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EPA RRP Workshop for contractors comes to Long Island, New York

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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 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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Mass RRP Takeover Causes Contractor Headaches and Confusion

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The recent Massachusetts takeover (7/9/2010) of the EPA RRP Lead Law is causing widespread headaches and confusion among contractors in the state. We have spoke with many lumberyards and building officials who are not aware of the changes. Many still believe that the EPA Memo of 6/18/2010, delaying enforcement of fines, is still in effect in Massachusetts. This is not the case. When Mass Department of Safety took over the law this nullified the EPA extension in the state. Currently any contractor who works on pre-1978 properties, who is not certified, is non-compliant. This change has caught many with their pants down and exposed to fines and work stoppages if they are caught. I spoke with a lumberyard today and they were under the impression that contractors have until 12/31/2010 to obtain the training. The fact is in Mass contractors must be trained now.

The Mass RRP Law adds additional provisions on top of the EPA RRP regulation. The Mass Law changes the provision for Certified Renovators presence on the job during lead safe practices performance. Under the federal law, the CR could leave the job and delegate the lead safe work to his job site trained workers. Under the Mass Law this is disallowed. This change creates a scheduling nightmare for contractors who have several jobs running at the same time. Many contractors will need to train all their lead carpenters if they want to run multiple jobs from now on.

RRP Practices on a Collision Course with OSHA Safety Practices

Mass has brought OSHA issues to the forefront in its revised law. The EPA RRP sanctioned training mentions OSHA practices but does not delve into the conflicting regulations. Training focuses on the RRP and Certified Renovators are instructed to research, know and be responsible for OSHA regulations when performing renovations on pre-1978 properties. In a recent post from Shawn McCadden these OSHA vs RRP conflicts in Mass are well described. Contractors will likely need additonal training and assistance to make sure they do not violate OSHA regulations while performing the RRP lead safe practices. 

Certified Firm Application Nightmare

Contractors in Mass must now fill out a firm registration in the state of Mass different than the federal certified firm application. Contractors who fell for the 6/18/2010 EPA extension must now pay $375.00 to the state to be a certified firm. The federal certified firm application was $300.00. The new Mass Certified Firm Registration is only good for Massachusetts. If you are a contractor who works in other states you will need to also complete the federal certified firm application. The cost now will be $675.00 for a contractor that works in Massachusetts and New Hampshire or Massachusetts and Connecticut. OUCH!!!!!

Other factors causing contractor headaches 

On 7/7/2010 the Opt Out Clause was removed from the law. No longer can homeowners elect to forgo lead safe practices if there are no children or pregnant women in the property.

Contractors must now provide a copy of the lead safe practices used on a RRP project and give it to the homeowner after the job is done.

Lack of consumer education and resources to enforce the law across the board are constantly brought up in our trainings.

Stay tuned for additonal posts on the moving RRP landscape.

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RRP Training

EPA RRP Fine Extensions Null and Void in Massachusetts

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On June 18th, 2010 the EPA posted a memo that delayed enforcement and fines for Firm Certification until 9/30/10 and Certified Renovator Training until 12/31/2010. This memo also stated that untrained contractors performing work on pre-1978 homes must follow and be compliant with the RRP Lead Rule. The content of the memo has caused a significant downturn in the number of contractors signing up for the mandatory training. Many lumberyards have told us that contractors think they have until next year to do training and many contractors are claiming that the law will be reversed. In Massachusetts putting off the training and certification is going to be costly for contractors.

Mass RRP Takeover Nullifies EPA 6/18/2010 Extension

Today we spoke with Patricia Sutliff, from the Mass Department of Safety, about the EPA FINE Extensions and are they recognized in Mass. The answer is NO. Per the DOS, Mass contractors who have not certified their firms and who have not obtained the required RRP training cannot work on pre-1978 homes where lead safe practices are required as of 7/9/2010.

We have heard many contractors say they will wait to get trained. We also have called over 1000 contractors who have been through our RRP Training Course and we have found that over 50% of the contractors have not Registered their firms with the EPA!!!

Certified Firm Registration Increased in Mass 

In Mass, contractors will now have to pay $375.00 to Register their firms as opposed to the $300.00 fee they could have paid before July 9th, 2010.  Mass will recognize any training or certification obtained or applied for before 7/9/2010. This is good news for contractors who became compliant on time.

Mass Lead Safe Renovation Contractor Firm Application

In addition, Mass contractors must obtain Certified Renovator Training immediately to be compliant with the new Mass Lead Law or forgo working on pre-1978 properties until they are trained. I learned of a project in Wellesley today that was paid a vist by the DOS. They found 5 men working on the house who said they were independent contractors. The DOS asked to see their documents. One independent produced his Certified Renovator License. The DOS asked if he certified his firm and he said no I will do it later. The DOS said Certify your firm within the week or stop working. Also the DOS said to the CR "all these other independents must certify their firm and sign up for a RRP training class immediately."

The enforcement effort has begun in Mass.

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RRP Training Dates

RRP Implementation Workshops

Contractor Alert; Massachusetts files to take over EPA RRP Rule

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Massachusetts will soon become the 9th state to enforce and administer the EPA RRP Lead Rule. The state filed emergency legislation on April 2nd to begin the process that will lead to local enforcement. This change will provide local service from state government officials for contractors and property owners who must comply with the new law. The state filed today. Once approved the Department of Occupational Safety will run the program.

Contractors and Property Owners must still follow the EPA RRP Lead Rule while working on pre-1978 homes. When the State of Mass is confirmed to administer and enforce the law new changes will need to be included in work practices.  

Here is the article form the State of Mass site;

On June 25, 2010, the Division of Occupational Safety filed with the Secretary of the Commonwealth, amendments to 454 CMR 22.00 (Deleading and Lead-Safe Renovation) and, in conjunction with the Executive Office for Administration and Finance, amendments to 801 CMR 4.02 454 (16) and (18) (Licensing Fees for Lead-Safe Renovation Contractors and Lead-Safe Renovator Training Providers).  These amendments, which will be published in the Massachusetts Register and become effective on July 9, 2010, can be viewed by clicking HERE.  These regulations were filed as emergency regulations on April 2, 2010.  The edits made in red line (click HERE) indicate changes made after public comment to the emergency regulations. 

These amendments, which establish safety standards for renovation, repair and painting work that disturbs lead paint in target housing and child-occupied facilities built before 1978, parallel similar federal EPA requirements that became effective on April 22, 2010 under the "Renovation, Repair and Painting Rule" (RRP Rule), 40 CFR 745.80 - 745.92.  The amendments to 454 CMR 22.00 are designed to be as protective of human health and the environment as the federal standard.  At this time, EPA has the exclusive authority to administer and enforce the RRP Rule. DOS will be filing an application shortly with EPA, seeking authorization to administer and enforce the lead safety standards for renovation, repair and painting work set forth in 454 CMR 22.00, in lieu of the federal standard being enforced by EPA in Massachusetts. DOS will request that this authorization be approved as close as possible to July 9, 2010, to coincide with the effective date of the amendments to 454 CMR 22.00.

Further information on the current federal administration of the RRP Rule, including application forms for contractors, applicable fees and lists of approved training providers may be obtained through the following link:  http://www.epa.gov/lead/pubs/renovation.htm#contractors.  Further information on Massachusetts' administration of RRP requirements, including application forms for contractors, applicable fees and FAQs, is being developed and will be posted on this website as it becomes available.  In the interim, questions can be directed to DOS Environmental Engineers Patty Sutliff, Rick Rabin or Frank Kramarz at (617) 969-7177

The Contractor Coaching Partnership will continue to post new movements on this important development.

For contractors looking for guidance and assistance deciphering all the new developments and help implementing RRP practices into your business, we are holding a RRP Implementation Workshop on 6/30/2010 at Brockway Smith in Andover Mass. To register for this timely workshop use the link below. Seating is limited.

RRP Workshop Link; Register today!

RRP Implementation Workshop with Shawn McCadden

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RRP Training

EPA RRP Enforcement of Contractors in Mass and New Hampshire

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We have received several reports from contractors about EPA RRP enforcement over the last two weeks. The reports are from contractors who have signed up for our RRP courses. Contractors who work without their certification are taking a huge risk with their business. The fines can be as large as $37,500 per violation.

We are waiting for official word from the EPA to substantiate these reports and as soon as we have it we will report the details. Here is the list of reports we have received.

JOBS SHUT DOWN BY EPA OFFICIALS

1. Contractor installing windows in Athol Mass shut down and fined $8.000.00. Report from contractor who was told by a paint supplier.

2. Painting contractor in New Hampshire painting a large building on the common in Essex shut down for not using lead safe practices and not certified. This report also came from a paint store where contractors were talking about it.

3. A contractor who signed up yesterday reported he was at Home Depot and there were several contractors discussing jobs that were shut down in Winchester, Somerville, Cambridge and Arlington, Mass.

4. In Leominster Mass a painting job that has been on going for several months down town was hit by the EPA and the contractor was told to stop work.

5. In one of our seminars in Haverhill a contractor reported a window project shut down Amesbury.

Inspectors asking for RRP Certification 

We have also had reports that in Amesbury the inspector is requiring the RRP Certification on pre-1978 projects. Other towns where we have been told by contractors applying for permits are Rowley, Topsfield, Boxford, Frankln and Needham.

I personally spoke to the EPA Boston office and they said that they are definitely combing the neighborhoods for non-certified contractors. They would not give me details over the phone but said they would publish fine results as soon as cases are finalized.

If you have information about EPA RRP enforcement, projects stopped or fines please let us know and we will spread the word.

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EPA RRP Training

EPA RRP Workshops

RRPedia, the ultimate resource for RRP information for contractors

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Last September while speaking with Shawn McCadden about the upcoming EPA RRP lead law, we were surprised there was a shortage of relevant content on line for contractors about the law. In January we met with the EPA in Boston and asked several questions that they were not able to answer without consulting with EPA headquarters. The EPA was very helpful where they could be but had to refrain from answering many of our questions until they could be reviewed by the Washington DC headquarters. This dilemma created a huge void for contractors looking for answers about the RRP rule.

This lack of information led to the genesis of Shawn's outstanding resource called RRPedia. For any contractor, property owner or business owner seeking up to date accurate information, RRPedia is a must read.

Many contractors and industry professionals have told me they go to Shawn's RRPedia first before they go to the EPA's website on the RRP Lead Law!

For straight forward explanations and valuable tips on how to comply with this law add Shawn McCadden's RRPedia to your favorites list or better yet, sign up for his blog and receive updates as they are posted. It will save you valuable time and clear up many things you hear from the contractor rumor mill.

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EPA RRP Lead Training

RRP Workshops

 

Will insurance companies force contractors to be RRP Certified?

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As The Contractor Coaching Partnership marches on to providing training for 3000 contractors we are often asked if we know what insurance companies are going to do. Will they provide cost effective pricing to cover contractors for lead? Will they require specific certification and or training in order to qualify for coverage? Will EPA RRP Certification be required in order to qualify for general liability coverage?

I was concerned about this earlier this year and asked some insurance experts and they assured me it would likely not be a requirement. They said it would likely be a choice and the insurance industry will produce a policy that will be priced in the 2500.00 dollar range for RRP coverage. There is a policy on the market now in that price range.

I was skeptical that RRP coverage would not be required to qualify for general liabilty. Now it appears that we thought correctly. The following excerpt from an EPA representative may be be the harbinger of what contractors will face in a few months. 

On Friday I received an email from a training provider in Texas. This email is from an EPA official from region 6 in Dallas. It also includes an interpretation of concerns between OSHA and RRP when setting a ladder on plastic. I will post the entire email and source here and let the readers of this blog draw their own conclusions. My conclusion is that insurance companies are going to demand that contractors are EPA RRP Certified Firms, employ certified renovators and that all sub contractors are certified. This will be very similar to the requirement that all subs carry workmen's compensation. I also believe that there is a better than average chance that insurance companies will cancel non-EPA Certified contractors who work on pre 1978 properties. Maybe this is a way that insurance companies can charge for more coverage?

Here is the email from; Estella Sugawara-Adams, M.S. Region 6 EPA

Thank you to every R6 Trainer Provider who added extra classes to meet the April 22nd deadline. I know that you all can cite the Instructor's Manual in your sleep!  The Region 6, Dallas office, owes you a huge THANK YOU!  

I have a request for everyone that involves purchasing supplies, brochures, tips and complaints.  Please, if possible, include in your training packet the name(s) of the company(ies) where the weatherization tape, yellow caution tape, Renovate Right Brochures, rolls of 6ml plastic etc., can be purchased. Some folks have never heard of "Google" or finding information on the web!
The "Lead-Check" company is really overwhelmed trying to fill requests for test kits.  Please remind your students that the new regulatory provision on the test kits will change in September 2010 - so don't over purchase the current test kits.

I would like for you all to include my name, telephone number and email address, for sending complaints, tips, etc. It is really important that your students know their efforts to obey the law is not being overlooked.
If you receive tips and/or complaints, about companies advertising as Certified EPA Trainer Providers, please let me know.  To date, we have caught two companies that were advertising as EPA Certified Trainer Providers and told the students they are now certified.  Unfortunately, the students never received their Certificates, and the companies are shams.

(Insurance Companies Dictating The Rules)

Insurance companies are requesting a copy of the Renovator Certificates, Firm Certificates and when training was completed. If the Certificates are not sent (faxed) to the insurance company, then the employees are let go and/or the Firm is dropped from coverage.  This is something that was launched by the Insurance companies, and we do not have control over their efforts to bring their industry into compliance.  A temporary card or signed letter (complete with date of training) on company Letterhead, would help your students tremendously.

(OSHA Interpretation)

Finally, I have been notified of several areas where the new regulation is in direct conflict with OSHA. Actually, it is not in conflict. The most serious is the slippery surface, we require that plastic must cover the ground, and the contractor must use   a ladder on the plastic, while keeping the surface of the plastic sprayed to contain the lead dust.  This is what OSHA requires:
The OSHA regulations don't say that you can't put a ladder on plastic.  It says that if you put it on a slippery surface, then you should secure it or use slip resistant feet.  The ladder regulations are at 29 CFR 1926.1053(b)(5)(ii) -(b)(7)

I will be setting up meetings with the Trainer Providers in May/June, so that we can review some of the areas that need improving, the 4-hour Refresher course, and any other topics that you may want to discuss.

Again, thank you.
Stella


Estella Sugawara-Adams, M.S.
Regional Lead (Pb) Coordinator
U.S. EPA, Region 6
6PD-Toxics
214-665-2704 (Direct)
214-665-6655 (Fax)

Here is one last question before I sign off.

If insurance companies follow through on requiring that all contractors become EPA RRP certified what will this mean for our industry, the average contractor and you?

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The Contractor Coaching Partnership

 

1000 Contractors EPA RRP trained; The Contractor Coaching Partnership

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On Monday 4/12/2010, we ran our 21st EPA RRP Seminar and went over 1000 contractors trained since late January. Our RRP training dates are filling up as fast as we put them up.

Our phones start ringing at 6:30 in the morning and don't stop until after 9:00 PM. We even get calls on Saturday and Sunday from contractors looking to get a seat before the April 22nd effective date. The month of April is jammed and we are doing 15 trainings. We have scheduled 20 dates in May and are planning for more in June.

The word is starting to get out to all trades and inspectors. We have had several building inspectors sign up as well.

Next week the law will go into effect and the pressure to become certified will intensify. We are expecting a busy summer as many try to find a seat and training from a small supply of trainers. We are fortunate to have a resource of over 20 trainers to handle multiple classes in many locations. 

Our training dates are carefully placed to service the Boston market with locations in Taunton, Westborough, Andover and Haverhill.

If you or contractors you know are looking for the best training please go to our EPA RRP Training page for available dates. 

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Senators write letter for contractors to delay EPA RRP Lead Rule

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Update for contractors on the EPA RRP Lead Rule effective date. Senators signed a letter to the OMB urging the delay of the effective date unless the goals of the law have been reached.

I met with the Boston EPA Region 1 manager and RRP Coordinator twice last week and they doubt the effective date will be delayed or extended. This was based on their most recent information form their superiors. They said it was highly unlikely to expect extensions unless there was considerable pressure. The letter says it is bi-partisan but only one democrat signed the letter with 7 republicans. Giving the recent health care bill passsage I would be shocked if this final attempt will work. Time will tell. In the meantime I urge all contractors and property owners to schedule their training and certifiy their firms as soon as possible.

Here is the letter;

Senators Send Bipartisan Letter Urging EPA Action on Lead Rule March 26, 2010

Contact:

Matt Dempsey Matt_Dempsey@epw.senate.gov (202) 224-9797

David Lungren David_Lungren@epw.senate.gov (202) 224-5642

Senators Send Bipartisan Letter Urging EPA Action on Lead Rule

Jobs, Health At Risk, As Thousands of Contractors Have Yet to Be Certified

Link to Letter

WASHINGTON, DC - Several United States Senators last night sent a bipartisan letter to the Office of Management and Budget (OMB) urging OMB to ensure compliance with EPA's Lead: Renovation, Repair and Painting Rule. The Senators wrote, "We strongly urge OMB to take whatever actions necessary in the next 26 days to ensure that when this rule goes into effect, there are enough certified renovators available to meet the compliance goals of the rule."

Starting on April 22, 2010, renovation work that disturbs more than six square feet in target housing must be supervised by a certified renovator and performed by a certified renovation firm. In its economic analysis of the rule, EPA estimated that it would need to certify 236,000 renovators between April 2009 and April 2010. According to EPA, the agency has certified only 50,000 renovators, well below EPA's estimated 236,000 needed to meet the requirements of the rule.  Additionally there are several states-Oklahoma,  Louisiana, South Dakota, Wyoming, West Virginia--and the District of Columbia, which currently have no approved trainers.

U.S. Sen. James Inhofe (R-Okla.), Ranking Member of the Senate Committee on Environment & Public Works, joined Senators Mike Crapo (R- ID), David Vitter (R-LA), George  Voinovich (R-OH),  Lamar Alexander (R-TN), Chuck  Grassley (R-IA), Ron Wyden (D-OR), John Barrasso (R-WY), Christopher Bond (R-MO) and John Thune (R-SD) in signing the letter.

Background

The letter echoes concerns raised in recent letters sent to OMB from Senators Byron Dorgan (D-ND), Kent Conrad (D-ND), and a bipartisan group of members in the House of Representatives. Further, Senator Amy Klobuchar (D-MN) urged EPA to come up with a solution that will ensure that contractors have the opportunity to come into compliance with this rule and that children's health is protected at a recent hearing of the EPW Subcommittee on Children's Health.

The issue has also been raised before the Senate Energy and Natural Resources Committee. In testimony before the committee on March 11, Bob Hanbury, speaking on behalf of the National Association of Homebuilders, raised concerns about "potential conflicts between Home Star and an environmental rule - e.g., the EPA's Lead: Renovation, Repair and Painting Rule (LRRP) - that may create a serious compliance problem whereby it becomes illegal to work on any pre-1978 without certification by EPA in Lead Safe Work Practices (LSWP) as of April 22, 2010."

The construction and renovation industry has lost nearly 2 million jobs since the recession started.  Unemployment in construction and renovation jumped to 24.7 percent, more than double the national rate of 9.7 percent.  The sector is expecting that another 5 percent of construction workers will lose their jobs in 2010.  Currently, EPA has only 184 accredited training providers and 50,000 certified renovators nationwide.  EPA believes it can train 100,000 renovators by the April deadline-this is less than half of the required 236,000, well short of what's needed to carry out millions of renovations annually.  In addition, EPA has stated that the certification process takes six weeks or more to complete.  Industry estimates that over 200,000 renovators still need to be certified before the April 22, 2010 deadline.

In addition to last night's letter, Senators Inhofe and Vitter have sent letters (here) and (here) to EPA Administrator Lisa Jackson regarding the pace at which EPA was certifying trainers and training facilities. 

Text of the letter:

We are writing today to express our concerns about the impending April 22, 2010 deadline for implementing EPA's "Lead: Renovation, Repair and Painting Rule."  Starting on April 22, 2010, renovation work that disturbs more than six square feet in target housing must be supervised by a certified renovator and performed by a certified renovation firm, as outlined in 40 CFR ยง 745.85.

EPA, in its economic analysis of the rule, estimated that it would need to certify 236,000 renovators between April 2009 and April 2010, with another 94,000 renovators between April 2010 and April 2012. According to EPA they have certified only 50,000 renovators, well below EPA's estimated 236,000 needed to meet the requirements of the rule. The National Center for Healthy Housing estimated that it is taking EPA nearly eight weeks to certify trainers, and currently has only 184 certified training providers. In order to meet the compliance goals of the rule, many more training providers and training sessions are needed. Additionally there are several states-- Louisiana, South Dakota, Wyoming, West Virginia-- and the District of Columbia, which currently have no approved trainers.

We believe the new lead rule can only work if there are enough certified renovators to meet the rule's compliance goals. We strongly urge OMB to take whatever actions necessary in the next 26 days to ensure that when this rule goes into effect, there are enough certified renovators available to meet the compliance goals of the rule. These actions could include ensuring EPA has enough resources devoted to compliance assistance, speeding up the turnaround time for approving trainers, expediting public awareness and media campaigns and, if necessary, delaying the rule's implementation or phasing in the rule in areas where there are adequate certified renovators.

###


Pella Pro Expo, Boston EPA, The Contractor Coaching Partnerhship

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BREAKING NEWS 

The Contractor Coaching Partnership has been invited to speak at the Pella Pro Expo tomorrow at Gillette Stadium. I was contacted a few weeks back by a fellow NARI member, Ian Dobbs of Pella in Haverhill Mass to speak about the EPA RRP Lead Rule.

In the past two months we have provided EPA RRP Certified Renovator training for over 600 contractors. We are scheduled to train another 1800 through June. Last fall I noticed a shortfall in available trainers to train contractors in our NARI chapter as well as other contractors in the Boston market. This situation concerned me so I made a decision to bring training to as many contractors as possible in the Massachusetts market. I had no idea this would consume my entire schedule like it has.

I believe this is a major reason why Pella invited us to speak on this industry changing topic. In early January I was joined by Shawn McCadden and Greg Antonoili to speak with the EPA in Boston on behalf of the EM NARI chapter. We then held a town hall meeting at our January meeting led by Shawn McCadden. It became obvious that this rule would become a major factor in how we run our businesses.

I am honored to have the opportunity to address the professionals at the Pella Pro Expo and would love to talk about the things I do as a contractor business coach. But I think that should be saved for another day. There is a greater obligation and opportunity to our industry. With that said, tomorrow will be all about the EPA Boston Officials, EPA RRP Rule and the major role NARI is playing to educate all contractors in the Mass market. 

I approached Pella and asked them if they would like to have the EPA address the show attendees and talk about the EPA RRP Lead Rule. They thought that would be a great idea. I am thankful they have given us this opportunity.

NARI Delivers 

In January, the EPA asked EM NARI President Greg Antonoili, Shawn McCadden and I if we could help them get in front of key groups to spread the word of the new RRP Lead Rule. I thought this Pella event would be a great way to help them and so did they.

Yesterday, we were able to deliver another opportunity to them, to speak to the Mass Federation of Building Officials in Charlton, Mass. We also invited the state Department of Occupational Safety who attended. This meeting went well and all present were pleased to have the opportunity to discuss the EPA RRP Lead Rule. (I will write another post about that meeting). 

The Mission of NARI coincides with my mission to lead our industry in the pursuit of contractor education, best practices and professionalism. Tommorow, I get to live up to that mission by stepping back and giving the EPA the limelight to speak about this industry changing regulation. They are appreciative and have stated that they are glad to work with NARI and look forward to a mutually beneficial relationship.

Hope to see you there.

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