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let us know how it goes. shoot, michigan is supposed to take over enforcement this month from the epa, but have i gotten any information or been able to find out about how to register with the state? nope. no big surprise there though. the state is awful with communication and contractors/business owners.
 

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Discussion Starter · #3 ·
My state was a little slow too, seems like they can't do anything until they are approved by the EPA. I was lucky to have the state guy at my RRP training, since then, they have sent letters to all the licensed contractors. In Utah, everyone needs to be licensed and it is enforced fairly well. Rob has been "carded" on the jobsite by DOPL twice this year!
 

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uh..........What is a dust sampling tech?
It's a person who can do clearance testing on RRP jobs. They take wipes and wipe it on the floor, window sill and window trough. Then they send it to a lab to see how much lead dust is there.

The RRP supposedly will change next year to require clearance testing on certain jobs.
 

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Discussion Starter · #6 ·
Thanks Dean, it is required on HUD jobs as well, I'll be the only one in my area.
I'm also doing it to fulfill one of the requirements of being an RRP Instructor.
 

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Born To Be Mild
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I have not been keeping up. (obviously!) So are we going to still be able to clear our own jobs? Or will this have to be relegated to an independant contractor?

Is this a certification needed above and beyound the RRP cert? Or does my current certification cover me?
 

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Discussion Starter · #8 ·
Yes, it is above and beyond, you don't have to have it.
You cannot clear your own jobs.

From the EPA site,

conduct clearance testing following renovation , and
-- conduct non-abatement clearance in accordance with HUD regulations, and
-- collect lead dust sampling in other settings such as pre-sale home inspections, unit turnovers, or at the request of homeowners.

Like Dean said, it may be mandatory soon, July of 2011, under certain conditions, like demo work, hud, seems there was another one, maybe Dean will chime in.

Until it is approved, hard to know exactly, but it did not seem like it would affect a regular repaint.
 

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I have not been keeping up. (obviously!) So are we going to still be able to clear our own jobs? Or will this have to be relegated to an independant contractor?
We don't know exactly what the new RRP changes will be, but they are considering ...

1. Requiring clearance after scrapping more than 60 sq ft (I think that amount is right).

2. If you use a power sander or grinder.

There are other areas, but they are stuff that most painters don't do.

They are also considering putting up a containment wall outside to help keep the lead dust off of neighbors.
 

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Lambrecht Painting
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It sounds like the rules are going to fall more in line with the current lead abatement rules. I agree that a lead dust sampling should be sent off to a lab, the way that is allowed now makes no sense. The only way to ensure no lead is being left behind is to have a lab test samples. Only problem with lab testing is that they often take a week or longer before you get the results.
 

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Discussion Starter · #11 ·
The rules are going more to OHSA and LSHR, which already have rules in place, which RRP contradicts at times. I agree about the lab testing, the cleaning verification is a joke.
 

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You also want to look at your state laws.

In Texas, the EPA handles RRP, but the state doesn't allow dust sampling technicians.

Texas doesn't recognize certified renovators using test swabs. However, what you do on a RRP job is not a concern to Texas. However (again), if you need a formal paperwork (like for legal or being dragged into court) a test done by a certified renovator is worth nothing.
:eek:
 
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