Posted by Mark Paskell on Mon, Sep 06, 2010 @ 12:47 PM
RRP Implementation Workshops For Contractors
Help for EPA RRP Certified residential contractors has arrived.
The Contractor Coaching Partnership and Shawn McCadden are taking our RRP Implementation Workshop on the road. We have held several in Massachusetts and now will branch out to bring this important workshop to other regions. Together, Shawn and I have created a powerful workshop designed to help contractors navigate the choppy waters caused by the EPA RRP Lead Rule.
Shawn and I will be at the Remodeling Show in Baltimore the week of the 13th. Shawn is the key note speaker on Thursday 9/16/2010. We hope to see you there.
Shawn McCadden, Remodeling Industry Speaker,Educator and award winning author for Remodeling Magazine.
Our next stop is Long Island. On 9/29/2010 we are scheduled to present the workshop at The East Winds Conference Center in Wading River, New York. Our sponsor is Riverhead Building Supply. They have been instrumental in bringing EPA RRP training to over 500 contractors on Long Island this year.
We are fortunate to be joined by Long Island NARI members Attorney Erik Ortmann from Goldberg and Connolly, Attorneys at Law and Ed Palace from Newbridge Coverage Corp. Erik will cover RRP legal issues and Ed will cover RRP insurance. Shawn will cover RRP best practices and documentation, and I will cover RRP marketing and sales strategies. To learn more about Shawn check out his blog called RRPedia. Shawn's RRPedia site is one the most informative independent publications on the EPA RRP Lead Rule.
Here is the flyer for the EPA RRP Workshop on Long Island.
docs/RBS Flyer for BOS RRP WS 9.29.2010.pdf
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Posted by Mark Paskell on Tue, Aug 24, 2010 @ 02:19 PM
This afternoon the MASS DOS posted, Comparison of EPA and DOS RRP Rule Requirements. This post itemizes many of the differences between the EPA RRP Rule and the Mass Lead Rule. One huge difference is the Mass requirement that contractors (with employees)must document that a medical monitoring/respirator protection program is in place. Patricia Sutliffe of the DOS said that this is an OSHA program that has alway been required but has not been widely enforced. She added that bringing this OSHA requirement to the forefront, will aid employers in their efforts to comply with both RRP and OSHA practices and protect the health of employees.
Here is the complete DOS post;
I. Applicability of Requirements
EPA: The EPA RRP Rule applies to renovation, repair and painting (RRP) work conducted for a fee in pre-1978 target housing and child-occupied facilities where the work involves the disturbance of more than 6 ft2 of painted surfaces per room or more than 20 ft2 of paint on exteriors (total), except that the quantity exemptions do not apply to any projects involving window replacement or demolition of structures.
DOS: Same as EPA.
II. Firms or Entities Requiring Licensure
EPA: All firms or other entities performing work subject to the Rule require certification as “Certified Firms.”
DOS: Firms or other entities performing work require licensure as “Lead-Safe Renovation Contractors,” except that the following entities may apply to DOS for a “Contractor License Waiver”:
1. Entities that perform regulated work in facilities that they own, using their own employees.
2. Entities that were certified by EPA (or a state delegated by EPA to administer EPA RRP Rule) prior to July 9, 2010.
DOS also allows Deleading Contractors licensed by 454 CMR 22.00 to perform regulated renovation work without being separately licensed as “Lead-Safe Renovation Contractors.” Entities applying for a “Contractor License Waiver” do not have to pay a fee for the waiver but must subsequently comply with all other provisions of 454 CMR 22.00, including the requirement to have the work supervised by a “Lead-Safe Renovator-Supervisor”, compliance with work practices (including cleanup), notifications, cleaning verification and recordkeeping.
III. Contractor Licensing Fee and Required Documentation
EPA: $300 for five years. Applicants must submit identifying information, list of professional certifications related to lead-based paint activity and list of previous violations related to lead-based paint activity.
DOS: $375 for five years. In addition to filling out identifying information on application form, applicant must:
1. Document that a person in a supervisory or management capacity has received the one-day Lead-Safe Renovator-Supervisor (“Certified Renovator”) training.
2. Document that a medical monitoring/respirator protection program is in place (entities with employees only). Program templates are on DOS’s website.
3. Submit information related to organization of the business or entity – corporate articles of organization, business certificate, etc., as applicable.
4. Submit lists of current and previous employees.
5. Document workers compensation coverage (entities with employees).
6. Affirm compliance with Massachusetts tax laws, including DOR, DUA, FSC.
7. Submit lists of occupational health and safety-related violations, notices of noncompliance, enforcement actions, etc.
IV. On-site Supervisor Requirement
EPA: EPA requires the supervisor (“Certified Renovator”) to be on site only during certain phases of the work (posting of Warning Signs, establishment of work area containments, during final cleanup and cleaning verification) and available by phone the rest of the time.
DOS: DOS requires the supervisor (“Lead-Safe Renovator Supervisor”) to be on site at all times when RRP work is in progress.
V. Training and Certification Requirement for Supervisor
EPA: EPA requires a one-day “Certified Renovator” course given by an EPA-certified training provider. Possession of the training certificate, which includes a digital image of the trainee, constitutes the certification – persons who possess this certificate do not have to apply to EPA directly. The one-day training course does not include respirator/personal protection training elements. The training/certification is good for five years, after which time the “Certified Renovator must take a one-half day refresher course. EPA allows persons who have taken the deleader-supervisor and deleader-worker courses to take a one-half day upgrade/refresher course to upgrade to “Certified Renovator” status.
DOS: DOS requires essentially the same one-day training course for certified “Lead-Safe Renovator-Supervisors” that EPA requires for “Certified Renovators” except that the DOS-required course includes respirator/personal protection training elements. Where the training is given in Massachusetts, the course must be given by a Massachusetts-licensed training provider. As is the case with EPA, possession of the training certificate, which includes a digital image of the trainee constitutes the certification – persons who possess this certificate do not have to apply to DOS directly. The training/certification is valid for five years, after which time the “Lead-Safe Renovator-Supervisor” must take a one-half day refresher course. DOS also allows persons who have taken the deleader-supervisor and deleader-worker courses to take a one-half day upgrade/refresher course to upgrade to “Lead-Safe Renovator-Supervisor” status. DOS also requires training providers to include “Lead-Safe Renovator-Supervisor” training elements in four-day training courses required for “Deleader-Supervisors” given after July 9, 2010, and DOS will therefore allow “Deleader-Supervisors” to function as “Lead-Safe Renovator-Supervisors” on renovation worksites after they have completed this training.
VI. Certification and Licensing Reciprocity between EPA and DOS
EPA: Firms or entities that have been licensed as “Lead-Safe Renovation Contractors” by DOS in Massachusetts must become certified with EPA as “Certified Firms” in order to carry out RRP work in states where EPA is running the RRP program. EPA allows individuals who have been trained/certified as “Lead-Safe Renovator-Supervisors” in Massachusetts to act as supervisors and perform the functions of “Certified Renovators” on RRP projects in other states where EPA is running the program without needing to obtain separate EPA certification as “Certified Renovators.”
DOS: DOS allows firms that were certified with EPA as “Certified Firms” prior to July 9, 2010 to perform RRP work in Massachusetts without becoming licensed by DOS as a “Lead-Safe Renovation Contractor,” provided that they have received a “Contractor Licensing Waiver” from DOS – there is no fee for this waiver. The “Contractor Licensing Waiver” application is on the DOS website. Contractors that apply for EPA certification after July 9, 2010 are required to pay the licensing fee and become licensed as “Lead-Safe Renovation Contractors” with DOS. DOS will allow “Certified Renovators” that have received training from EPA-approved training providers to perform the functions of “Lead-Safe Renovator-Supervisors in Massachusetts without further training or licensure.
VII. License/Certification Fees for Providers of RRP Training
EPA: EPA issues a four-year certification to lead training providers. Certification fees, which are assessed on a per-course basis, range between $400 and $870 per course. The charge for certification to give to the initial “Certified Renovator” training course is $560, and the charge to give the refresher course is $400. The charge for renewing the certification in either discipline is $340. The training provider certification fee is waived for providers who are state and local governments, federally recognized Indian Tribes and non-profit organizations.
DOS: DOS issues a one-year license to lead training providers and charges a flat licensing fee of $1775, regardless of the number of lead training course disciplines in which the trainer is seeking approval to provide training. DOS has the same licensing fee waiver as EPA for training providers who offer only RRP training and are state and local governments, federally recognized Indian Tribes and non-profit organizations.
VIII. Work Practice Requirements
EPA: The set of work practice requirements specified by EPA’s RRP Rule is a somewhat relaxed version of the work practices currently required for deleading projects. As opposed to what is required for deleading projects, units undergoing renovation are not required to be unoccupied while the work is in progress; it is only required that persons be excluded from the work area, which must be isolated from the rest of the dwelling or child-occupied facility by appropriate means. Plastic sheeting, which must be disposed after each use, must be used to cover floors and other surfaces on building interiors and plants and ground on exteriors. EPA specifies the use of a “cleaning verification” procedure, which is carried out by the on-site ”Certified Renovator” to determine if interior work areas have been adequately decontaminated. Under this procedure, the color of a wiping cloth, that is used to wipe down the work area following the final cleaning, is compared to the color of a standard “cleaning verification card” issued by EPA. If the color of the wiping cloth is the same shade as (or lighter than) the cleaning verification card, the area “passes.” Dust-wipe clearance, as is used to clear deleading projects, may also be used to “clear” RRP projects.
DOS: DOS’ work practice requirements for RRP work are almost identical to those required by EPA, except that DOS allows the use of tarpaulins to cover plants and ground on exterior projects, provided that the tarpaulins are thoroughly decontaminated after each use and not subsequently used for any interior work in target housing and child-occupied facilities.
Stay tuned for more information on this huge development.
mark the coach
Posted by Mark Paskell on Thu, Aug 19, 2010 @ 10:43 PM
As we begin to understand the full impact of the Mass RRP Lead law contractors will soon be faced with the decision to develop and implement Worker Protection and Medical Monitoring Requirements. In section 22.09 of the Mass RRP Law 454 CMR 22.00, OSHA standards are described. This clause calls for the medical monitoring for employees on lead projects that generate 50 micrograms of lead dust exposure over an eight hour period. Other clauses describe the need for respirator fitting, medical examinations to determine lung capacity, blood testing, air monitoring, protective clothing and more.
Line Item #8 on the Massachusetts application for firm registration, called the Lead-Safe Renovation Contractor Application, states the need to supply a worker protection plan with the application.
The clause reads; A respiratory protection and worker health and safety program evidencing compliance with 29 CFR 1910.134 and OSHA medical monitoring requirements. If the applicant does not have a written program it can request a program template and checklist by calling the division at 617-626-6963.
Links
Here is the link to the template for the Mass DOS Model Written Respirator Program
Model Written Respirator Program
Here is the link to the Model Written Medical Monitoring and Worker Protection Program
Medical Monitoring and Worker Protection Program
Contractors who have these programs in place will have to show documentation to that effect.
More Contractor Confusion
We are receiving numerous calls about this subject from contractors who are unsure how to fill out the application. On the Lead Safe Renovation Contractor Licensing Waiver there is no direct mention of the medical monitoring requirement however the waiver states "in accordance with the provisions of 454CMR 22.00" which includes these requirements. So in order to comply with the waiver a worker protection plan and medical monitoring procedure applies.
These requirements will surely add significant costs over and above those encountered to comply with RRP.
Contractors have shown hesitation signing up for RRP Certification and Registration due to concerns about level enforcement, costs and confusion. The OSHA requirement, inserted into the RRP law for respiratory, medical monitoring and programs to implement them reveals a significant cost to contractors who don't have them in place. Will contractors hold off on this requirement?
Here are some cost items that are to be paid for by the employer;
Air monitoring equipment
Doctor appointments for blood lead testing (on company time?)
Doctor appointments for employees to be tested for lung and pulmonary capacity (will the employee be paid for this time?)
Respirators
Administrative cost to write the program
An approved OSHA trainer to validate the program and train the employees
Record keeping for blood and health monitoring
Security costs to protect worker health records
Work clothing and changing provisions on the job
Cost to implement this program..........priceless!
I thought the EPA said RRP compliance would only cost $35.00 per job?
Stay tuned this post will get everyone fired up.
Please share your thoughts.
mark the rrp coach
Posted by Mark Paskell on Tue, Aug 10, 2010 @ 08:52 AM
The new Mass RRP Lead Law effective on 7/9/2010, requires adherence to OSHA rules when performing RRP lead safe practices. The EPA RRP training program touches upon the neccessity to follow OSHA rules regarding RRP work but fails to cover these practices in sufficient detail to protect workers. RRP training covers the lead safe practices in great detail yet leaves contractors wondering what are the required OSHA practices to comply with both.
OSHA VS RRP ON A CONTRACTOR JOB SITE
Recently, we were told by a contractor in the Boston market that his site was visited by a Lead inspector and an OSHA inspector at the same time. The OSHA inspector had concerns with all the plastic on the ground set up for exterior containment. His concerns were for the workers walking on the plastic. He also expressed concerns setting and moving ladder on the plastic in order to scrape and prepare the house for new paint. The lead inspector argued the plastic needed to be left as set up to prevent lead dust contaminating the soil. Arguments ensued between the OSHA inspector and the Lead inspector. The contractor said OSHA won and the lead inpsector yielded. The plastic was removed.
Will this scenario be a regular occurence on residential job sites? What should a contractor do if OSHA and DOS have differing points of view on how a contractor should comply with the various regulations?
Do you workers have the lung capacity for respirators?
Another development is the Mass requirement for respirator protocols. On the Mass application line item number 8, there is a clause regarding respirators and worker safety programs. This is not spelled out on the EPA Certified Firm application.
Clause #8 from Massachussetts Lead-Safe Renovation Contractor Application
8. WORKER PROTECTION INFORMATION
A respiratory protection and worker health and safety program evidencing compliance with 29 CFR 1910.134 and OSHA medical monitoring requirements. If the applicant does not have a written program, it can request a program template and checklist by calling the Division at 617-626-6963.
This requirement states that a respiratory protection and worker health and safety program is in place. Including medical monitoring!
This focus on compliance with OSHA on the state application creates another step for contractors who have not been OSHA trained. I spoke with OSHA Expert Darcy Cook, from Safety Trainers about this yesterday. She informed me that contractors will need to be fitted for respirators and tested for lung capacity by a physician. Employees with facial hair may not be able to wear the respirator because facial hair will prevent a tight seal. Then the company must develop a comprehensive program in writing for their company. The company will additionally be required to purchase the proper equipment to protect their workers. Other related requirements include air monitoring and a work clothes changing/clean up station set up on the job site. Darcy also said workers who are not cleared by the physician to wear a respirator will not be allowed to work on projects where they are exposed to specific lead dust levels. What do we do with this worker? Do we tell our workers with facial hair they must shave or they can't work on demolition?
These items are mentioned in RRP training however, they are not trained in detail to insure that contractors truly understand the impact these regulations will have on their companies.
RRP Training Combined With OSHA Training
Should OSHA training be mandated for all contractors? Should OSHA create a training specific for RRP trained contractors?
The State of Massachusetts clearly states on their application for Lead-Safe Renovation Contractor that Worker Safety Programs are mandatory. Signing the application commits you to this requirement.
We are receiving many calls from contractors on how to comply with both OSHA and RRP Lead laws as they begin to work with lead safe practices. We are discovering that many contractors have not been through the basics of OSHA training. Several contractors who have been through OSHA training do not have worker protection programs in writing in place. I am still looking for one who has a respiratory program in place.
Please let us know about your concerns or questions regarding th euse of RRP practices that conflict with OSHA safe practices. We will air your concerns on this blog and make sure they reach the OSHA and DOS officials who frequently read this publication.
mark the coach
Posted by Mark Paskell on Fri, Aug 06, 2010 @ 02:56 PM
Today we received a call from a Massachusetts painting contractor in Rockport Mass., about a site visit from the Department of Occupational Safety (DOS). On 7/9/2010 the Mass DOS became the enforcer for the RRP Lead Law in the state.
With the painter contractor's permission we are sharing this enforcement story.
Jerry Enos, owner of Jerry Enos Painting Inc of Rockport, Mass, is re-painting a home in Rockport. His men were trained in The Contractor Coaching Partnership RRP Seminars. He is using grinders and sanders to remove old paint to prepare for new coats of primer and paint. His job was visited by a DOS inspector from the Haverhill office twice. The inspector was at the site due to a phone call from a neighbor who had questions about the project. This homeowner also called the EPA last year on another project on the same street. Jerry met with the inspector and discussed the lead safe practices he is using to contain the dust and debris and the subsequent cleanup. Jerry had no need to worry because he is properly trained, certified and registered to perform work on pre-1978 properties. Jerry enclosed the structure with vertical containment to contain and control the spread of dust. His men are using the proper tools tools and they have hepa vacuums to catch the dust and debris caused by the grinding and sanding.
The inspector visited the job twice. Jerry is glad that he properly implemented the lead safe practices into his production process. The inspector complimented on a job well done. Jerry doesn't have to worry about fines or having his job shut down because he made the right business decision to implement his training.
A Warning For Contractors From the DOS Inspector
Jerry and the inspector had conversations about how the State of Massachusetts is going to enforce the law. Jerry said he hopes the state will take this law seriously and enforce it across the board to create a level playing field.
Many Lead Certified contractors are concerned that they will have to compete against contractors who are not certified or not following the Lead Law. In our RRP trainings, contractor students share their frustrations about illegal allien contractors, non-compliant contractors with no certification, firemen and teachers working on the side, many taking cash and working without permits or insurance and under the table workers.
In their conversation Jerry was told by the DOS inspector that the state is taking this very seriously. The inspector then went on to say;
"Tell every contractor you know we're out there enforcing. Tell your friends, your neighbors, contractors you know, suppliers and trades. We are here and we will enforce the new law" DOS Inspector.
We thank Jerry for sharing this information with us. We compliment him on implementing these practices into his work. He was prepared and prevented an unpleasant site visit with an inspector.
Do you have a true story about DOS or EPA site visits to share?
If you have a factual story that you would like to share and see posted please let us know. Help us get the word out so we can help other contractors learn about this new law.
mark the coach
Posted by Mark Paskell on Thu, Jul 29, 2010 @ 09:43 PM
RRP Training in Massachusetts is heating up again. We have had many calls from contractors after they had site visits from the DOS (Department of Safety). The DOS is out enforcing the law. They are giving warnings and letting contractors know that as of 7/9/2010 contractors must be registered with the State of Mass and trained to work on pre-1978 properties.
Contractors Caught By Suprise
Many contractors believed that they had until September 30th to get certified because of the 6/18/2010 memo from the EPA delaying fines. Well that all changed on 7/9/2010, when the State of Mass was awarded delegating authority from the EPA to enforce and administer the EPA RRP Lead Law. Contractors who put off the training and certification are now deemed non-compliant to work on target properties.
RRP Classes
We have just scheduled classes at Brockway Smith in Andover, Mass on;
8/13/2010, 8/18/2010, 9/1/2010, 9/15/2010 and 9/30/2010.
Brockway Smith has hosted classes all year in an effort to bring this mandatory training to contractors in Massachusetts. Steve Fisher from Brockway Smith says " this is our way of giving back to the industry by making our training facility available and hosting this important training."
To sign up for training use the link below.
RRP Training in Mass
Mark the Coach
Posted by Mark Paskell on Sat, Jul 24, 2010 @ 01:56 PM
On Thursday the EPA announced that Hybrivet's Lead Check test kit will retain it's current recognition indefinitely. This EPA approved test kit is used in the EPA RRP training course for contractors. The EPA reviewed several test kits and deemed Lead Check was suitable for their needs. Many industry experts were anxious to see if the EPA would change the recommended kits leading to the potential that contractors would need to be retrained on a new testing product. This development should for the short term allay these fears.
The EPA states;
‘Because no new kits meet both the false negative and false positive criteria, EPA will continue to recognize the LeadCheck® test kit and the State of Massachusetts lead test kit. After EPA reviews the final report on Test Kit A, the Agency anticipates that this test kit will also be recognized as meeting the false negative criterion.’
Here is the link to the EPA report;
http://www.epa.gov/lead/pubs/testkit.htm
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Posted by Mark Paskell on Sat, Feb 27, 2010 @ 08:40 PM
On Friday 2/26/2010 The Contractor Coaching Partnership facilitated the 6th straight sold out EPA RRP training. We have selected Kachina Lead Paint Solutions to provide training for our clients and associates. To date all of our trainings have sold out in less than 4 weeks.
Our contractor attendees have commented that our instructors are excellent at explaining such a boring subject. Our instructors have extensive background in remodeling and property renovations. One contractor commented the Kachina instructors understand their world because they are contractors. Not lab coat technicians or boring professors teaching about safety. Another contractor said his boss went to a training firm and it was like watching paint dry, they had no lunch and they barely had enough coffee. His boss sent 6 of his lead carpenters to our training with Kachina.
Our trainings are carefully set up with the contractor in mind. Continental breakfast is served with plenty of coffee. A buffet style lunch with freshly cut turkey, ham and roast beef, salads and home made chocolate chip cookies and other desserts. (contractors get hungry sitting for 8 hours)
Our selection of Kachini Lead Paint Solutions has resulted in numerous referrals from attendees. John Zilka, lead trainer for Kachini, has a great knack for hiring trainers that relate to the contractor. He also has extensive contacts throughout the EPA and assisted with the development of the training manual.
The Contractor Coaching Partnership has added several training dates throughout the spring to the summer. We will be holding 45 plus trainings through June. we currently have 10 for the month of March with 6 already sold out!
The clock is ticking, the effective date is only 7 weeks away. To receive the best training from trainers who know your world check out our training dates today.
Who is required to receive this training; all contractors who want to work on pre-1978 homes after 4/22/2010. This includes remodelers, carpenters, window, siding, roofing, gutter and painting contractors. Also subs like plumbers, electricians, plasterers, hvac, insulation, floor and tile, IT, alarm and cable technicians. Once we get contractors trained then we can start on property owners.
EPA RRP Training in Massachusetts
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Posted by Mark Paskell on Tue, Jan 26, 2010 @ 08:03 PM
We are asked every day about who must be certified under the new EPA RRP Rules. One common question is, do sub contractors have to be certified. See this recent answer from the EPA site about general contractors and subs.
From the epa web site; 2 questions
Question 1
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Does a general contractor need to get firm certification under the Renovation, Repair, and Painting (RRP) rule for renovations that are subcontracted to other companies? |
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Question 2 |
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Does a general contractor need to get firm certification under the Renovation, Repair, and Painting (RRP) rule for renovations where its employees are not present during renovations that are subcontracted to other companies? |
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Answer |
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Yes, a firm or general contractor that enters into a contract or is paid to perform a renovation must get RRP firm certification even if all of the work is subcontracted to other firms including independent contractors. Under the RRP rule, only firms certified by EPA may perform, offer to perform, or claim to perform covered renovations. Firms that perform renovations for compensation must use certified renovators (or, as appropriate, workers that receive on-the-job training). Therefore, general contractors that are paid by individuals or organizations to perform covered renovations must be certified firms and must ensure that a certified renovator is assigned to each renovation performed by the firm and that individuals performing renovation activities on behalf of the firm are either certified renovators or have received appropriate on-the-job training by a certified renovator. In the case of a general contractor that subcontracts out the work, EPA interprets the requirement that certified firms use certified renovators as being satisfied if the general contractor uses firms that are certified that in turn comply with the rule on behalf of the general contractor (such as assigning a certified renovator to the job). In this case, from the time that containment is established until post-renovation cleaning verification occurs, all general contractor and subcontractor personnel performing renovation tasks within the work area must be certified renovators or trained and directed by certified renovators in accordance with the rule. In addition, these personnel are responsible for ensuring the integrity of the containment barriers.
The work practice requirements of the rule, including cleaning and post-renovation cleaning verification, could be performed by any properly qualified individuals, without regard to whether they are employees of the general contractor or a subcontractor. However, both the general contractor and any subcontractors performing work within the work area established for the containment of lead dust and debris are responsible for compliance with this final rule, regardless of any agreements they may have made among themselves. |
To sign up for EPA RRP training see our EPA Training page for available dates in Massachusetts.
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Posted by Mark Paskell on Sat, Jan 16, 2010 @ 03:07 PM
The new EPA Renovate, Repair and Painting Rule requires that both contractors and sub-contractors become certified. Many contractors think this won't affect sub-contractors, however it does.
First, the firm must fill out the application to become a certified firm. The fee for this certification is $300.00 and is good for five years. Secondly the sub-contractor must have a certified renovator on the job if their work disturbs more than 6 square feet of painted surface.( EPA Lead Paint renovation firm application.pdf )
The challenge facing remodelers and general contractors is that they will be responsible for all work on their project. In the event their subs fail to use lead safe practices the remodeler will be accountable. The liability risk is too great to not require that the subs have Certified Renovator Training.
In our training on Wednesday the EPA Certified Trainer indicated that we should let all our sub-contractors know of this requirement and encourage them to obtain the necessary certification and training.
The Contractor Coaching Partnership has two upcoming EPA RRP Training dates, In Westborough Mass on 2/8/2010 and in Taunton Mass 2/12/2010 hosted by National Lumber.
There is a lot of confusion in and around this industry changing regulation. We will continue to provide the most current information as it becomes available. We are in touch with the EPA on a regular basis and at our recent training met some of the Massachusetts Division of Occupational Safety officials who are taking a strong interest in helping the EPA enforce the regulation throughout the state. It has been mentioned that the state of Mass may eventually take over the program and administer from here in the state. Some states are considering this to keep control locally.
Stay tuned for more information. Sign up for this blog and you will be notified whenever we post information and news regarding the EPA RRP.
Meanwhile let all your subs know that you will need them to become certified to work on your projects.
mark the coach