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2011 RRP Changes

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  • 2011 RRP Changes

    Thought it wouldn’t hurt to begin talking on the 2011 RRP changes that will most likely take place. In general, the changes are ...

    1. Certified renovators will get a new way to test for lead based paint. This would be paint chip sampling.

    2. On exterior work, put up vertical containment if work will affect surfaces within 10 feet of the property line. Assumption is “neighbors” property line.

    3. Dust Sampling test by Lead Inspector, Assessor or Dust Sampling Technician after use of heat gun at below 1,100 degrees … removal or replacement of door or window frames … scraping 60 square feet of a painted surface and removing more than 40 square feet of trim/molding/cabinets (or other fixtures).

    4. Clearance testing by the same folks mentioned in number 3. This will be required after demolition of 6 square feet of plaster and lath … using machines to remove paint (sanding, grinding, power planning, needle gun & abrasive blasting).

    Good reason to begin talk, is that your contracts may need to be changed. You may also have to add cost into estimates of jobs coming up in late summer and you may want to consider becoming a dust sampling technician.

    Note: Not all states allow dust sampling technicians.
    Dean

  • #2
    Re: 2011 RRP Changes

    Dean - can you point me to dust sampling technician certification (or whatever it is).

    Thanks, -Norm

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    • #3
      Re: 2011 RRP Changes

      Hello Dean. I hope things are well with you. Thanks for your past and continuing efforts to keep us updated.

      Q2. What exactly does the "if" mean in "if it will affect surfaces within 10ft of the property line?" Is this another one of those judgement call rules?

      Q3. I know you and I discussed dust sampling tech a while back. I forgot to ask if I'm allowed to dust sample my own jobs.

      Q4. Can I clearance test them too?


      Thanks.

      Comment


      • #4
        Re: 2011 RRP Changes

        just what I need-another change in the rules I already am having trouble understanding.

        Thanks for the updates anyway.

        Comment


        • #5
          Re: 2011 RRP Changes

          Originally posted by VTNorm View Post
          Dean - can you point me to dust sampling technician certification (or whatever it is).

          Thanks, -Norm
          http://www.epa.gov/lead/pubs/samplingmodel.htm

          8 hour training course I believe. Be sure to check your state first. Example, I am in Texas. The EPA handles RRP, but the state doesn't allow for dust sampling techicians.
          Dean

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          • #6
            Re: 2011 RRP Changes

            The House Oversight Committee is going to be looking into this.
            "The only communists left in the world are in American Universities."

            --Mikhail Gorbachev

            Comment


            • #7
              Re: 2011 RRP Changes

              I can't remember where I read it , but I was thinking we can test our own stuff , it was just not recommended was all. I sure am thinking with these changes coming that I really need to look in finding training for the dust sampling. Seeing how their is no one with in 150 miles of me.
              Randy
              ________________________________________________

              The bitterness of poor quality lingers long after the sweetness of a cheap price is forgotten

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              • #8
                Re: 2011 RRP Changes

                Originally posted by Shawn Prentice View Post
                Hello Dean. I hope things are well with you. Thanks for your past and continuing efforts to keep us updated.

                Q2. What exactly does the "if" mean in "if it will affect surfaces within 10ft of the property line?" Is this another one of those judgement call rules?

                Q3. I know you and I discussed dust sampling tech a while back. I forgot to ask if I'm allowed to dust sample my own jobs.

                Q4. Can I clearance test them too?


                Thanks.
                Good to see you are still alive Shawn!

                Q2. The EPA gives the Certified Renovator some judgement calls on when the vertical containment would be used. Good example would be if the neighboring building is 5 feet away or if a windy day. No actual specifications, except they don't want dust getting on a neighbors property.

                Q3. They haven't made a final decision on this yet. They were thinking of allowing another person (other than the person doing the work) in the company to do it. For us solo guys, we may have to have an independent person do this.

                Q4. Clearance test is different then dust sampling. However, they haven't made a decision on this either. Most likely like Q3, but not sure.
                Dean

                Comment


                • #9
                  Re: 2011 RRP Changes

                  Originally posted by Dick Seibert View Post
                  The House Oversight Committee is going to be looking into this.
                  I have heard this. I see two main hurdles. One, the house voted and pushed EPA to begin all this RRP mess to begin with. Second, clearance testing was an agreement to settle a lawsuit along with the Opt-Out.
                  Dean

                  Comment


                  • #10
                    Re: 2011 RRP Changes

                    Originally posted by Randy Bush View Post
                    I can't remember where I read it , but I was thinking we can test our own stuff , it was just not recommended was all. I sure am thinking with these changes coming that I really need to look in finding training for the dust sampling. Seeing how their is no one with in 150 miles of me.
                    The big problem I see, is what the EPA is thinking ... and what they actually put in the law. Right now, the EPA was talking about things, but the actual regulation doesn't show what they were talking about.

                    Typical.

                    As far as doing it yourself, see my response to Shawn
                    Dean

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                    • #11
                      Re: 2011 RRP Changes

                      Dean,
                      Thanks for the heads up. I've been trying to find a post from a while ago that showed the number of lead poisoning cases caused in non-RRP situations (i.e. homeowner or non-contractor jobs). Does anyone remember that thread?
                      "American political opportunities are heavily loaded against those who are simultaneously intelligent and honest" --Richard Dawkins

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                      • #12
                        Re: 2011 RRP Changes

                        Thanks Dean.

                        So, when are these proposed rules supposed to go into effect (your best guess)?
                        Last edited by Shawn Prentice; 01-23-2011, 02:40 PM.

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                        • #13
                          Re: 2011 RRP Changes

                          Originally posted by m beezo View Post
                          just what I need-another change in the rules I already am having trouble understanding.

                          Yep. Most of the jobs I did last year were under RRP and the more I think about the rules, the more confused I get.

                          Comment


                          • #14
                            Re: 2011 RRP Changes

                            Originally posted by Shawn Prentice View Post
                            Thanks Dean.

                            So, when are these proposed rules supposed to go into effect (your best guess)?
                            Finalize in July, but they may give a month or two past that time before implementation. Just not sure.
                            Dean

                            Comment


                            • #15
                              Re: 2011 RRP Changes

                              For the record, removing and replacing doors (not including jambs/frames or casings) does NOT fall under RRP rules, correct?
                              Richie Poor

                              See no evil, hear no evil, speak no evil, value engineer your unit prices.

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