rrp on a remodeled house

[S.Joisey]

80 yr old house was completely remodeled 5 years ago. Everything went except the brick walls.

I know. I was working next door at the time and watched the whole process.

The contractor didn't detail the porch steps and railings correctly, so I've been asked to replace them.

It is all new material. Obviously. Finger jointed risers, factory milled hand rails. I can tell you where some of the stuff was bought.

Is this an RRP job?

[Bill Robinson]

If you are not disturbing lead paint, no!

Show the homeowner the Renovate Rite pamphlet anyway in case someone brings that up later.

I believe you can test for lead paint in Jersey, even down the shore

[Chuck Kiser]

If it was a total gut remodel 5 years ago, and you are sure everything is new except the brick walls then no, it is not a RRP job. But as Bill stated, pamphlets are cheap insurance.

[S.Joisey]

There is no LBP involved. My only concern is documentation - proving to an auditor that there indeed was no LBP and no need to test for it.

To my thinking, pictures would be enough documentation. One can tell by looking this is new construction.

Does that sound reasonable?

[Catspaw]

To be safe, I would perform a lead test (which will of course be negative) and document the results.

- Rich

[Dean CRCNA]

80 yr old house was completely remodeled 5 years ago. Everything went except the brick walls.

I know. I was working next door at the time and watched the whole process.

The contractor didn't detail the porch steps and railings correctly, so I've been asked to replace them.

It is all new material. Obviously. Finger jointed risers, factory milled hand rails. I can tell you where some of the stuff was bought.

Is this an RRP job?

Yes, it is an RRP job. Like others have mentioned, I would do a lead test.

[tomthetoolman40]

My main concern would be, is the soil contaminated with LBP dust from the other remodel? I'd test and document the soil condition and have the client sign off on the results prior to starting your project, to relieve you of liability from the other contractor's work.

[Bill Robinson]

Yes, it is an RRP job. Like others have mentioned, I would do a lead test.

This can be misleading Dean, please clarify.

While the job as stated sounds like there will be no lead paint disturbed the home was built before 1978.

Being built before 1978 the house is subject to the rule but there will be no lead paint disturbed.

Is that an RRP job or simply subject to the rule?

Matter of understanding. As I view it, if it is an RRP job there must be containment and cleaning verification.

If there is no lead paint disturbed it is not an RRP job.

[Dean CRCNA]

This can be misleading Dean, please clarify.

While the job as stated sounds like there will be no lead paint disturbed the home was built before 1978.

Being built before 1978 the house is subject to the rule but there will be no lead paint disturbed.

Is that an RRP job or simply subject to the rule?

Matter of understanding. As I view it, if it is an RRP job there must be containment and cleaning verification.

If there is no lead paint disturbed it is not an RRP job.

Officially, the only way to know if it has lead based paint or not, is to test. If no test is done, then you have to do RRP.

Example: If I personally replaced the siding on a house 6-months before and then 6-months later I needed to demo the siding ... I would have to either test (and find it negative) or do RRP.

I realize this sounds stupid, but according to RRP ... it must be done (at least from what I read)

[S.Joisey]

Officially, the only way to know if it has lead based paint or not, is to test. If no test is done, then you have to do RRP.

Example: If I personally replaced the siding on a house 6-months before and then 6-months later I needed to demo the siding ... I would have to either test (and find it negative) or do RRP.

I realize this sounds stupid, but according to RRP ... it must be done (at least from what I read)

Sounds more reasonable to supply your paperwork showing that you did the work 6 months earlier.

Proposals and invoices are better evidence than a lead test. Lead tests are based on the honesty of the tester - they can be easily faked. Proposals and invoices for work done are less easily faked.

Doing and billing for lead tests (and soil tests were mentioned, too) also is not complimentary to me as a contractor. Both I and the owner know it os obvious I am only disturbing new material. If I make an issue of lead, I look like someone who slavishly follows some rules regardless of their practicality.

[Bill Robinson]

Agreed, I am making the point that if there is no lead paint being disturbed I would not label that an RRP job.

Of course testing is required to confirm that.

Only jobs where lead paint is involved are RRP jobs in my world.

But if calling it an RRP job is more convenient than have at it.

Note it is not necessary to establish containment, and test out (cleaning verification) t if there is no LBP.

[Dean CRCNA]

Sounds more reasonable to supply your paperwork showing that you did the work 6 months earlier.

Proposals and invoices are better evidence than a lead test. Lead tests are based on the honesty of the tester - they can be easily faked. Proposals and invoices for work done are less easily faked.

Can't disagree with you.

Just wanted to state how the EPA considers it.

[S.Joisey]

Can't disagree with you.

Just wanted to state how the EPA considers it.

Does the EPA have a concept called "Following the intent of the rule"?

[ThingOfBeauty]

From page 6 of the EPA RRP FAQ page:

Question (23002-15694)
Does the RRP Rule apply to work on windows that have been installed within the last 20 years in a pre-1978 housing unit? Would confirmation of the window installation based on property owner documentation (i.e., receipts, warranty paperwork, contracts) and/or date of manufacture of the windows
be sufficient to exclude this work from the lead-safe work practices and other requirements?
Answer
The RRP Rule applies unless you have determined that all the components affected by the renovation, including the windows, are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight. This determination must be made either by a certified inspector or risk assessor, or by a certified renovator using an EPA recognized test kit or performing paint chip sampling. You must keep records of any lead-based paint free determination and make the records available to EPA if requested.

Can't argue that it makes sense, but it is the rule.

[S.Joisey]

From page 6 of the EPA RRP FAQ page:



Can't argue that it makes sense, but it is the rule.

Thanks Doug, for finding that. I haven't had time to dig though the EPA Q and A's myself.