Posted by Mark Paskell on Fri, Jun 25, 2010 @ 08:49 PM
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
Mark the Coach
RRP Training
Posted by Mark Paskell on Sat, Jun 19, 2010 @ 08:49 AM
Yesterday, the EPA formally announced that they will delay enforcement actions for violations of the RRP Rule certification requirement. The EPA has admitted that their efforts to fully implement the program as written and amended, has failed to produce the desired results.
Efforts by NARI and the NAHB has helped bring attention to the lack of sufficient training opportunities throughout the country.
Factors leading to EPA Fine Delays
1. Lack of EPA accredited trainers
2. Failure to educate regulatory agencies.
3. Insufficient funding to market and announce the program to states and the residential construction industry.
4. Numerous amendments leading to widespread confusion about the law. The opt out clause and clearance verification causing the bulk of the confusion.
5. Lack of funding and a strategy to enforce the law evenly.
6. Failure to educate homeowners.
7. Miscalculation of the amount of contractors, property managers and firms that need to be certified.
8. Failure to mesh the RRP law with other lead laws and programs leading to widespread confusion.
9. Miscalculation about the true costs to become compliant.
10. Insufficient industry capacity to supply contractors with the required supplies to comply with RRP practices.
11. The application to register as a Certified Firm confuses contractors leading to delays in applying.
12. Failure to provide effective outreach to the average residential contractor. Many contractors are just finding out or still have no idea that this law exists.
13. Effective lobbying efforts of NARI, NAHB, and other industry associations and spokesman.
Contractors and Property Managers Must Enroll in Certification by September 30th, 2010.
The EPA Mea Culpa does not remove the requirement to become certified. It only delays the inevitable responsibility to a later date. Contractors must prove that they are enrolled in a training by 9/30/2010 and must complete the training by 12/31/2010.
You must apply to become a Certified Firm by 10/1/2010
The announcement says that the EPA will not take enforcement actions for violations of the RRP Rule's firm certification requirement until 10/1/2010. Given the 90 day time frame for approving an application, all firms should apply right away to become a Certified Firm. After 10/1/2010, you will be non-compliant if you are not a Certified Firm.
Here is the Certified Firm Application
Certified Firm Application
Here is the official EPA announcement document;
EPA Mea Culpa, Contractors Given Reprieve on RRP Fines
Schedule your training now to insure that you have a seat
In the weeks preceding April 22nd we had over 400 people schedule RRP training. Many contractors and property managers waited until the last minute and some did not get in. Companies who wait until September to schedule their training may find seats hard to come by. Schedule your training now and avoid the last minute rush.
mark the coach
EPA RRP Training
EPA RRP Workshops
Posted by Mark Paskell on Thu, Jun 17, 2010 @ 06:53 AM
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.
mark the coach
EPA RRP Training
EPA RRP Workshops
Posted by Mark Paskell on Sun, Jun 13, 2010 @ 08:52 AM
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.
mark the coach
EPA RRP Lead Training
RRP Workshops
Posted by Mark Paskell on Sun, Jun 13, 2010 @ 08:18 AM
On 6/18/2010 Riverhead Building Supply and The Contractor Coaching Partnership will host a training for EPA RRP training in Southampton New York. The training site is the Old Polish Hall at 230 Elm St in Southampton.
There are very few Spanish EPA RRP trainings being offered in the United States. On Long Island their is a significant Hispanic population that needs to be trained to comply with the EPA RRP Lead Rule which became law on 4/22/2010. RBS asked The Contractor Coaching Partnership to bring one to their area for their Spanish speaking contractor clients.
Riverhead Building Supply continues to be a leader in their market place bringing important industry related training to their clients.
For more information on this training click here.
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 Thu, Jun 03, 2010 @ 08:36 PM
On 6/30/2010 The Contractor Coaching Partnership and Shawn McCadden will hold our first RRP Workshop at Brockway Smith in Andover, Mass. Our workshop team of instructors will include Insurance expert Tom Messier of Mason and Mason Insurance and Construction Lawyer Michael Sams of Kenney and Sams P. C.
This is the first in a series of workshops we will have throughout the year. We are all members of EMNARI with extensive knowledge of the EPA RRP Lead Law. We have met with both the EPA Region 1 and Department of Occupational Safety numerous times to make sure we are at the forefront of any movements in the EPA RRP Lead Law so that we can provide accurate and timely information to our industry.
We are grateful to Brockway Smith and Steve Fisher for their amazing support. They have opened their doors and provided the use of their state of the art training facility for many EPA RRP trainings throughout the year.
As of this date The Contractor Coaching Partnership has provided training for over 2500 contractors since February. We are receiving calls everyday from contractors on how to incorporate the RRP lead law into the business. Our RRP Workshops will help contractors navigate the choppy waters that lie ahead.
To learn more about our RRP Workshops follow the link provided below and please pass the word.
RRP Workshop Flyer; RRP Workshop with Shawn McCadden
Sincerely,
Mark the Coach
RRP Workshop on 6/30/2010 at BROSCO