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 Wed, Aug 04, 2010 @ 09:37 AM
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.
mark the coach
RRP Training
Posted by Mark Paskell on Thu, Jul 22, 2010 @ 09:05 PM
Today we spoke with the Mass Department of Safety (DOS) and learned that they will be providing a flier for contractors on The Mass RRP Law for all building departments in the state. These fliers are being made and laminated for distribution and placement at building permit counters. They will be displayed prominently and building departments will be asked to share this information with contractors who come in.
Here is the flyer that will be posted at building departments;
RRP compliance notice to contractors from Mass DOS.pdf
The State of Massachusetts took over the administration and enforcement of the EPA RRP Lead Law on 7/9/2010. There are significant enhancements to the baseline EPA RRP Lead Rule that impact trained contractors. One significant change is the Certified Renovator needs to be on site and in control of the work at all times when the work is in progress. Formerly under the EPA RRP Lead Rule the Certified Renovator could leave after setup of containment and be within a few hours away. The work could then be done by employees who received on the job training described in the EPA Lead manual. In addition, the term Certified Renovator has been changed to Lead Safe Renovator Supervisor. This change along with several others will require persistent vigilance by all contractors who work on pre-1978 properties to insure that they are in compliance. More to come.
Mark the RRP Coach