Keeping Up with RRP.(Feature)

Keeping Up with RRP

By Ginny Petru, Contributing Writer

Stay on top of recent and upcoming changes in the EPA ruling to keep your customers informed.

Some might say the Environmental Protection Agency (EPA) Renovation, Repair and Painting (RRP) Rule feels like a construction project with a customer who keeps changing his mind or continues to generate change orders after the original plan is accepted.

Over the last year, we have seen some changes in the original blueprint of the RRP Rule, mostly due to how a lawsuit was settled. The consortium of organizations who brought forward the lawsuit included the Sierra Club, the Center for Environmental Health, New York City Coalition to End Lead Poisoning, Northern Manhattan Improvement Corporation, New York Public Interest Research Group and Make the Road New York. They felt the RRP did not go far enough in protecting the health and well-being of children against the health hazards of lead paint.

These changes present more compliance issues. However, they also bring more opportunities to expand your business as the tentacles of RRP creep into more areas of construction and renovation.

Opt-out provision. The original RRP Rule contained an "opt-out" provision that enabled homeowners to sign a statement to "opt-out" of the Renovation, Repair and Painting work practice requirements.

Status: With the refinement of the RRP Rule in July 2010, the "opt-out" provision was eliminated. This option is no longer available. See the Federal Register of May 6, 2010, for details: http://edocket.access.gpo.gov/2010/2010-10100.htm.

Clearance testing. The EPA is currently deciding revisions to the way in which an area is "cleared" for occupancy after RRP work has been completed. Currently, contractors use a "white glove" methodology. The contractor carefully cleans the work space area, then wipes surfaces with a cloth to collect any dust that still might linger. The wipe is compared to a comparison chart that indicates by color if the area is clear of hazardous lead dust levels.

The RRP Clearance Testing revision under consideration would require expensive multiple dust wipe tests verified through an independent, third-party, EPA-accredited lab. The type of work that this would cover would be "jobs involving the demolition or removal of plaster through destructive means or the disturbance of paint using machines designed to remove paint through high-speed operation, such as power sanders or abrasive blasters." (75 FR 25038): http://www.nmhc.org/Content/ServeContent.cfm?ContentItemID=5771

Status: The EPA will render its final rule in regards to changing the Clearance Testing process in July 2011. The comment period for this revision is closed.

RRP expansion to commercial/public facilities. Currently, RRP applies only to residential properties. The revision currently being considered by EPA is expanding the RRP Rule to include all renovation, repair or painting done on the exterior and/or interior surfaces of commercial and public facilities built before 1978. So basically, any building built before 1978 would be considered under the RRP Rule.

Status: The actual proposal on how the EPA will expand the RRP Rule to include these facilities will be issued to the public on December 15, 2011. The final action on the proposal will be July 15, 2013.

Distributor opportunities

The industry has been a little slow in fully embracing lead-safe certification. And for good reason ... it has been an extremely difficult economic period and adding more expense to running a construction or renovation business has been burdensome for many companies. Additionally, many in the industry approached RRP with skepticism and questions about full enforcement. Others have just decided to not work on pre-1978 homes.

However, there are many professionals who have decided to get lead-safe certified and are finding ways to profit from the RRP Rule. As the RRP Rule becomes better recognized in the public as a requirement and it is expanded to all pre-1978 buildings, there will be a greater need for supplies and materials to guarantee compliance.

As a distributor, it can be beneficial to stock inventory to assist contractors in complying with the RRP Rule. Some contractors are even packaging plastic bins with all materials needed for an RRP work site, including the necessary forms and procedure "cheat sheets." When they go on an RRP work site, they just bring the "RRP Bin" with them.

As a distributor, you can promote your savvy in RRP by labeling certain inventory items as "RRP Compliant" materials in your catalog and on your website. You may want to actually bundle materials and sell them in an "RRP Box" that includes RRP warning signs, RRP worksite forms (available on the internet) and the required personal protection equipment. Some of your customers may appreciate this packaging, as it might help them estimate material costs for their RRP proposals.

You can read the list of materials needed for RRP work by downloading the EPA RRP Student Manual: http://www.epa.gov/lead/pubs/rrp_8hr_studentmanual_feb09.pdf.

In addition to basics like barrier tape, heavy-duty plastic sheeting, tape (duct, painters, masking), orange cones, disposable tack pad and cutting tools, be sure to pay special attention to some of the more specific items required. As an example, the HEPA vacuum that is required to be used for interior work area cleaning must have a filter that is capable of capturing particles of 0.3 microns with a 99.97% efficiency (40 CFR 745.83). And respirators must meet NIOSH testing standards and be marked with NIOSH designations such as P100 and N95.

There is no doubt the RRP Rule has added a tremendous amount of additional work to pre-1978 residential worksites. As we look forward and witness the ever-changing blueprint of RRP, it appears the sales opportunities will also continue well down the road.

Ginny Petru is senior managing editor of ForRenovationPros.com, an online information source dedicated to the EPA's RRP Rule and key issues facing this marketplace.

FORRENOVATIONPROS.COM

ForRenovationPros.com is an online information source dedicated to the EPA's RRP Rule and key issues facing this marketplace. News, products, blogs and articles will help you better understand the industry and how it impacts your business and your customers' businesses.

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