# 2011 RRP Changes



## Dean CRCNA

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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## plainpainter

Oh the reasons just keep piling up to avoid this sector at all costs.


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## RCP

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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## aaron61

Sigh


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## Dean CRCNA

RCP said:


> 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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## RCP

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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## Dean CRCNA

RCP said:


> 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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## CliffK

Dean CRCNA said:


> 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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## Dean CRCNA

CliffK said:


> 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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## 6126

So much for "free" estimates.


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## aaron61

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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## Dean CRCNA

Changes to take place in July, I believe.


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## y.painting

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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## Dean CRCNA

y.painting said:


> 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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## BrushJockey

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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## DeanV

BrushJockey said:


> 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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## CliffK

DeanV said:


> 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???:whistling2:


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## CliffK

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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## Dean CRCNA

CliffK said:


> 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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## dubinpainting

Dean CRCNA said:


> 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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## dubinpainting

This is all I could find.....Is this even EPA certified? Can I use this?


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## Dean CRCNA

Right now. Has to be LeadCheck or D-Lead. Nothing else approved.

Plus, only a Certified Renovator, Lead Inspector or Lead Assessor can use them (to make it official)


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## dubinpainting

Dean CRCNA said:


> Right now. Has to be LeadCheck or D-Lead. Nothing else approved.
> 
> Plus, only a Certified Renovator, Lead Inspector or Lead Assessor can use them (to make it official)


I am a certified Renovater, Just have not been keeping track of any of the updates, so where can I get the right test kit? I went to the Depot, and Richmond Hardware, both did not have them. Only this crappy one.


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## dubinpainting

The leadcheck they dont carry any more!!!! Thats the one in the tube u brake and rub on, it turns red if theres lead....I cant find em anywhere


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## CliffK

Dean CRCNA said:


> 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.
> 
> That must have been what I heard. Thanks Dean


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## Dean CRCNA

dubinpainting said:


> The leadcheck they dont carry any more!!!! Thats the one in the tube u brake and rub on, it turns red if theres lead....I cant find em anywhere


Order LeadCheck or D-Lead online. I heard the D-Lead was selling in some of the Home Depots, but haven't checked.


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## RCP

I agree with Dean's comments in post 19. :thumbsup: (all of them really!)

On the tests, the Swabs I get from Sherwin Williams, they have to be the LeadCheck from Hybrivet with the confirmation card inside. The DLead (can also be used on drywall) is supposed to be in Home Depot

Even if Dust Sampling is not going to be required, it is a good way to way to protect yourself to have a third party come in and clear it, although it is not necessary. I would recommend it more for a GC than a painter.


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## Different Strokes

I'm not starting yet another new lead thread for this question. 

Why are certain companies offering lead certification only good for 3 years, and others do not expire for 5 years. Some say it's $600, and others say it's much less. I'm confused. 

many here are certified, have any of you tried an online certification. any thoughts are appreciated. thanks


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## RCP

Different Strokes said:


> I'm not starting yet another new lead thread for this question.
> 
> Why are certain companies offering lead certification only good for 3 years, and others do not expire for 5 years. Some say it's $600, and others say it's much less. I'm confused.
> 
> many here are certified, have any of you tried an online certification. any thoughts are appreciated. thanks


I think you may have Firm Certification and Certified Renovator fees confused.

For the training:
If you take a Certified Renovator class by an EPA Approved trainer, the Certification is good for 5 years. Costs vary because the training is done by private companies (that are approved and follow the EPA "script"). These companies can charge what they need to. Often they are sponsored in part by the local Homebuilders Associations or Paint stores and may be less. The average I have seen is $200. 

For the Firm Certification:
You can apply before you take your class, this basically is just registering your Firm with the EPA and saying your company will follow RRP Rules, this is good for 5 years and is $300.

You are in PA, so that is what applies to you, there are 10 other states that adopted the rule and you have to pay your Firm Cert fee to them, not the EPA.
As a CR, you can train your employees in Lead Safe Practices, but you are still responsible, just all your employees don't have to be a CR.

As far as the online courses, you still have to do the two hour hands on training, but it can be a good option for many.


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## Dean CRCNA

Different Strokes said:


> I'm not starting yet another new lead thread for this question.
> 
> Why are certain companies offering lead certification only good for 3 years, and others do not expire for 5 years. Some say it's $600, and others say it's much less. I'm confused.
> 
> many here are certified, have any of you tried an online certification. any thoughts are appreciated. thanks


Like RCP said.

You may be looking at other certificates in the lead area. Example, you may be looking at abatement courses that cost $600 and last 3 years.

You can go here to find a trainer to become a lead renovator http://cfpub.epa.gov/flpp/searchrrp_training.htm


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## Steve Richards

Dean CRCNA said:


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





Dean CRCNA said:


> http://edocket.access.gpo.gov/2010/pdf/2010-10102.pdf


This pdf is from 2010.
Any updates?

What about commercial property... is that still going to be RRP-ed starting this year?

Do I need to put on some gloves, goggles, and go dig around in the EPA's website? 
I was doing that for awhile last Spring on almost a daily basis.

Having that website on my "favorites" is a GD lie!


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## 6126

Depressing. I knew I should have gone with my first choice and became an Astronaut instead of a Painter


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## Steve Richards

Has there been any talk of bringing back the opt-out?

I haven't been on "that site" for quite awhile...I dread it, but I can't expect all my questions to be answered by the people here.

can I?


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## PatsPainting

Steve Richards said:


> Has there been any talk of bringing back the opt-out?
> 
> I haven't been on "that site" for quite awhile...I dread it, but I can't expect all my questions to be answered by the people here.
> 
> can I?


From what I understand that case to bring it back has been put on hold till other things get figured out.

http://www.painttalk.com/f27/any-updates-nahb-v-epa-12083/

Pat


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## Steve Richards

Thanks Pat.

It'd be nice if the EPA could notify cert-holders whenever any of this stuff changes.

man...what a good idea!


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## 6126

Couple questions here please. I took the class last spring, and after completing the class I pretty much came to the conclusion I wanted no part of this BS. Since then I have had to turn down several jobs. Now I am thinking about finishing my certification. Would the class I took last spring still be good? Also, I cant find anything on Washington State having its own laws, so I would apply directly to the EPA? From what I see looks like its $300? Next question, looks like it takes up to 90 days to process an application so I guess I couldnt bid or do any RRP work for possibly 90 days? Thanks


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## Steve Richards

Woodland said:


> Couple questions here please. I took the class last spring, and after completing the class I pretty much came to the conclusion I wanted no part of this BS. Since then I have had to turn down several jobs. Now I am thinking about finishing my certification. Would the class I took last spring still be good? Also, I cant find anything on Washington State having its own laws, so I would apply directly to the EPA? From what I see looks like its $300? Next question, looks like it takes up to 90 days to process an application so I guess I couldnt bid or do any RRP work for possibly 90 days? Thanks


So you took the class, but didn't send in yer 300 bucks...
I'd GUESS that because the certs are good for years, and there's no required "refresher course" (yet), that your course date is still ok.

The application form is on the EPA's website.
(I'd look for it for you, but I don't like digging around over there, even for myself)

Took about 6 weeks to get my actual cert. I don't know how long it takes nowadays.


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## RCP

As long as the class was held by an EPA Certified Trainer, you are fine, yes, you need to pay EPA, i hear times for the turnaround are much quicker.

Here is a link of all the states and their status as far as adopting it.


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## 6126

Thanks. And thanks for the link Chtis. Thats the same page I was at last night, and I clicked Washington and from what I gathered Wa was not one of the 10 states that has adopted its own laws. After I completed the course last May, it was not a matter of the $300. As I mentioned earlier, this new law scares me. I am also confused about the Dust Sampling Tech? Is this another course I need to take? And finally, this may sound like a stupid question, but since I have taken the class would I have to wait for the certificate to arrive from the EPA before I could bid or do any work? Sending off the $300 today would be no problem. Thanks


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## RCP

Woodland said:


> Thanks. And thanks for the link Chtis. Thats the same page I was at last night, and I clicked Washington and from what I gathered Wa was not one of the 10 states that has adopted its own laws. After I completed the course last May, it was not a matter of the $300. As I mentioned earlier, this new law scares me. I am also confused about the Dust Sampling Tech? Is this another course I need to take? And finally, this may sound like a stupid question, but since I have taken the class would I have to wait for the certificate to arrive from the EPA before I could bid or do any work? Sending off the $300 today would be no problem. Thanks


The Dust Sampling Tech is another certification, mine took 8 hours. You probably do not need it. Depending on the proposed changes, it may only be required on certain jobs. It is basically a clearance test after the job is done, and you can't do it for your own jobs. 

The EPA cert is basically saying you will comply and are registered. It is required, how close are you to Seattle? Maybe call and you can take it in?
http://www.epa.gov/aboutepa/region10.html


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## 6126

RCP said:


> The Dust Sampling Tech is another certification, mine took 8 hours. You probably do not need it. Depending on the proposed changes, it may only be required on certain jobs. It is basically a clearance test after the job is done, and you can't do it for your own jobs.
> 
> The EPA cert is basically saying you will comply and are registered. It is required, how close are you to Seattle? Maybe call and you can take it in?
> http://www.epa.gov/aboutepa/region10.html


 Thank you Chris. Seattle isnt too far. Approx 150 miles. So if I sent the EPA my $300 today, and alltough I have taken the course I would not be able to bid or do an estimate til the cert comes in the mail correct? I know... Im slow :jester:


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## 6126

I have come to the conclusion if I go through with this and become certified, I will probably take the course again because there is way too much I still do not understand.


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## CliffK

Woodland said:


> I have come to the conclusion if I go through with this and become certified, I will probably take the course again because there is way too much I still do not understand.


 At least with all this info from the forum you'll be the one asking the best questions!!!:thumbsup:


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## oldpaintdoc

Woodland said:


> Thanks. And thanks for the link Chtis. Thats the same page I was at last night, and I clicked Washington and from what I gathered Wa was not one of the 10 states that has adopted its own laws. After I completed the course last May, it was not a matter of the $300. As I mentioned earlier, this new law scares me. I am also confused about the Dust Sampling Tech? Is this another course I need to take? And finally, this may sound like a stupid question, but since I have taken the class would I have to wait for the certificate to arrive from the EPA before I could bid or do any work? Sending off the $300 today would be no problem. Thanks


The way the Firm Certification was explained to me is you do not have to wait for it to be processed as long as you have a copy of payment and a copy of the application on site.

This was explained to me from the EPA.


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## RCP

Woodland said:


> Thank you Chris. Seattle isnt too far. Approx 150 miles. So if I sent the EPA my $300 today, and alltough I have taken the course I would not be able to bid or do an estimate til the cert comes in the mail correct? I know... Im slow :jester:


Technically, correct. You need your number the EPA will issue. As many have said, enforcement is a joke, so if you do an estimate after you send away, will a horde of EPA agents be waiting outside? Doubtful!



Woodland said:


> I have come to the conclusion if I go through with this and become certified, I will probably take the course again because there is way too much I still do not understand.


You probably could, but the course is only as good as the instructor. They all follow the same powerpoint you can find on the EPA site. There are some online courses you could take to review, and skip the two hour hands on.
One benefit of taking another class is the discussions that come up are very informative, unless you have a disgruntled group of guys who resent being there!

This link has all the the up to date legal info.


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## 6126

RCP said:


> Technically, correct. You need your number the EPA will issue. As many have said, enforcement is a joke, so if you do an estimate after you send away, will a horde of EPA agents be waiting outside? Doubtful!
> 
> 
> 
> You probably could, but the course is only as good as the instructor. They all follow the same powerpoint you can find on the EPA site. There are some online courses you could take to review, and skip the two hour hands on.
> One benefit of taking another class is the discussions that come up are very informative, unless you have a disgruntled group of guys who resent being there!
> 
> This link has all the the up to date legal info.


Thank you. I will save that link too and study some more. I am going to send off my $300 today. Anyway, with a contractor needing the cert number I will not bid any RRP work til the cert actually comes back. As for the course? I need to take it again. I do not learn lor pick things up like you guys do. Im embarassed to admit this, but I do not learn like some of you. I have had a learning disability since I was a kid.Heck, I cant even spell or write correctly. A lack of education and many years of lacquer, epoxies, etc didnt help either. When I was in class that day, it scared me. All I pictured was doing estimates that now will cost me money for lead test kits, piles of paper work, possible fines for not complying even if it was unintentional, and then the signs and the yellow caution tape?  I only see that as a bunch of neighbors looking at me as the painter who is now poisoning their children. It really seems like that would put a guy under a microscope all though he is doing his best to abide by the law. This really sucks, but at the same time I also feel it could weed out many non legit contractors evenually. The contractors who are not only certified, but fluent in RRP work will domiante. If I take the time to learn this as some of you have it will pay off. I am very new in business. My phone is not exactly ringing off the wall. I am going to have to turn down a very big and possibably lucrative interior on an old Victorian today.  Not only could I use the work, but I really would have loved to have done this house, but not if it means a fine and going out of business. :no:


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## RCP

You don't have to be embarrassed, Rob is exactly the same way, so I know how you feel. You are making an effort to educate yourself, and that is what counts. In my opinion, that is what this forum is for. Please do not hesitate to ask a question, I am sure there are many others who benefit from it as well.


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## RCP

Has the house been tested?


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## 6126

RCP said:


> Has the house been tested?


No, it has not been tested. But, its a 1930s Victrian with plaster walls that need patching. Im sure its gotta be lead.


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## RCP

Woodland said:


> No, it has not been tested. But, its a 1930s Victrian with plaster walls that need patching. Im sure its gotta be lead.


Probably, you could find a CR to do a test, or better, or an Inspector like Dean that could use an XRF machine to determine the level of lead, which could be under the level required for RRP. On a large job, the initial expense might be worth it. 

Could you approach the homeowner with this option?


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## 6126

Yes, thats an option but dont I still need to have my cert back from the EPA to even work on the job? Especially if lead is found? The house is vacant right now but Im sure that doesnt change anything.


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## 6126

As much as I need the work, Im going to pass on any older homes until I get my certificate in the mail and understand all this.


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## Steve Richards

Send in for your cert now
Go ahead and assume there's lead...and follow RRP best you can
Times are too tough to let a good job go.
That's what I'd do anyhow

course...if one of us has to go to jail over it ..it won't be me, either...

send me a postcard


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## 6126

Steve Richards said:


> Send in for your cert now
> Go ahead and assume there's lead...and follow RRP best you can
> Times are too tough to let a good job go.
> That's what I'd do anyhow
> 
> course...if one of us has to go to jail over it ..it won't be me, either...
> 
> send me a postcard


LOL Yeah :whistling2: Im sending off the $300 for the certificate, but I think I would feel more comfortable taking the class again before attempting to branch into this. Its only 8 hrs. I can probably get SW to cover the cost for me.


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