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Old 01-23-2011, 12:46 PM   #1
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Default 2011 RRP Changes

Thought it wouldn’t hurt to begin talking on the 2011 RRP changes that will most likely take place. In general, the changes are ...

1. Certified renovators will get a new way to test for lead based paint. This would be paint chip sampling.

2. On exterior work, put up vertical containment if work will affect surfaces within 10 feet of the property line. Assumption is “neighbors” property line.

3. Dust Sampling test by Lead Inspector, Assessor or Dust Sampling Technician after use of heat gun at below 1,100 degrees … removal or replacement of door or window frames … scraping 60 square feet of a painted surface and removing more than 40 square feet of trim/molding/cabinets (or other fixtures).

4. Clearance testing by the same folks mentioned in number 3. This will be required after demolition of 6 square feet of plaster and lath … using machines to remove paint (sanding, grinding, power planning, needle gun & abrasive blasting).

Good reason to begin talk, is that your contracts may need to be changed. You may also have to add cost into estimates of jobs coming up in late summer and you may want to consider becoming a dust sampling technician.

Note: Not all states allow dust sampling technicians.
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Old 01-23-2011, 12:49 PM   #2
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Oh the reasons just keep piling up to avoid this sector at all costs.
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Old 01-23-2011, 12:51 PM   #3
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Thanks Dean, what info have you got about chip sampling? Price? Procedure?
This one of the reasons I got my DST, I think there will be a demand for clearance testing, even where not required, just as a CYA.
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Old 01-23-2011, 12:52 PM   #4
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Old 01-23-2011, 02:26 PM   #5
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Thanks Dean, what info have you got about chip sampling? Price? Procedure?
This one of the reasons I got my DST, I think there will be a demand for clearance testing, even where not required, just as a CYA.
Find an approved EPA lab and ask them what size sample they want and the cost. It could be around $20 to test each paint chip sample.

You would need to put a folded piece of paper (like the video) to make sure you collect all the paint. You also want to make sure that you get all layers of the paint.

There are several ways to get the 1 sq in or 4 sq inch sample. On sheetrock, you can cut a square out using a utility knife. Then you would remove all (or as much as possible) any substrate materials (like the sheetrock and paper coating on top of the sheetrock).

On wood, concrete or metal … it is often easier to use a heat gun below 1,100 degrees to blister up the paint and scrape it off. You can also use a scraper or chisel.

Repairing the area where you removed the paint chip sampling is required before leaving for the day. This can be as simple as putting some spackling over the area or doing a full repair.

You would then put one paint chip per container (in most cases) in a transport tube, similar to the one you would use for dust wipes. Next, you need to fill out a chain of custody form that most laboratories provide and mail the samples to the approved laboratory.

Wait a few days and the lab will tell you the results.
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Old 01-23-2011, 02:30 PM   #6
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So the renovator could do this, find out while although positive via Swab test, levels may be under levels that require RRP?
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Old 01-23-2011, 02:50 PM   #7
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So the renovator could do this, find out while although positive via Swab test, levels may be under levels that require RRP?
Yes, as far as the paint chip sampling, the Renovator will be able to do this, without any additional training.

Realistically, there is no practicable reason to do paint chip sampling. It takes more work, larger samples and higher cost to do a paint chip sample.

I have a gut feeling that ultimately, the EPA will remove the LeadCheck and D-Lead only leaving the paint chip sampling the only way to test. However, I have no proof of this. Just speculation on my part.

The only advantage of paint chip sampling is that you can get an accurate reading. Hard to tell if LeadCheck or D-Lead is reading a above or below the level.

You're the expert on the Dust Sampling Technician, since you are the only one around that I know that has already taken the course. So any questions on that subject should be answered by you IMO.
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Old 01-23-2011, 04:45 PM   #8
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Quote:
Originally Posted by Dean CRCNA View Post
Thought it wouldn’t hurt to begin talking on the 2011 RRP changes that will most likely take place. In general, the changes are ...

1. Certified renovators will get a new way to test for lead based paint. This would be paint chip sampling.

2. On exterior work, put up vertical containment if work will affect surfaces within 10 feet of the property line. Assumption is “neighbors” property line.

3. Dust Sampling test by Lead Inspector, Assessor or Dust Sampling Technician after use of heat gun at below 1,100 degrees … removal or replacement of door or window frames … scraping 60 square feet of a painted surface and removing more than 40 square feet of trim/molding/cabinets (or other fixtures).

4. Clearance testing by the same folks mentioned in number 3. This will be required after demolition of 6 square feet of plaster and lath … using machines to remove paint (sanding, grinding, power planning, needle gun & abrasive blasting).

Good reason to begin talk, is that your contracts may need to be changed. You may also have to add cost into estimates of jobs coming up in late summer and you may want to consider becoming a dust sampling technician.

Note: Not all states allow dust sampling technicians.
Thanks a lot for posting this Dean!

It would be nice if the EPA informed certified contractors as they continue to alter the rules!
I became certified early last year and only found out through the grapevine that they had eliminated the opt out clause!
When I took the course we were taught that the homeowner could opt-out under certain conditions and given the forms.

Questions

Have you heard anything about the possibility of the opt-out being brought back? I heard a rumor, but I imagine it's just that.
Again, thanks a lot
Cliff
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Old 01-23-2011, 05:35 PM   #9
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Originally Posted by CliffK View Post
Thanks a lot for posting this Dean!

It would be nice if the EPA informed certified contractors as they continue to alter the rules!
I became certified early last year and only found out through the grapevine that they had eliminated the opt out clause!
When I took the course we were taught that the homeowner could opt-out under certain conditions and given the forms.

Questions

Have you heard anything about the possibility of the opt-out being brought back? I heard a rumor, but I imagine it's just that.
Again, thanks a lot
Cliff
The only thing I know about the Opt-Out, was that the NAHB did a press release saying they were going to sue over this. Not sure if they ever officially did. Haven't heard anything more about it.
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Old 01-24-2011, 03:36 AM   #10
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So much for "free" estimates.
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Old 01-24-2011, 08:17 AM   #11
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You would think they could, at the very least, keep those who are certified & have signed up for email updates informed on any and all changes.
AAHH government bureaucracy at its finest!
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Old 01-24-2011, 08:31 AM   #12
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Changes to take place in July, I believe.
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Old 01-24-2011, 09:23 AM   #13
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Thanks Dean.

Can you post a link to these changes...I just can't seem to find them on their website. BTW, always had a poor user experience with the epa lead website.
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Old 01-24-2011, 09:47 AM   #14
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Thanks Dean.

Can you post a link to these changes...I just can't seem to find them on their website. BTW, always had a poor user experience with the epa lead website.
http://edocket.access.gpo.gov/2010/pdf/2010-10102.pdf
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Old 01-24-2011, 10:17 PM   #15
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So if the EPA is making ZERO effort to directly inform the contractors that MADE THE EFFORT to get cert'd, and the contractor doesn't hang out on cool forums like this to get tipped off, how would they ever know? And isn't that a defense- the EPA made NO effort to inform, about anything, ever?
Here the whole thing has gone completely silent. Stores aren't talking about it, contactors aren't- nothing.
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Old 01-24-2011, 11:24 PM   #16
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So if the EPA is making ZERO effort to directly inform the contractors that MADE THE EFFORT to get cert'd, and the contractor doesn't hang out on cool forums like this to get tipped off, how would they ever know? And isn't that a defense- the EPA made NO effort to inform, about anything, ever?
Here the whole thing has gone completely silent. Stores aren't talking about it, contactors aren't- nothing.
If I was paranoid, I would think they were doing things this way to setup contractors to be busted for non-compliance. Instead I will chalk it up to governmental idiocy.
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Old 01-25-2011, 06:46 AM   #17
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If I was paranoid, I would think they were doing things this way to setup contractors to be busted for non-compliance. Instead I will chalk it up to governmental idiocy.
You make an interesting point Dean. They are going to need more money than just the certification fees to run this program. They are probably counting on the fines.
Maybe we should ask Capt Sheetrock what he thinks???
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Old 01-28-2011, 04:06 PM   #18
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Does anyone know if you will need to be a dust sampling tech in order to even test the house prior to RRP work? I think I heard in California that they want you to be a certified dust sampling tech. to test prior to the work and then again for the dust after the work is complete. I have no idea if this is accurate. The amount of info out there concerning all of this is confusing. I guess if they eventually go to the paint chip testing that has to be sent to the lab that will be similar. Then we will have a third party testing before work and another third party checking for any dust or contamination after work is complete. Can a RRP contractor become a dust sampling tech. and test his own job?? That sounds like a conflict of interest that would defeat the purpose.
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Old 01-28-2011, 04:26 PM   #19
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Does anyone know if you will need to be a dust sampling tech in order to even test the house prior to RRP work? I think I heard in California that they want you to be a certified dust sampling tech. to test prior to the work and then again for the dust after the work is complete. I have no idea if this is accurate. The amount of info out there concerning all of this is confusing. I guess if they eventually go to the paint chip testing that has to be sent to the lab that will be similar. Then we will have a third party testing before work and another third party checking for any dust or contamination after work is complete. Can a RRP contractor become a dust sampling tech. and test his own job?? That sounds like a conflict of interest that would defeat the purpose.
A dust sampling tech can not do a lead inspection prior to RRP work.

A certified renovator, lead inspector or lead assessor can do a lead inspection prior to RRP work. Note: In many states, a certified renovator is only allowed to check only the components that will be disturbed. In other words, they can not do whole house inspections.

I thought in California, test swabs were not allowed, so only lead inspectors/assessors could do inspections. Not sure where they will stand with the paint chip sampling coming up.

In the preamble of the changes, they are considering letting the dust sampling tech be one of the workers in the firm. But they haven't made any for sure statements. A certified renovator can become a dust sampling tech.
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Old 01-28-2011, 05:10 PM   #20
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Quote:
Originally Posted by Dean CRCNA View Post
Thought it wouldn’t hurt to begin talking on the 2011 RRP changes that will most likely take place. In general, the changes are ...

1. Certified renovators will get a new way to test for lead based paint. This would be paint chip sampling.

2. On exterior work, put up vertical containment if work will affect surfaces within 10 feet of the property line. Assumption is “neighbors” property line.

3. Dust Sampling test by Lead Inspector, Assessor or Dust Sampling Technician after use of heat gun at below 1,100 degrees … removal or replacement of door or window frames … scraping 60 square feet of a painted surface and removing more than 40 square feet of trim/molding/cabinets (or other fixtures).

4. Clearance testing by the same folks mentioned in number 3. This will be required after demolition of 6 square feet of plaster and lath … using machines to remove paint (sanding, grinding, power planning, needle gun & abrasive blasting).

Good reason to begin talk, is that your contracts may need to be changed. You may also have to add cost into estimates of jobs coming up in late summer and you may want to consider becoming a dust sampling technician.

Note: Not all states allow dust sampling technicians.

Soooo whats the new way to test for lead. I'm doing a bid on Monday and need to test. I went to buy the old test kit and tey dont even cary it any more? So what do I use now????
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