# multi-unit RRP question



## Steve Richards (Dec 31, 2010)

I should probably already know this, but I don't.

I'm gonna do the exterior of a 23 unit apt bldg ..20 of those units are studio/buffet apts. 

Do I just need to get pamphlets to (and signatures from) the 3 tenants that have bedrooms?


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## Steve Richards (Dec 31, 2010)

ok..another question on this job.
Not in too bad of shape
Probably won't be able to fit it into the schedule before Spring.

What if I prep about 19.5 sq ft every month through the Winter?

Would I need to bill for that every month, or could my final invoice just say:
prep 19.5 sq ft on Nov. 3, Dec 5, Jan. 8, etc?


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## Dean CRCNA (Feb 4, 2010)

Steve Richards said:


> I should probably already know this, but I don't.
> 
> I'm gonna do the exterior of a 23 unit apt bldg ..20 of those units are studio/buffet apts.
> 
> Do I just need to get pamphlets to (and signatures from) the 3 tenants that have bedrooms?


Give the owner a pamphlet

On the 3 tenants ...

Obtain, from the adult occupant, a written acknowledgment that the occupant has received the pamphlet; or certify in writing that a pamphlet has been delivered to the dwelling and that the firm performing the renovation has been unsuccessful in obtaining a written acknowledgment from an adult occupant. Such certification must include the address of the unit undergoing renovation, the date and method of delivery of the pamphlet, names of the persons delivering the pamphlet, reason for lack of acknowledgment (e.g., occupant refuses to sign, no adult occupant available), the signature of a representative of the firm performing the renovation, and the date of signature.

This with the assumption you will not being doing any "common" areas and you keep under the 20 feet on exteriors like you were suggesting in post 2


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## Dean CRCNA (Feb 4, 2010)

Steve Richards said:


> ok..another question on this job.
> Not in too bad of shape
> Probably won't be able to fit it into the schedule before Spring.
> 
> ...


1 bill would be fine, but document in some way the monthly 19.5


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## Steve Richards (Dec 31, 2010)

Thanks Dean

IF (big if) I decided to prep less than 20 sq ft per 30 day period throughout the Winter, would I be compelled to notify anyone..or follow any other RRP rule for that matter?


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## Dean CRCNA (Feb 4, 2010)

Steve Richards said:


> Thanks Dean
> 
> IF (big if) I decided to prep less than 20 sq ft per 30 day period throughout the Winter, would I be compelled to notify anyone..or follow any other RRP rule for that matter?


No, because it is not an RRP job.


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## Steve Richards (Dec 31, 2010)

What if I could teach some Monkeys to scrape paint.
Is there anything in the book about non-human workers having to follow RRP?

J/K 

I'm just in the "thinking about how to do this" stage, and I do appreciate your replies.

Thanks again Dean


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## Steve Richards (Dec 31, 2010)

Dean CRCNA said:


> Give the owner a pamphlet
> 
> On the 3 tenants ...
> 
> ...


BTW
I'm sure the courtyard would be considered a "common area" on this building.
Do you think that would that mean I need to notify all the tenants in the buffet apartments too?
(I don't have that many pamphlets!)


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## Dean CRCNA (Feb 4, 2010)

Steve Richards said:


> BTW
> I'm sure the courtyard would be considered a "common area" on this building.
> Do you think that would that mean I need to notify all the tenants in the buffet apartments too?
> (I don't have that many pamphlets!)


Yes.

_Note: common areas are handle differently. You don't need to give each person a Renovate Right. You have to give them notice and tell them where they can pick up a Renovate Right_

I personally would go hot or cold, but not somewhere in the middle. Example: If I was notifying everyone (because of the common area), the zero bedroom folks may start thinking about their interior. Going to be hard to tell them that EPA doesn't protect them, but does protect the other 3 units.

Have you thought about getting a Lead Inspector to test the exterior and 3 interiors? You will be *disturbing* paint on those 3 interior units?


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## Steve Richards (Dec 31, 2010)

Dean CRCNA said:


> Yes.
> 
> _Note: common areas are handle differently. You don't need to give each person a Renovate Right. You have to give them notice and tell them where they can pick up a Renovate Right_
> So I'll post a sign that says: "if you want a pamphlet, ask the guy outside in the white clothes."?
> ...


But like I said, it's not in bad shape. Containment won't be a problem. Probably won't need to powersand anything either.


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## Steve Richards (Dec 31, 2010)

Dean CRCNA said:


> the zero bedroom folks may start thinking about their interior.


..and I'm sure the owner doesn't want that.

I'm thinking he may balk at blanket notification...and that's what made me come up w/the 20 sf per 30 days idea.

He's a 30+ year client, and although I've explained the rules to him more than once...he don't much care for 'em.

..but he likes me enough to not wanna see me in jail either.

I could even suggest he get someone else w/o fear of losing his business over it.
BUT...the job's a blank-check, and I'd sure like to have it on the schedule.


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## Steve Richards (Dec 31, 2010)

I'm considering suggesting we wait until after the election to decide on anything..see if maybe some of the rules get rolled back.
I'm not against RRP, but there are no children living in this complex.

..and so this thread evolves into me talking to myself.

That's ok Steve... typing things out helps you think sometimes.


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## Steve Richards (Dec 31, 2010)

I PMed Dean a question about this thread....

but I'll ask part of that here too...is there such thing as paint being "within normal lead levels".

Is there an "acceptable level"? I thought there was either lead, or there wasn't.


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## Gough (Nov 24, 2010)

Steve Richards said:


> I PMed Dean a question about this thread....
> 
> but I'll ask part of that here too...is there such thing as paint being "within normal lead levels".
> 
> Is there an "acceptable level"? I thought there was either lead, or there wasn't.


Steve, here's all I could find (from DOL.gov):

"HUD defines lead paint as having greater than 1 microgram per square centimeter of surface or 0.5% by weight. OSHA does not define lead paint based on content. Any detectable lead in a paint makes it lead paint for purposes of complying with OSHA regulations to determine worker exposure."

I have heard that 0.5% threshold in other contexts, but I can't remember where. Most days, I'm lucky if I can remember where I left my keys.


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## Dean CRCNA (Feb 4, 2010)

Paint can have .00001 to .99999 ug/cm2 of lead in it and still be considered not lead based paint according to EPA and HUD (but not OSHA).

This is the problem with LeadCheck or D-Lead, in that you don't have a number. When using LeadCheck or D-Lead, I would think the wording of "within normal lead levels" might be a temptation to use, but could be illegal unless that wording is defined as being less than 1 ug/cm2

A Certified Industrial Hygienist can't inspect for lead based paint for the Renovation, Repair and Painting Rule. Only a Lead Inspector, Lead Risk Assessor or a EPA Lead Renovator can do this. If the Environmental company you are dealing with is not one of these ... their results are worthless.


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## Steve Richards (Dec 31, 2010)

Dean CRCNA said:


> Paint can have .00001 to .99999 ug/cm2 of lead in it and still be considered not lead based paint according to EPA and HUD (but not OSHA).
> 
> This is the problem with LeadCheck or D-Lead, in that you don't have a number. When using LeadCheck or D-Lead, I would think the wording of "within normal lead levels" might be a temptation to use, but could be illegal unless that wording is defined as being less than 1 ug/cm2
> 
> A Certified Industrial Hygienist can't inspect for lead based paint for the Renovation, Repair and Painting Rule. Only a Lead Inspector, Lead Risk Assessor or a EPA Lead Renovator can do this. If the Environmental company you are dealing with is not one of these ... their results are worthless.


Are you a lead inspector/risk assessor, Dean?..or do you know all about this stuff because it's a hobby of yours?
(if that's the case, maybe you need to get out more )

Do you happen to know if an XRF analyzer would give those numbers, or if they'd need to be obtained through a lab? 

..and if a CIH would typically use a XRF? (I'd never heard of a Certified Industrial Hygienist until yesterday)


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## Dean CRCNA (Feb 4, 2010)

Steve Richards said:


> Are you a lead inspector/risk assessor, Dean?..or do you know all about this stuff because it's a hobby of yours?
> (if that's the case, maybe you need to get out more )
> 
> Do you happen to know if an XRF analyzer would give those numbers, or if they'd need to be obtained through a lab?
> ...


Yes to being a Lead Inspector and Lead Risk Assessor.

My XRF gives 2 decimal places, so it could read .99. Lab could also give those numbers.

It would be rare for a CIH to have XRF. Rare for a lot of Risk Assessors to have one. CIH are top notch and smart. Work with hazards and help keep folks safe.

I've had several Hygienist trying to do Elevated Blood Lead Level Investigations. They are smart enough to do ... just don't have the license to do it. Just risk assessors can.


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## Steve Richards (Dec 31, 2010)

Very cool.

Thanks a lot for all the information, Dean.


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## Steve Richards (Dec 31, 2010)

You too, Gough


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