Five months have passed since the EPA RRP Lead Law went into effect on April 22nd, 2010. To date almost 500,000 contractors have been trained to become Certified Renovators. The 6/18/2010 extension has come and ended.
Are these RRP trained contractors ready to tackle an RRP project?
The reality is many contractors, who have obtained their training, are not ready. We have recently followed up with over 900 contractors to see how they were doing implementing the Certified Renovator training into their business. One basic question we asked "did you complete your firm certification application?" We found that over 50% of those called did not. Another question we asked was "did you purchase a HEPA vacuum?" Most said they had not. We asked if they had purchased or printed off Renovate Right brochures to give to homeowners again the answer was most have not. We asked if they purchased warning signs and perimeter caution tape and again no.
When asked why not contractors gave the following responses;
- I will fill out my application when the extension is over.
- I will buy a HEPA vacuum when I have the money.
- The EPA will never enforce this, they don't have the people.
- If I fill out the application then they will be able to find me.
- I don't have the money for the application.
- My trade association said the law will be repealed.
- I don't know where to buy the supplies.
- I am getting out of this business.
- I will worry about it when I get a RRP project
By far the most common response was the EPA delay followed by lack of enforcement and then not having enough money.
Other possible factors are;
- the confusion caused by the numerous amendments
- rumors due to lack of awareness and inconsistentcies between the EPA, OSHA and other lead programs
- not enough time in the course to go over all the material
- contractor apathy
- failure to quickly implement the RRP course material
The current EPA RRP Certified Renovator course covers a tremendous amount of material in one day. A similar course taught in the 1990's by HUD/NARI was a two day course. The HUD/NARI course covered the RRP lead safe practices and the OSHA lead safety procedures in two 8 hour days. We have been told by contractors who went through the 2 day HUD/NARI course that it was more comprehensive and they were better prepared.
Why did the EPA decide to only require 8 hours when the HUD/NARI class of the 90's was two days?
We do not know, however here in Massachusetts we are inundated with calls on how to comply with the referenced OSHA standards. The State of Massachusetts has partnered with OSHA and is requiring that contractors have respirator programs and worker safety programs in place as a condition to become a certified firm. The current Certified Renovator course references that contractors must be compliant with HUD and OSHA regulations regarding lead. However there is little time given to these subjects in the current RRP course.
Based on the Massachusetts DOS and OSHA programs many contractors are calling us to help them comply with the OSHA requirements. We are adding OSHA RRP material to our RRP Implementation Workshop to address this need. In addition we will begin to schedule OSHA classes for respirator and worker protection programs.
In conclusion, it appears that many RRP trained contractors still haven't opened the manual since they were trained and they have not prepared their businesses to start working on RRP projects. Whatever their reasons for not implementing the RRP Lead Rule, contractors are exposing themselves to potential violations and fines.
"Training immediately followed by implementation, insures what is paid for and learned in the classroom, makes it to the field"