Posted by Mark Paskell on Sun, Sep 05, 2010 @ 10:47 PM
We recently added a new page to our website called RRP Forms and Resources. The page includes RRP Forms, Lead Check video on how to use the test swabs, RRP supplies and equipment, links and more.
Here is the link;
http://www.thecontractorcoachingpartnership.com/rrp-resources-forms-compliance/
Mark the Coach
"Training immediately followed by implementation, insures what is paid for and learned in the classroom, makes it to the field."
Posted by Mark Paskell on Sun, Sep 05, 2010 @ 10:21 PM
A contractor recently inquired about our RRP training services and the quality of our trainers. After a lengthy inquisition he said "training should be just like lead paint, it should stick for a long time"
Will your RRP Lead training stick? Are you sure the trainer you select is the right one for you, your employees, your sub contractors?
2010 is a pivotal year for the residential construction industry. The EPA RRP Lead Law has turned the industry upside down and promises to make things very interesting for years to come. Contractor compliance is no longer an option, it is a must. Training for RRP Lead Safe practices will be a big part of that compliance. OSHA training to coincide with RRP practices will follow. Quality training is a must to insure you have the right information and tools to comply with these regulations.
Demand for RRP training will increase as extensions end
In the first 6 months of the year, 3000 contractors in New England, New York and Washington D. C. went through our RRP training program. The spring was chaotic due to the 4/22/2010 effective date, high demand, a lack of trainers, available training seats, poor notification from the EPA, and the propensity for contractors to wait until the last minute. With that said, we expect a very busy fall. With the impending September 30th deadline upon us, contractors will once again scurry (some at the last minute) to schedule their training to comply with the EPA deadlines. Will there be enough quality trainers to meet the demand?
More EPA Approved Trainers
Over the summer the EPA has approved more training providers with the hope that there will be enough trainings to meet the demand. To date only 10% of contractors in this country are trained. The EPA is under pressure to increase the number of trainers as soon as possible. A large number of new trainers have entered the market hoping to expand their businesses. In the amendment effective on 7/6/2010, the EPA relaxed the requirement to become a trainer from 16 hours to 8. Now it is very easy to become a trainer.
Is it possible that some trainers will be rushed through to meet the demand? Will training providers convert existing abatement or safety trainers to RRP instructors even if they have little or no experience with the residential construction industry? Will the EPA, already severely short handed, be able to audit training providers to insure that the quality of training they expect is delivered?
We are hearing from contractors some trainers are lacking in relevant residential construction experience. Trainers who cannot relate to the world of the residential contractor may not be received well and the training may fall short. Given the severity of the fines and increased liability, contractors can ill afford to pay for training that is delivered by trainers who cannot relate to residential contractors.
In the conversation with the contractor above, I asked him what were his main concerns. He responded "I went to a training provider in New York to be trained on the RRP Lead Law. I shopped around and selected the best price I could find. I didn't stop to think about the trainer, I just knew I had to get it done. I was disappointed because the instructor had no clue about working for homeowners and he obviousy didn't know my world. He couldn't answer my questions and was unclear on the law. All he did was read from the slides in a monotone voice. People were nodding off because he was boring. He didn't teach me anything I didn't already know. In fact I am more confused now.
He then went on to explain that he had several employees to train and he didn't want to risk spending his dollars on training that wouldn't be suitable for his men. He said "training should be just like lead paint. It should stick for a long time".
Before you pick your trainer do some homework and ask them as many questions as possible to make sure your valuable training dollars are well spent. The risk of sending your guys and subs to someone who is not relevant to your world can cost you big time. Either in retraining costs, or worse, fines.
mark the coach
"Training immediately followed by implementation, insures what is paid for and learned in the classroom, makes it to the field."
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 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 Sun, Jun 13, 2010 @ 07:49 AM
In March of this year Koopman Lumber hosted two EPA RRP Certified Renovator Courses for their contractor clients. Due to continued interest in the RRP training they are sponsoring another training on 6/28/2010 at the Doubletree Hotel in Westborough, Mass.
Koopman Lumber continues to be a valued resource for their contractor clients throughout the Blackstone Valley and Worcester County. They have set up RRP supply sections in each of their locations so that contractors can purchase supplies and equipment needed for performing RRP lead safe practices.
To learn more about this training on 6/28/2010 see the following flyer for details.
http://www.thecontractorcoachingpartnership.com/Default.aspx?app=LeadgenDownload&shortpath=docs%2fKoopman+Lumber+RRP+Flyer+6.28.2010.pdf
Posted by Mark Paskell on Sat, May 15, 2010 @ 11:21 PM
Back in January when I chose to partner with Kachina Lead Paint Solutions I had no idea that we would together, train 2000 contractors. Yesterday we hit 2000 with many more to go. We currently have 7 sold out dates this week and 5 the following week before the holiday. This business has taken on a life of its own. We now have four awesome instructors who have an extensive background in residential construction.
Our instructors;
Peter Lawton a former NARI board member and kitchen and bath remodeler has received accolades from Brockway Smith as one of the best trainers they have ever seen.
Mike Cavalaro a former president of an NKBA chapter and owner of a Kitchen and Bath remodeling firm.
Scott Syropolous and Fred Ellsworth both successful painting contractors.
I have been told by numerous contractors that our trainers are the best around. This is evident due to the numerous referrals we receive everyday from our contractor clients and the lumberyards who ask us to put these trainings for them. We are starting to see an increase in the number of sub trades coming to the trainings as more and more general contractors request that they obtain RRP certification.
We are currently expanding our program to other regions with a capacity to train 1500 contractors or more per month. We are working on Long Island in New York as well as Washington DC.
I now have to reset my goal which was only one thousand contractors to something more challenging.
I miss having the time to write blog posts. We are servicing hundreds of contractors every week. Calls come on any day at any time. One contractor called me at 9:30 tonight asking how to handle a project that begins next week. We just wrapped up and he now has his strategy. It is reassuring that we are making a difference helping contractors obtain the best training around.
I am looking forward to finding the time to start writing more frequently. Maybe after we train 10,000 contractors.
mark the coach
Posted by Mark Paskell on Tue, Mar 23, 2010 @ 07:07 AM
I am ready to leave for my meeting today to fight for the rights of legal contractors in Massachusetts. Maybe this will even help contractors throughout the country.
I am scheduled for a meeting at 9:30 AM in Charlton, Mass with the Mass Federation of Building Officials. I was invited by the President, Robert Camacho. It turn out that a friend I grew up with is a building inspector and he got me the invitation.
I have invited Industry expert Shawn McCadden to join me. We will be joined by Nancy Barmakian and Jim Bryson from the Boston EPA Regional Headquarters. Also we have invited Ernie Kelley and Patty Sutcliff from the Division of Occupational Safety. DOS has applied to the EPA to take over the administration and enforcement of the EPA RRP Lead Rule.
My goal is to seek a requirement that will allow the building inspector to require an EPA Certification when any contractor applies for a permit.
I am excited to have this opportunity to fight for contractors and hope I can help lead the charge to establish a level playing field for all legal hard working contractors in Massachusetts and maybe even America.
Wish me luck.
I will let you all know the results in a few days.
mark the coach
Posted by Mark Paskell on Tue, Mar 02, 2010 @ 08:34 PM
Just found out that there will be a public hearing for the state of Massachusetts to take over the administration and enforcement of the EPA RRP lead Rule. I was informed by the Boston EPA office last night. I am glad the EPA gave me a heads up. The EPA will be present at this important meeting.
I am perplexed why the state of Masschusetts is not including the building industry in their notifications. The EMNARI chapter has not been informed. I do not know about the builders association.
To date we have provided EPA RRP training for 400 contractors and one of the most common statements is the lack of notification from officials. I just happened to call the EPA on an unrelated matter and they informed me of this hearing. When I receive important information like this I will let you know on this blog.
I will be joned by Shawn McCadden and Greg Antonoili to represent EMNARI and the residential construction industry.
I will write a blog post about this hearing later in the week to help my readers stay informed.
Here is the notification;
In accordance with 40 CFR 745.324(a)(2), the Massachusetts Division of Occupational Safety (DOS) will hold a Public Hearing to receive comments on its intent to seek authorization from the United States Environmental Protection Agency (EPA) to administer and enforce a regulatory program for renovation, repair and painting work that disturbs lead paint in pre-1978 housing and child-occupied facilities. To meet the requirements for EPA authorization, the DOS-administered program must be as protective as that set forth in EPA regulations at 40 CFR 745.80 through .92 - the Renovation, Repair and Painting Rule (RRP Rule). The lead regulatory program set forth in the RRP Rule, which will become fully effective on April 22, 2010, includes requirements for the certification of firms carrying out work subject to the Rule, training of supervisors and work practice standards. The hearing will be held on Wednesday March 3, 2010, from 12:30 p.m. to 2:30 p.m. in the South Street Amphitheater of the UMass Medical School at 333 South Street, Shrewsbury, MA. Comments on DOS' intent to seek this authorization may be sent to Laura Marlin, Commissioner, Massachusetts Division of Occupational Safety, 19 Staniford Street, 2nd Floor, Boston, MA 02114 until the close of business on March 12, 2010.
Proposal to Seek EPA Authorization to Regulate Renovation Work Involving Lead Paint
As allowed in EPA lead paint regulations at 40 CFR 745.324, the Division of Occupational Safety (DOS) is proposing to apply for EPA authorization to administer and enforce standards for renovation work that disturbs lead paint in pre-1978 residences and child-occupied facilities. DOS had previously applied for and received a similar EPA authorization to administer state standards for deleading work in 1999.
The Division of Occupational Safety and the Childhood Lead Poisoning Prevention Program (CLPPP) of the Department of Public Health have been administering the requirements of the Massachusetts Lead Law (M.G.L. 111, ss. 189A through 199B) for more than twenty years. Pursuant to 105 CMR 460.000, CLPPP regulates lead paint inspections and standards for deleading compliance. Pursuant to 454 CMR 22.00, first promulgated in 1989, DOS licenses contractors who carry out deleading work and prescribes the work practices for such work.
In 1996, the federal EPA promulgated standards ("Lead Paint Activities" - 40 CFR 745.220 through 239) for deleading work in pre-1978 residences and child-occupied facilities. These standards set forth licensing requirements for companies engaged in deleading work, training requirements for deleaders, work practice standards and job clearance requirements. Pursuant to 40 CFR 745.324, states with deleading regulatory programs as protective as the federal standard could apply to EPA to administer their own programs, in lieu of the federal deleading regulations being enforced by EPA in those states. DOS amended its deleading regulations, 454 CMR 22.00, to bring them into line with the EPA deleading regulation in 1999 and applied for and received EPA authorization to administer its own standards in Massachusetts. It has been administering those standards under EPA delegation since that time.
In April 2008, EPA promulgated regulations, the "Renovation, Repair and Painting Rule, (RRP Rule), 40 CFR 745.80 through 745.92, which regulate renovation work that disturbs more than de minimis quantities of lead paint in pre-1978 residences and child-occupied facilities. Licensing and training requirements for companies and individuals carrying out this work, as well as work practice standards and job clearance standards are also specified. As was the case with EPA's Lead-Based Paint Activities Rule, states with regulations and regulatory programs as protective as the federal standard can apply for EPA authorization to administer their own programs. The Division of Occupational Safety (DOS) is planning to seek EPA delegation to administer a regulatory program for lead-safe renovation in Massachusetts pursuant to 454 CMR 22.00. If DOS receives this delegation, it will have responsibility for administering and enforcing the Rule. If DOS does not receive delegation, EPA will have the responsibility for administering and enforcing the RRP Rule in the Commonwealth when the Rule becomes fully effective on April 22, 2010.
mark the coach
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
mark the coach