On 6/18/2010 the EPA issued a memo about enforcement delays. The Contractor Coaching Partnership has received numerous calls from contractors who are now more confused than before. One remodeler commented "does this mean I have nothing to worry about until the end of December?" Another said "does this mean I don't need to use mountains of plastic or buy a HEPA Vac until December?" Another said "see, I told you so, the EPA will never enforce this. It is just a scare tactic from government to get our money". A contractor from Boston said "the National Home Builders Association will force them to delay it or repeal it."
This recent development in the RRP Law, is causing many contractors to believe that they can put off the training and certification and still perform work with no worries until the end of the year. I fear that this false sense of security may expose uncertified and untrained contractors to severe penalties, if they do not use the mandated practices required under the EPA RRP Lead Law.
The memo specifically addresses the status of two items required by the EPA RRP Lead Law;
1. Firms will have until 9/30/2010 to complete the Certified Firm Application and receive their Certified Firm License.
2. Renovators must prove that they are enrolled in a EPA RRP Certified Renovator Class and they MUST complete their training on or before 12/31/2010.
The memo also states that contractors must follow lead safe practices. Even if a contractor has not been certified or trained they will still be responsible for knowing and following the EPA RRP Lead Rule. In other words, even though a contractor is not trained they MUST know and follow the RRP practices if they work on pre-1978 properties and trigger the rule! Does that make sense?
EPA FAQ Clarification on 6.18.2010 Delay Memo
In a recent posting on the EPA FAQ section, questions were posted and answered to clarify this. See the document below for clarification.
If you are contractor who is certified please pass this information along to those you know who are not. If you are not certified or trained, please read the memos carefully and prevent a situation where you can be fined.
Since 4.22.2010 there have been numerous changes to the RRP Lead Rule. In our RRP Implementation Workshop at Brockway Smith on Wednesday we covered many of these topics. The contractors who were present are Certified Renovators and Firms. Many of them were unaware of the recent developments. One workshop contractor said "I would like to think that I am well informed, but today I learned how little I really know about this law. I am shocked about all the changes in just 2 months".
Can you imagine how well informed uncertified contractors are at this point?
Stay tuned here to keep up on this changing landscape.
Another great resource for information on the RRP Lead Rule is Shawn McCaddens's RRPedia blog.