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Old 09-29-2011, 12:01 AM   #21
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Here is the link to the whole thing - the doc in the last post was from 7-6-2011. If you found that interesting read the one from 3-30-2011

link

As you can see they are being sued for not having done any studies on the matter - Just like dean is asking you to show studies. This group is asking the Epa to show its studies which there were none when concerning this opt out rule

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Old 09-29-2011, 06:10 AM   #22
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I still would like to get an answer from the EPA about the generation of billions,( trillions?) of pounds of lead dust contaminated PLASTIC sheeting that is being generated(or will be, if all the rules are followed)

I asked this at my class and got a laugh and buy some 3M stock quote.

I ,for one, take this seriously. This stuff cannot be recycled, so it sits in a landfill forever?. Just think of the quanity of this stuff if everbody gets compliant, it blows the mind.
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Old 09-29-2011, 11:00 AM   #23
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@ Dean, sorry about the confusion, brother. I meant no disresect. It's hard to nuance print talk, but my dialog is not of an angry man, shouting and foaming at the mouth, while pointing a finger, but rather, respectively subdued. So please except my apologies, as I did not mean to be offensive. Yes, it's true that I have raised a bit of lead dust in my time, and no I havn't been sued, and the effective methods of removal ( ie flame removal, interior, grinding, exterior) have lost thier appeal to me. But, these massive projects were completed before the laws were instated, And it's younger man work. The majority of my work is and was interior restoration, design and construction.
My only intentions are to protect conscientious, hard working guys, from being exposed to lawsuits they cant defend themselves against, by asking questions and posing solutions. I think were on the same page.

@ Pat Thanks for that link, brother. that information is exactly what I wanted, and it's pretty clear by those challenges, that a lot of knowledgeable people are on this case on our behalf. That is good news for us. Again, thank you
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Old 10-03-2011, 04:09 PM   #24
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Quote:
Originally Posted by Dean CRCNA View Post
When you ban the group together to reinstate the opt-out or to promote a waiver ... you are going to have to bring forth evidence (scientific studies, research ... etc.) that shows this would be acceptable.

What cannot be used is personal opinion or speculation IMO.

Can any of you reference me to these types of studies? I really would like to read them.
That is pretty funny as the EPA presented no real data to prove that the Opt-Out clause should be removed in the first place. This is the basis of a suit brought against the EPA by NARI. In fact, most of the data that supports this ruling, that the RRP is necessary at all, is suspect.

Yes there is lead, of that there is no doubt. Yes, it is bad for you, but so is salt. The real numbers and percentages of individuals poisoned by lead because of professional renovations is a fraction of the over all number of poisonings and yet the focus of this regulation is to protect that fraction of the possibly poisoned.

What's more there is always the unintended consequences: that the work is being performed by the less-than professional contractor who is willing to skirt the rules and the client is willing to do so to save the added expense and thus possibly endangering themselves needlessly because said contractor exposes the client's family to lead.

And on top of all of this even though Lead has been banned from just about all paints there are greater hazards in the paint now than lead could ever hope to be. Crystalline Silica is a component of most contractor grade paints is a widely known carcinogen. A subject for another day probably 30 years from now.
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Old 10-03-2011, 06:06 PM   #25
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Originally Posted by Roamer View Post
That is pretty funny as the EPA presented no real data to prove that the Opt-Out clause should be removed in the first place. This is the basis of a suit brought against the EPA by NARI. In fact, most of the data that supports this ruling, that the RRP is necessary at all, is suspect.

Yes there is lead, of that there is no doubt. Yes, it is bad for you, but so is salt. The real numbers and percentages of individuals poisoned by lead because of professional renovations is a fraction of the over all number of poisonings and yet the focus of this regulation is to protect that fraction of the possibly poisoned.

What's more there is always the unintended consequences: that the work is being performed by the less-than professional contractor who is willing to skirt the rules and the client is willing to do so to save the added expense and thus possibly endangering themselves needlessly because said contractor exposes the client's family to lead.

And on top of all of this even though Lead has been banned from just about all paints there are greater hazards in the paint now than lead could ever hope to be. Crystalline Silica is a component of most contractor grade paints is a widely known carcinogen. A subject for another day probably 30 years from now.
No doubt we will all be dead by then from silica poisoning
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Old 10-03-2011, 11:42 PM   #26
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Quote:
Originally Posted by Roamer View Post
That is pretty funny as the EPA presented no real data to prove that the Opt-Out clause should be removed in the first place. This is the basis of a suit brought against the EPA by NARI. In fact, most of the data that supports this ruling, that the RRP is necessary at all, is suspect.
First, the EPA included the opt-out. They were sued and the other party presented the proof.

Secondly, where does it say that no real data was presented? You are hearing this from a brief that the NAHB gave. This brief is "opinion". They could have also said in the brief that you like to wear women's clothes. Doesn't mean it is true. Doesn't mean they have any evidence. Just means they are expressing an opinion.

Plus, anyone can say anything is "suspect". Once again, it doesn't mean it is true. Doesn't mean they have any evidence. Just means they are expressing an opinion.

Quote:
Yes there is lead, of that there is no doubt. Yes, it is bad for you, but so is salt. The real numbers and percentages of individuals poisoned by lead because of professional renovations is a fraction of the over all number of poisonings and yet the focus of this regulation is to protect that fraction of the possibly poisoned.
What are the real numbers and percentages? What are the numbers that show it is a fraction of the over all number of lead poisonings? I would like to know what those numbers are that you have!!!

Quote:
What's more there is always the unintended consequences: that the work is being performed by the less-than professional contractor who is willing to skirt the rules and the client is willing to do so to save the added expense and thus possibly endangering themselves needlessly because said contractor exposes the client's family to lead.

And on top of all of this even though Lead has been banned from just about all paints there are greater hazards in the paint now than lead could ever hope to be. Crystalline Silica is a component of most contractor grade paints is a widely known carcinogen. A subject for another day probably 30 years from now.
More on the opt out.

1. What about the woman who opts-out without knowing she is pregnant?
2. What about the 6 year old child?
3. What about the grandparents opting out and then have their grandchildren visit?
4. What about the homeowners who opt-out but their exterior work poisoned the neighbors 2 year old?
5. What about the new buyer/renter who moves in with their infant to a place that just had major sanding of lead based paint?

The list goes on and on.

There is plenty of research on these.

On top of this, In adults, 3.6 mcg/dl can cause

1. a 25% increase risk of dying of cancer.
2. a 55% increase of dying from cardiovascular disease
3. a 89% increase of dying from heart attack
4. a 250% increase of dying from a stroke

this from a recent study published in Journal of the American Heart Association. JAMA showing similar things.

Adults measuring 2.11 mcg/dl, have 230% greater chance of major depressive disorders. This not including increase risk of panic and anxiety disorders.

3.6 and 2.11 is a speck of dust.
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Old 10-03-2011, 11:55 PM   #27
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Dean - Santiago Conception who was my instructor who is also in the article in the OP basically told us that the majority of all the testing was done on section 8 type houses. He also told the only reason they epa pulled the opt out rule was because they got sued by the sierra club.

There are some major flaws with this whole thing - How is it that homeowners are exempt from this rule if they perform their own work? yet we are not? So in a sense there is a opt out rule. And if the owners do their own prep work do you really think they will be as neat as a professional?

Dean - I appreciate your dedication and your position on pushing this thing. If everything stays the way it is we need allot more people like you.

Pat
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Old 10-04-2011, 08:26 AM   #28
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He also told the only reason they epa pulled the opt out rule was because they got sued by the sierra club.
Kind of what I was implying with my first response in the above post. EPA (when sued) didn't have to provide proof ... the people suing did. EPA basically saw that they were going to lose the suit, so settled. NAHB came in latter and did a lawsuit, but basically tabled it (put a hold on the lawsuit).

Quote:
There are some major flaws with this whole thing - How is it that homeowners are exempt from this rule if they perform their own work? yet we are not? So in a sense there is a opt out rule. And if the owners do their own prep work do you really think they will be as neat as a professional?
I agree. However, there is a major difference between someone poisoning/harming themselves and someone poisoning/harming others ... especially if they get paid for it.

Quote:
Dean - I appreciate your dedication and your position on pushing this thing. If everything stays the way it is we need allot more people like you.

Pat
Thanks. I fought to keep the opt-out in. In fact, to a large degree, I like where the original law was. Where the only requirement was to give the Renovate Right.

I see this similar to seat belt laws. Does wearing seat belts save lives? You bet. But how far can government go to force you to protect yourself? A fine line. On the issue of lead. Do the lead laws protect people? Yes. But how far should the government go in protecting people from their own decisions?
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Old 10-04-2011, 09:16 PM   #29
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What are the real numbers and percentages? What are the numbers that show it is a fraction of the over all number of lead poisonings? I would like to know what those numbers are that you have!!!
http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5803a3.htm

Above site by the CDC details a study of lead poisoning in NY state during 2006-2007.

Quote:
The results indicated that, during 2006--2007, the elevated BLLs of 139 (14%) of the 972 children with BLLs >20 g/dL were related to RRP activities (Table).
Yes this is disconcerting and definitely reason for concern. However, closer inspection of the 14% of the children exposed to lead from RRP activities shows that only 6.5% of of the 139 children (9 kids) were poisoned due to activities by professional contractors, whereas, 66% of the 139 children (91 kids) were exposed to lead from DIY'ers.

Quote:
Contractors performed a small percentage (6.5%) of RRP work related to elevated BLLs in New York state during 2006--2007. Resident owners or tenants performed 66% of this work. To help prevent lead contamination when contractors perform RRP projects, the U.S. Environmental Protection Agency issued regulations in March 2008 that will require all renovators in the United States that work on certain types of housing or child-occupied facilities to be certified and follow specific work practices as of April 2010 (8). To address the risk from RRP by owners and do-it-yourselfers, more public outreach and education is needed to raise awareness of potential lead-exposure hazards from RRP and to ensure protective measures that safely contain dust and paint chips. In New York, state and local health departments have implemented education programs on RRP activities and lead-safe work practices for contractors and do-it-yourselfers.†
It stands to reason that one of the unintended consequence of these regulations should consequently mean that more kids will be exposed to lead poisoning. This would be the result of increased costs associated with a professional RRP contractor as more homeowners seek to save money and do the work themselves.

The above study was performed two years prior to the implementation of the RRP.
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Old 10-04-2011, 09:42 PM   #30
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Great post Roamer - In other words this new RRP will make things worse not better as more and more Home owners decide to tackle the prep on their own instead of hiring out to a professional.

Pat
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Old 10-05-2011, 08:28 AM   #31
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Ref post 29

Roamer,

I could see where you would be upset if all of this RRP stuff was to help 79 kids nationwide (from what I understand you are implying).

My calculations ...

1. New York State says; A total of 8,723 children nationally had blood lead levels ≥ 25 mcg/dL in 2000. (closest figure to ≥ 20, which is showing in your link that I could find on their site).

2. 14% got EBLL from renovations, which equals 1,221 kids

3. 6.5% from contractors, which equals 79 kids

Do you really believe all this stuff is to just help 79 kids nationwide?

note: found that link a long time ago. I too had to read it several times and then investigate it.

additional note: In re-reading, it sounds like I'm being a smart a--. Sorry if I come across that way. Not my intention.
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Old 10-05-2011, 10:25 AM   #32
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So according to that data the money spent on RRP design and implementation plus the huge cost to contractors and HOs is to protect a microscopic sliver of the countryside children.

The EPA isn't spending money informing HOs about lead danger it is focused on the contractors. Well less than 1400 kids have EBLL from renovation AND contractors combined apparently.
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Old 10-05-2011, 01:53 PM   #33
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So according to that data the money spent on RRP design and implementation plus the huge cost to contractors and HOs is to protect a microscopic sliver of the countryside children.

The EPA isn't spending money informing HOs about lead danger it is focused on the contractors. Well less than 1400 kids have EBLL from renovation AND contractors combined apparently.
Believe me, if that was the case, then NAHB, NARI and the other contractor organizations would have used this successfully to get rid of RRP.

The first thing wrong is the 20 mcg/dl. The level of concern for children under 6 is 10 mcg/dl. Recent research is showing the level of concern at 5 mcg/dl, which equals to around 2 to 2.5 million kids.

The second thing that is wrong is that the report itself claims it's limitation. At the same time as this research, they did another along side. It showed 40% comes from renovations ... not 14%.

A third thing that is wrong is the definition they used for contractor ... a person under a contract. Many of the resident owner (who use their own employees (apartments)), other and unknown would now need to be Lead Safe Certified Firms officially.

Fourthly, while kids are the major concern, adults get harmed at very low rates as shown in a post above. Also of concern is the timeline. A contractor could have worked on the home 5 years ago and created the lead dust (that stays around forever, unless properly cleaned up) that is causing the EBLLS ... but weren't associated with the report.

These and more reasons are why the big contractor organizations realized that this wasn't a good thing to use to overturn the RRP (or even the opt-out). Once again, believe me ... they would have if they could have.
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Old 10-05-2011, 11:55 PM   #34
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Once again, believe me ... they would have if they could have.
Good point I'm sure they would have.
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Old 10-23-2011, 10:49 PM   #35
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Quote:
Originally Posted by Roamer View Post
http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5803a3.htm

Above site by the CDC details a study of lead poisoning in NY state during 2006-2007.

Yes this is disconcerting and definitely reason for concern. However, closer inspection of the 14% of the children exposed to lead from RRP activities shows that only 6.5% of of the 139 children (9 kids) were poisoned due to activities by professional contractors, whereas, 66% of the 139 children (91 kids) were exposed to lead from DIY'ers.

It stands to reason that one of the unintended consequence of these regulations should consequently mean that more kids will be exposed to lead poisoning. This would be the result of increased costs associated with a professional RRP contractor as more homeowners seek to save money and do the work themselves.

The above study was performed two years prior to the implementation of the RRP.
I read the study with interest and have but 2 observations. were these studies based on testing a target group of newborns, say age 1 year. Determining that the infants bbl was certifiably lead free, and then allowing them to be subject specifically to a lead contaminated job site, to arrive at the asumption that this was positively where the poisoning originated from? Of course not! This is my point, it is immposible to arrive at the conclusion these children were poisoned with RRP lead paint dust unless they were indeed subject to that kind of researched exposure, the rest is pure speculation. Did the child chew a painted toy? Who knows, who cares, it's now the contractors fault. Sue him. It is absolutely humanly immposible to contain lead dust 100% My second observation would be that there should be millions ( not hundreds) of people suffering from lead related illness at least, as all prior contruction would make the problem nationally epidemic. ( I think all those exposed children grew up and became congressmen and senators, that would explain it) Oh well, we're stuck with this law, as exasperating, and presumtuous as it is, but I was just curious on how this data was acquired, bacause it certainly wasn't scientifically acquired, that's for sure. Age old job site Bromide: When in doubt, blame the painter.
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Old 02-17-2012, 03:04 PM   #36
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Can someone please clarify a question on the rrp issue for me. I am bidding a 35 k sq ft commercial building, all exterior, that was pre 78. I have read on several articles that rrp only applies to residential and schools. Am I violating rrp rules by undertaking this job? Thanks
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Old 02-17-2012, 03:58 PM   #37
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Can someone please clarify a question on the rrp issue for me. I am bidding a 35 k sq ft commercial building, all exterior, that was pre 78. I have read on several articles that rrp only applies to residential and schools. Am I violating rrp rules by undertaking this job? Thanks
No RRP. Unless their is a child care facility in the building.
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Old 02-28-2012, 04:31 PM   #38
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hi guys , how many of you been in the middle of scraping a lead job when it starts to rain . are we held liable for that ? so why can,t we pressure wash it,s a bunch of bs
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Old 02-28-2012, 11:14 PM   #39
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its called check the weather!! pressure washing only blows **** everywhere!!! and yes ive been in the middle of a lead abatment right before the rain!! plan your trip and youll be fine
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Old 02-29-2012, 08:29 AM   #40
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Default Pressure washing conundrum

Pressure washing has its' place as a tool for removing mold, mildew, dirt and for cleaning the home after scraping and sanding to allow for proper paint adhesion. As long as it is done right it doesn't just "blow ---- everywhere! I was being facetious as my comment was merely taking a jab at our responsibility as painters to collect the runoff. As for the weather, New England is unforgiving as it can change in a moments notice and as any painter knows even with 'planning ahead' there will be those occasions out of your control. Get it!
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