likely will have a major effect on all Massachusetts contractors.
IEE will send you updates as more details emerge.
Please be aware, given the significant involvement of the various Massachusetts department heads (including several high-level Building Officials) that if the Commonwealth does submit the filing, it intends to assertively enforce the Renovation rule at the state and local level for any contractor not in compliance.
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06-19-2010, 12:22 PM #4
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Re: And so it comes to pass .................
Ted,
What that means is that Mass. is adopting the rule as their own. That means that the state DEP has the authority to enforce it. They also can be even stricter. If a state does not have parity with the Feds by adopting the rule then only EPA inspectors can enforce it.
It really doesn't change anything as far as guys needing to be certified and compliant, it just delays applying penalties to the offenders, whomever they are.
The rule is not going away.
Also, when the local legislatures accept it, the building departments in those localities can then require a certification number in order to pull a permit.
philLast edited by philthegreek; 06-19-2010 at 12:24 PM.
It's better to try and fail, than fail to try.
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06-20-2010, 10:58 AM #5
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Re: And so it comes to pass .................
No, actually Chuck you can't,not that you would. You just have some time left to get people trained if they aren't, and get the firm certification if you don't, before they ( the epa) will start enforcing that part. The lead safe work practices are non negotiable. Since the government can't put parents in jail for letting thier kid eat paint chips this is the best next thing.
kevin zale
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06-20-2010, 04:40 PM #6
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Re: And so it comes to pass .................
Really! So all those, (must be millions) kids are just going to get lead poisoning and the parents get off scott free? I can read it in the history books already. "200 yrs ago, parents got away with killing their kids with lead paint".
I see kids licking houses all the time, but I don't say anything or worry about it because the paint isn't lead based."I would remind you that extremism in defense of liberty is no vice. And let me remind you also, that moderation in the pursuit of justice is no virtue."
--Barry Goldwater AD 1964
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06-21-2010, 04:15 PM #7
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Re: And so it comes to pass .................
I received an email today from Architectural Testing CORRECTING a mass-mailed newsletter referencing the same memo as at the beginning of this thread, claiming the memo is a HOAX, and that the rule has NOT been delayed. Anyone have more info? Anything on the official EPA sites?
"If you only have a hammer, all problems look like nails"
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06-21-2010, 04:23 PM #8
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Re: And so it comes to pass .................
I saw this on Twitter, according to the NAHB there a delay.
http://ht.ly/21c4a
http://www.nahb.org/news_details.aspx?newsID=10957"We are going to relentlessly chase perfection, knowing full well we will not catch it, because nothing is perfect. But we are going to relentlessly chase it, because in the process we will catch excellence. “
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06-21-2010, 05:14 PM #9
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Re: And so it comes to pass .................
Found it on the EPA site, so I guess Architectural Testing has been misinformed (perhaps by the EPA itself).
http://www.epa.gov/lead/pubs/giles_RRP_memo.pdf
This is what they sent me today:
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Please disregard the Special Edition of the InstallationMasters Newsletter that was distributed this afternoon. We have just found out that it is a hoax. The EPA DID NOT delay the implementation of the Lead Paint Renovation Rules. The letter that was attached to our newsletter was a fake.
The letter had come from a reliable source, so we believed that it was real. I just contacted the National Lead Information Center, and they told me that the letter is a fake. They are in the process of determining the source of the letter. I want to apologize for any inconvenience that this may have caused. In the future, I will be personally be confirming all information that comes in about the Lead Paint Renovation Program.
If you have any questions or comments, please feel free to contact me.
Benjamin E. Myers
Project Manager - Certification Services
130 Derry Court
York, PA 17406-8405
Main: 717.764.7700
Direct: 717.767.3967
Fax: 717.764.4129
E-Mail: bmyers@archtest.com
Web: www.archtest.comLast edited by hdrider_chgo; 06-21-2010 at 05:22 PM.
"If you only have a hammer, all problems look like nails"
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Weatherizing vintage buildings in Chicago
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06-21-2010, 05:38 PM #10
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Re: And so it comes to pass .................
The molasses just gets stickier and sticker :-)
philIt's better to try and fail, than fail to try.
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06-21-2010, 06:10 PM #11
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Re: And so it comes to pass .................
From what I heard, the fees for having a RRP license in MA will be around...$500 per year or more. Taxachusetts lives up to it's name. Found this
fee schedule on the MA State Website..
http://www.mass.gov/Elwd/docs/dos/le...edule_2003.pdfLast edited by Otis P. Driftwood; 06-21-2010 at 06:13 PM.
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06-21-2010, 07:22 PM #12
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Re: And so it comes to pass .................
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06-21-2010, 08:15 PM #13
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Re: And so it comes to pass .................
Dog and Pony show guys.
It will be 2012 until I'm certified... Until then post 78.
I'll let you guys figure it all out.Louisville Exteriors
Professional Installers of:
Siding | Replacement Windows | Roofing | Hand Rails | Gutters | And More!
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06-21-2010, 08:39 PM #14
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Re: And so it comes to pass .................
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06-21-2010, 08:53 PM #15
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Re: And so it comes to pass .................
I dont blame you JB. I have a job sold now on a 1965 ranch thats getting a second floor addition. I am 30 days plus waiting for CR and firm docs. Owners are young and not happy that they may have to get extra financing for possible lead paint costs. Since I am removing over 2000 sq ft of plaster and 800 ft of trim, 20 wood sashes and frames, costs could be way up there. I do have cheap access to an XRF gun, hopefully it's just regular paint. Since I will have to do the demo, this questionable amount of labor is also messing with scheduling future jobs.


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