construction business owner education and peer group program click to learn more

The Contractor Coaching Partnership Blog

EPA RRP Coaching and Consulting for Contractors

Posted by Mark Paskell on Sun, Nov 18, 2012 @ 09:24 PM

The recent EPA RRP fine announcement has many contractors throughout the country thinking about what would happen if the EPA audited their jobs. We received many calls this week regarding baseline RRP regulations and protocol. The lack of general knowledge is common amongst most contractors. Several are asking for re-training, guidance and coaching on catching up with all the changes since 2010.                    

                               RRP Coaching/Consulting Contact Us Today

Based on numerous conversations it appears that many contractors have not taken the RRP Law too seriously, are not up to date on changes to the law and are not in a good position if the EPA comes calling. 

Here is a list of items from our conversations with contractors in the past week revealing where they need to get up to speed on RRP.

  • Are trained in the 8 hour course but haven't read the book since 2010.
  • Have not applied to be a Certified Firm.  
  • Have not implemented a paperwork documentation process (many of the fines are because contractors could not produce the records on jobs done months ago)
  • Have not been providing the Renovate Right Pamphlet on pre 1978 properties (several fines for not giving out the pamphlets)
  • Are unaware of changes to the Renovate Right Pamphlet
  • Cannot find their certificate
  • Cannot find their cleaning verification card
  • Do not remember the prescriptive RRP lead safe containment requirements
  • Not sure of what documents they need in the job or in the office
  • Are unaware of the numerous amendments to the RRP Law
  • Some still think the OPT OUT Clause in effect
  • Some think the law was repealed
  • Are unaware that they are required to provide a post renovation check list to the homeowner
  • Are not requiring their subs to be certified
  • Are unaware of the new Vertical Containment requirement
  • Are unaware that Lead Check is approved for plaster
  • Are unaware of D Lead test kit
  • Are unaware of the paint chip sampling process
  • In states where the law has been taken over they are unaware that they need to follow the state guidelines. (Massachusetts and Rhode Island have their own programs)
  • Never purchased a HEPA vacuum
  • Have a HEPA vacuum but do not use shroud attachments
  • Never learned about the OSHA requirements for working on lead projects (Mass requires compliance with OSHA medical monitoring and respiratory standards)
  • Give out respirators to workers without medical clearance
  • Don't use personal protective equipment

After compiling the notes from our conversations this week we are amazed at how little contractors have retained from their RRP training over two years ago. Some may need to go through the training again since they haven't opened the book in two years. Very few companies have implemented record keeping and documentation processes. The unfortunate reality is most contractors are not in a good position if the EPA or Authorized State comes to audit a RRP job.  

                                     RRP Coaching/Consulting Contact Us Today


Tags: rrp coaching