The NARI Journal

Wednesday, July 30th, 2014

1 Those companies that are incorporating the RRP Rule into their operations through education and are using the rule as a strength that sets them apart from their competition.
2 Those that got certified, rarely do older home remodels, and make and find the RRP rule onerous but try to comply because it is the law.
3 Those that don’t know and don’t want to know about RRP and are in fear of the government ruining their livelihood. One fine could easily do that.

The passions are running high, lets face it the RRP Rule is changing the way we do business. I recently attended aResponsible Person certification class and the excavation community has worked with the EPA for years and gets it. Municipalities have incorporated the Best Management PracticesBMP into their operations and everyone is on a level playing field. Our river used to have rats running on the banks and raw sewage pumped into it. Now it is a beautiful place where our green belt is a highlight of the community.

I think the RRP Rule was poorly implemented but understand that it was a 10 year long process that was stuck in committee essentially so rather than postpone it again. They put it out and it is now a work in progress that is evolving into a solid policy. I have my gripes too, my primary one is that as a guideline it would have been easier to work with IE. DO DUSTLESS DEMOLITION AND CLEAN UP AFTER YOUR SELF.  Similar to the Responsible Person requirements contractors would be held responsible to eliminate lead paint dust but would be allowed to experiment with what works best for them. Focusing on results is what I believe BMP is all about. Lets face it, the rule does not take into account all of the types of situations that effect each specialty contractor weather is a prime example. That being said I for one am staying engaged and am trying to be an agent for constructive criticism.

Although I am running my business with the RRP flag attempting to set myself apart, I am understanding of the others.

My concern is that NARI contractors need to make a decision to either follow the rules, or decide not to work on pre-1978 homes.

I was recently asked to do a NARI sponsored presentation. I had it done by one of my fellow lead risk assessors at Lead Locators.

How are we as a group of Professional  Remodelers going to ensure we are keeping lead dust out of our work sites without verification? I urge my fellow NARI members to be vocal, do the best that you can. Test ahead of time or assume it is all leaded and verify your doing it correctly during the project and at the end. Perhaps we need to have an internal Lead Compliance Officer or committee that verifies appearance to the RRP rule. I will make a suggestion next opportunity I get.

I applaud those that are working to solve our problems and confusions between agencies likeOSHA.

I am pleased that there is a national discussion going on. I am anxious to see how states that are taking on the rule are adapting it to meet their individual needs.

I thank the Lead Community for being so involved and encourage them to stay vigilant so that the gains that were made are not lost over budget deficits and economic downturns.

Bottom line is that Morgan did a nice job of putting my story together. As a bonus she contacted the EPA and interviewed Laurie Fay to support the article. The implementation of RRP has been rocky to say the least.

I challenge The EPA to quickly get to word out to the public about RRP. I challenge the Remodeling Industry to work with the EPA to improve the nuts and bolts of the RRP program. I also challenge our industry to be leaders and agents for eduction just like the ones that have mentored me while I evolved from a “lemonade stand” into a real business. Cheers.