EPA is proposing some changes to the RRP rule which can increase the cost of renovations and repairs significantly. EPA has extended the comment period for these changes until August 6. I feel that as the National HBA you may want to send your comments to EPA. I have prepared a short synopsis of the changes and a cost summary sheet of the additional expenses associated with the proposed changes. Please let me know if you need additional information. The clearance standards are 40 µg/ ft2 on floors, 250 µg/ft2 on interior windowsills, and 400 µg/ft2 on window troughs, based on wipe samples. These criteria are very hard to achieve and many renovation project will not be able to pass these standards during the first clearance thus causing further delay of the project and significantly increasing the cost. An LBP certified technician must prepare and submit a thorough report for the clearance test to the renovation company within 3 days after receiving the test results. EPA preliminary estimate for the cost of clearance sampling is $160.00. EPA also estimated that the cost of the proposed rule for a typical small business averages approximately $1,200.00 per year. I disagree with the EPA’s cost estimate for these projects and feel that they have grossly underestimated the actual cost for conducting these clearances. The protocol requires at least 4 dust wipe samples and one control sample if the renovation involves only one room and up to 16 samples and one control sample if the renovation involves up to 4 bedrooms. In order to expedite the process most contractors will require the samples to be submitted to the lab overnight and obtain same day results which will significantly increase the cost. As a professional consultant who has been in this field for over 25 years and has conducted these types of inspections nationwide, I used our standard cost estimate price structure to estimate the actual cost for this type of sampling. According to our cost estimation, the cost of clearance test for a one room renovation is $400.00 and the cost for a four room renovation is $760.00 per clearance. Attached is our cost estimation sheet to substantiate the cost which is one of the requirements when submitting comments back to EPA. EPA also did not consider the additional cost associated with travel expenses for projects conducted in more rural areas or at a distance from metropolitan areas where certified inspectors and risk assessors will have to travel. Travel expenses can add as much as $500.00 to the cost of one clearance test. EPA also did not consider the added expense if the contractor does not pass the first clearance. Although I agree with EPA that the cleaning verification test can be subjective and dust clearance is a better method to ensure proper cleaning at the end of the job I feel that there is a significant cost factor associated with this type of test which neither the contractor nor the consumer will be able to absorb especially during our present economic condition. At this time analyzing dust samples in the field is not available. Once we are able to analyze these samples in the field then it would be much more feasible to implement these changes.
Proposed changes to the RRP rule may be very costly to contractors, now is the time to act on these changes.
ESHI
Special Announcement
To Fellow Contractors, The Environmental Safety & Health Institute (ESHI) is proud to announce that we have been selected to be the Lead RRP Training Provider for the upcoming National HBA Conference Held in Orlando on January 2011. Registration will open August 1, 2010. Come join us at the National HBA Conference Held in Lead Safety for Renovation, Repair, and Painting Training will prepare professionals performing renovation, repair, and painting in housing and child-occupied facilities constructed prior to 1978. It is required training to achieve EPA certification for those individuals and firms performing this work. This eight-hour course includes six-hour classroom training and two-hour hands-on practicum plus satisfactory completion of the course exam to fully qualify students as EPA Certified Renovators. (Six-hour classroom training can be achieved by taking an online course, and the two-hour hands-on practicum and exam are still required). Mr. Rizk, the main instructor, holds a Masters Degree in Industrial Hygiene and is a Certified Industrial Hygienist with 30 years of experience in this field. He has acted as an expert witness on many litigation cases involving toxic agents. He has extensive experience with Lead Based paint and in addition to the EPA curriculum he will be discussing how to protect yourself and your company from potential liability. He will also be discussing requirements to protect against this type of liability. ESHI is one of the Largest RRP Training Provider in the South East and Expanding Nationwide. ESHI is presently conducting classes for several HBA chapters, so If you are interested in conducting classes for your organization through ESHI please contact Mr. James F. Rizk or Ms. Continuing Education Points: Our Lead RRP class has been approved by Provider: 0001350 Course: 0608492 Effective: 03/09/2010
EPA has posted its preliminary results of the Environmental Technology Verification (ETV) of Lead Test Kits. Based on the preliminary ETV results, no new kits meet both the false negative and false positive criteria. Therefore, pursuant to the RRP regulation, EPA will continue to recognize the LeadCheck® test kit and the State of
It is important to note that the LeadCheck test kit may give you false positive results because it will also react in a similar manner to other metals in paint. LeadCheck results are not all conclusive for lead. When reporting positive results to your clients, general language such as “may contain lead or other metals in the paint” is recommended. Your client is required to provide the report of your results to any potential buyers or tenants and the presence of lead-based paint can affect property values.
It is also important to remember that the LeadCheck test kits should not be used on drywall or plaster.