# Water Recovery



## DeanV

Instead of hijacking the other thread, I thought I would start a new one. I have seen some water recovery systems for collecting water, but they all seem geared towards hard horizontal surface recovery (off of pavement, parking lots, etc). For most homes, you are not going to be able to funnel the water to the driveway only to collect it.

Has anyone actually collected water from power washing yet on one of these projects? I actually landed on exterior project (which given my cynical nature these days tells me I grossly underbid it) and need to start coming up with a system. 

I have a couple ideas, but with the home being stucco I really do not like the idea of nailing boards up to hold plastic in place into stucco.


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## NEPS.US

Dont pressure wash it.


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## ReNt A PaInTeR

Hire a guy from the EPA to do the pressure washing :whistling2:


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## RCP

Haha! 
Dean, i have been checking into this as well, you can spend a lot of time on Youtube looking at fancy setups, but nothing that would work for us.

I was thinking some type of berm system with the plastic and a wet/dry vac to collect the water, then some system to filter to 5 microns. 
Have you checked your state site to see the rules on disposing of the water?
In the EPA Q and A is it vague enough to be open and there really is nothing in the rule.


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## Dean CRCNA

Put plastic down as normal and then use these http://www.absorbentsonline.com/universalpadsrolls.htm up against the house, then throw away.


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## DeanV

I did check with local authorities and I can dump the water if I filter it. If I suspect that surface, chalky paint is lead, I may need to check lead concentrations of the water, but since everything is buried under regular latex, that should not be an issue and separating the chips should be sufficient.

NEPS, would you hand wash? I would think that rinse water from that would still need collection as well?????


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## Workaholic

RCP said:


> Haha!
> Dean, i have been checking into this as well, you can spend a lot of time on Youtube looking at fancy setups, but nothing that would work for us.
> 
> I was thinking some type of berm system with the plastic and a wet/dry vac to collect the water, then some system to filter to 5 microns.
> Have you checked your state site to see the rules on disposing of the water?
> In the EPA Q and A is it vague enough to be open and there really is nothing in the rule.


They have berm barriers and pumps that suck up water into your collection tank that is usually on a trailer. You are right though most everything is geared towards concrete.


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## DeanV

those pads look promising.


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## Workaholic

Dean CRCNA said:


> Put plastic down as normal and then use these http://www.absorbentsonline.com/universalpadsrolls.htm up against the house, then throw away.


Those pads look the part. 
Hire a helper to remove all the soaked pads at the end of a washing. 30"x150' must gain a lot of weight.


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## DeanV

Probably have to cut the wet pads up, wring them out, filter wager and dump


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## Workaholic

DeanV said:


> Probably have to cut the wet pads up, wring them out, filter wager and dump


On-site?

I am sure you would want them cut up anyways to fit in all the little alcoves and to make it a lot easier to pick up and put down. Either way the weight will accumulate. They look the part though, just more crap that has to be set up, removed, cleaned and hauled around. They are also well priced. If you pull the trigger on em let us see em in action.


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## Dean CRCNA

DeanV said:


> Probably have to cut the wet pads up, wring them out, filter wager and dump


What about cut them up and put them in plastic bags and throw away in the trash?

You can also cut them in half length ways. They still would hold a lot of water even cut in half length wise.


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## Workaholic

Dean CRCNA said:


> What about cut them up and put them in plastic bags and throw away in the trash?
> 
> You can also cut them in half length ways. They still would hold a lot of water even cut in half length wise.


That would take away from the reusable factor which is important from my view point.


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## RCP

I don't think you could reuse them, unless you could be sure they were "dust free"?
DeanC, have you used them?


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## Workaholic

RCP said:


> I don't think you could reuse them, unless you could be sure they were "dust free"?
> DeanC, have you used them?


Well then if they are being used as disposable then it would work if it was a once in awhile gig but if it was a semi regular basis I would want something else such as a collection tank on a trailer with a filter in the drain spout.


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## RCP

I had posted a while ago over on a pressure washing forum about RRP and it's effects without a lot of response. I had also PM'd Ken (PressurePros). I went back tonight and asked about filtering/recovering and talked to a PW'er on the phone for a bit.
His method:
Use 25' foot rolls of plastic.
Use 1" strips of cardboard, wrap edge of plastic around and staple/attach to house or use 2 by 4s to secure at base.
Use a homemade sump pump/vac to suck up the water and then use filters.
I invited him here to answer any questions.


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## PatsPainting

Write in your proposal that if they choose you, you will provide a FREE pressure washing.

Pat


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## chrisn

Dean CRCNA said:


> What about cut them up and put them in plastic bags and throw away in the trash?
> 
> You can also cut them in half length ways. They still would hold a lot of water even cut in half length wise.


 
The trash collectors around here will only lift 50 lbs., on a good day.:whistling2:


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## johnpaint

What ever happen to the simple paint job?


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## Burt White

I like the free P W idea. Might work.:thumbup:


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## bikerboy

Why not just skip the pressure wash and scrape sand? You may have more labor, but that equals more $$$$$.

I just don't like the liability of lead contaminated water seeping into the local watershed. Not that it hasn't been done for years, but because now you are liable.

What happens if you did collect every ounce of water, but the neighbors water tests positive for lead. Even if you can prove you collected all of it, can you afford the money it takes to mount a good legal defense? 

If you spend several thousand dollars in both collection, then defense and a subsequent win in court, did you really win? 

Better yet, did you make any money when done?


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## TJ Paint

bikerboy said:


> Why not just skip the pressure wash and scrape sand? You may have more labor, but that equals more $$$$$.
> 
> I just don't like the liability of lead contaminated water seeping into the local watershed. Not that it hasn't been done for years, but because now you are liable.
> 
> What happens if you did collect every ounce of water, but the neighbors water tests positive for lead. Even if you can prove you collected all of it, can you afford the money it takes to mount a good legal defense?
> 
> If you spend several thousand dollars in both collection, then defense and a subsequent win in court, did you really win?
> 
> Better yet, did you make any money when done?


I tend to agree. I really don't think there is anyway to contain 100% of the waste water from pressure washing a exterior structure like a home. You have landscaping barriers, horizontal and vertical surfaces where water will bounce off and scatter. 

Those pads look ok, except that you will have to cut them to fit obstacles and there will be water seeping in between, not to mention they will probably become saturated before completing that side of the house. How many gallons of water goes through the machine for wall? There is no way that 100% will get returned to a filter for "proper" disposal on a typical landscaped house. So if any lead paint is exposed, there may be seepage and contamination, even after all that work and expense. I think the most pragmatic approach using water would be a hose and scrub brush. And even then there could be seepage, unless no water hits the ground.


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## NEPS.US

NEPS.US said:


> Dont pressure wash it.





bikerboy said:


> Why not just skip the pressure wash and scrape sand? You may have more labor, but that equals more $$$$$.
> 
> I just don't like the liability of lead contaminated water seeping into the local watershed. Not that it hasn't been done for years, but because now you are liable.
> 
> What happens if you did collect every ounce of water, but the neighbors water tests positive for lead. Even if you can prove you collected all of it, can you afford the money it takes to mount a good legal defense?
> 
> If you spend several thousand dollars in both collection, then defense and a subsequent win in court, did you really win?
> 
> Better yet, did you make any money when done?


 
My version was just a little more direct. :thumbup:


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## DeanV

That is a lot of extra sanding with HEPA filtration. It probably would not get all the dirt out of every nook and cranny as well as a wash. A light power sand would not be sufficient for mildewed areas.

On this project for example, the house is stucco. Cannot sand that to prep and remove dirt from surface.


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## DeanV

If washed by hand, regular garden hose, etc I would still think water would need to be captured. Agree or disagree?


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## NEPS.US

I dont think so. The surface is not being disturbed.


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## RCP

The pressure washer I talked to said he used 50 gallons on a mid size home.


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## johnthepainter

the pressure washer you talked to???

you probably have a thousand here.

dont feel like you have to leave this forum to talk to pressure washers,,lol.


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## Woody

Use a Hot water blaster..... I would let you use mine, BUT we like hot showers at my house


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## Dean CRCNA

Would a high pressure steam cleaner work? Very little water output.

_still thinking outside the box_


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## RCP

Dean CRCNA said:


> Would a high pressure steam cleaner work? Very little water output.
> 
> _still thinking outside the box_


Never seen one, maybe the "thousands of pwers" will chime in.


I did finally get an answer to my state's law on the disposal.

Basically need to put it in a barrell and taken to the water treatment facility of the job location and do whatever they require!

I doubt we will be doing any exteriors!


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## Woody

RCP said:


> Never seen one, maybe the "thousands of pwers" will chime in.
> 
> 
> I did finally get an answer to my state's law on the disposal.
> 
> Basically need to put it in a barrell and taken to the water treatment facility of the job location and do whatever they require!
> 
> I doubt we will be doing any exteriors!




Any one can paint.... lots of home owners doing there own work...lol

It's $860.00 per 55gal in Ohio....lol


.....wtf


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## Schmidt & Co.

Sham Wow??????


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## VanDamme

Schmidt & Co. said:


> Sham Wow??????


Now that's funny! I don't care who you are!


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## straight_lines

DeanV said:


> If washed by hand, regular garden hose, etc I would still think water would need to be captured. Agree or disagree?


 You could use a busket and a rag. :jester:


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## Richard

*water recovery*

I spoke with my Sherwin Williams rep and here is what he told me.The local trainer advised to use the plastic to chanel the water to a low spot and then to have the hepa vac suck up the water into the top while the drain was open to let the "treated waste water" drain out.I had also thought to use a landscape cloth to catch the paint chips but I was told that I'm still responsible for the soil 18 inches down.Seems to me that after 100 years of weather that there is already a lot of lead in the ground, that I will ultimately be responsible for.


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## TJ Paint

Richard said:


> I spoke with my Sherwin Williams rep and here is what he told me.The local trainer advised to use the plastic to chanel the water to a low spot and then to have the hepa vac suck up the water into the top while the drain was open to let the "treated waste water" drain out.I had also thought to use a landscape cloth to catch the paint chips but I was told that I'm still responsible for the soil 18 inches down.Seems to me that after 100 years of weather that there is already a lot of lead in the ground, that I will ultimately be responsible for.


Sometimes I think that SW or other companies reps are just as ignorant about what it takes to run a painting business as the govt.


Thanks, 

Tim.


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## straight_lines

Richard said:


> I spoke with my Sherwin Williams rep and here is what he told me.The local trainer advised to use the plastic to chanel the water to a low spot and then to have the hepa vac suck up the water into the top while the drain was open to let the "treated waste water" drain out.I had also thought to use a landscape cloth to catch the paint chips but *I was told that I'm still responsible for the soil 18 inches down.Seems to me that after 100 years of weather that there is already a lot of lead in the ground, that I will ultimately be responsible for*.


 That part is bad enough, and I was talking to my SW rep Friday about this very thing. Worse is when some snot nose kid gets sick and they find lead in their system. 

With no way of proving where it came from your insurance will no doubt have to pay out. Unless I am broke and hungry I won't touch an RRP job.


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## PressurePros

I've sat back on this issue and public commenting because I was actually unsure how to approach it. I've found one solution that works for me. I do not wash pre-78 houses. I know that has zero positive affect on this thread and for you guys but it is not feasible to collect the waste water. My machines are 5-10 gpm. We can lay down 500 gallons of water on a property without blinking. My money is in vinyl and stucco. I feel bad for you painters that have no choice but to deal with this issue.


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## vermontpainter

Welcome to the hotel California. Oh wait, we do have the option of not working on pre 78 homes.


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## DeanV

I have been waiting for months to hear your take on this Fenner. On the cleaning boards, I saw some powerwashers say RRP does not apply to them, but I have to disagree based on what I heard in the class.


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## Last Craftsman

Richard said:


> The local trainer advised to use the plastic to chanel the water to a low spot and then to have the hepa vac suck up the water into the top while the drain was open to let the "treated waste water" drain out.


Actually this is a variation on what I think would work best.

All though obviously a hepa vac isn't going to do jack **** to filter the water.

I think if the EPA is going to force us to do this, they need allow us to filter the water onsite, and send the filtered water through sewage system for secondary treatment.

I like the idea of channeling the water then filtering it is good, just so long as the expectations are reasonable and you aren't required to capture every single last little mist particle.

If 2 percent escapes the tarp system, so be it.

Contractors should be allowed to filter 50 gallons of water ON SITE, then dump the rest in the sewer, or even the ground.

I don't know how much charcoal would be required, but I think a gallon of activated charcoal could easily handle 50 gallons of pressure washer water.

Collecting the water, then taking it somewhere else is absurd.

Also, I feel that if the contractor can demonstrate/document that they followed expected RRP procedures, homeowners and other authorities should not be allowed to go fishing around in the soil to come up with lead samples and hold the contractor liable.

Houses with lead paint have been sluffing off paint chips and particles for DECADES before the current contractor came along and did his/her best to do an RRP compliant job.


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## GHPainting

I am still trying to figure out if it's the pressure washer itself that the EPA is against. I for one don't use the pressure washer to blast chips off of houses. We let our bleach/detergent do its trick and just rinse the house off. I asked the teacher of my lead class and he didn't know. I am hoping that the use of regular hoses on sound surfaces is legal. If not, I don't know how the hell to get rid of mold/algae.


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## RCP

RRP does not exclude pressure washing or hoses. It is only concerned with the control of the dust and chips. So you can wash all you want, but you have to control the lead that is in the water. 
If you let that lead paint tainted wastewater go down the drain, it is regulated by your State and local laws apply.


EPA and Pressure Washing


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## DeanV

Looking over some Q&A's from RCP's link, I am looking forward to the day when OSHA requirements and RRP requirements are in contradiction and contractors get to pick which agency they want to fine them (note sarcasm here).


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## RCP

Well, actually, they are getting closer to be the same. OHSA is changing some of the lead rules and most of the recent and proposed RRP changes bring them closer to LSHR and OHSA requirements. Would have been nice if the the three could have gotten together!


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## DeanV

I am still holding out for a slip and fall injury on wet plastic OHSA vs. EPA smack down match in the courts.


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## johnpaint

what is this water recovery you speak of, is it maybe like depends?


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## plainpainter

PressurePros said:


> I've sat back on this issue and public commenting because I was actually unsure how to approach it. I've found one solution that works for me. I do not wash pre-78 houses. I know that has zero positive affect on this thread and for you guys but it is not feasible to collect the waste water. My machines are 5-10 gpm. We can lay down 500 gallons of water on a property without blinking. My money is in vinyl and stucco. I feel bad for you painters that have no choice but to deal with this issue.


I agree. I also think signing up for these courses and getting registered is like signing yourself up on a hit-list to be chased after. This is all about money, not safety, so now they have a list of names - who do you think they are going to chase? All pre-78 homes have contaminated dirt - due to all the neglect and peeling throughout the years {especially the 60's and 70's!} So when they go to test the dirt and find lead, what does that prove, other than the fact you were a fool to try to even play this game?

So goodbye yellow brick road, good by pre-78 homes, where the dogs of society howl, you can't plant me in your penthouse, I'm going back to my plough......


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## straight_lines

You know eventually I will do RRP work, but not with the economy the way it is and so many homeowners on very tight budgets I just don't see it being profitable.

We all know how bad low ballers are out there now, maybe in 5-10 years but now isn't the time.


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## RCP

straight_lines said:


> You know eventually I will do RRP work, but no with the economy the way it is and so many homeowners on very tight budgets I just don't see it being profitable.
> 
> We all know how bad low ballers are out there now, maybe in 5-10 years but no isn't the time.


I wonder when I hear guys say that, does that mean you will not even go look at a pre 78? You are ok with that? Even if it was a job where RRP was a minimal cost?

I know there are guys in my area that have said the same thing, but when they have no work and someone calls, will they really turn it down or take the chance?

Getting Certified will allow you to at least look at those jobs and make a decision on whether or not you want to do the work.

And Plain, yes, you could end up being named in a lawsuit on a lead case because you were on record, it is just one more risk (that can be mitigated) of running your own business. 

I'm not saying everyone should get certified, like Neps says, "Just say No"


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## straight_lines

I am not saying if I was hungry enough I would turn it down. But if I was that hungry things would be a lot different for me, and I would be happy with what I could get I suppose. I am turning down a big chunk of my past income on remodels alone, not counting repaints. However streamlining my business and cutting my work force in half has made things easier on me in reality.

I also feel that if enough contractors get hit on insurance claims that RRP policies are gonna go way up as well. I think these claims have the potential to be outrageous. Of course that is me thinking the worse, its my nature unfortunately.


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## VanDamme

straight_lines said:


> I am not saying if I was hungry enough I would turn it down. But if I was that hungry things would be a lot different for me, and I would be happy with what I could get I suppose. I am turning down a big chunk of my past income on remodels alone, not counting repaints. However streamlining my business and cutting my work force in half has made things easier on me in reality.
> 
> I also feel that if enough contractors get hit on insurance claims that RRP policies are gonna go way up as well. I think these claims have the potential to be outrageous. Of course that is me thinking the worse, its my nature unfortunately.


Bingo! Give that man a biscuit! :notworthy:

It's not the RRP work that scares me. It's not the extra cost to the customer that scares me. It's not even that I get to pay even more money to get certified so I can make a living that scares me.

It's the  fines that scare me!

I look at getting fined for RRP like a traffic cop pulling you over........they can always find SOMETHING wrong. And......if the person is in a really good mood, maybe I will get the fine cut in half to only $19,000 Hell......if I'm really, really lucky, maybe the fine will only be $7,000 LOL!

No fricken' thanks!

I have zero desire to take on that type of risk for a $3-$6,000 job.


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## Dean CRCNA

We now have ...

1. Abatement Contractors
2. Lead Safe Contractors (pre-78)
3. Post 77 Contractors

I think it is perfectly fine for a painting company to stay out of the Lead Safe and abatement work.

If you decide to do Lead Safe or abatement work ... charge for it. If it's not for you ... fine. Less competition.

Abatement companies aren't being sued all over the place and it will be similar for the Lead Safe contractors.

What is dumb (my opinion) is doing Lead Safe or Abatement work and not being certified for it.


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## clammer

Richard said:


> I spoke with my Sherwin Williams rep and here is what he told me.The local trainer advised to use the plastic to chanel the water to a low spot and then to have the hepa vac suck up the water
> 
> 
> hepa =( high efficiency particulate air) Don't suck up water with a hepa vac there made for air.The filters are made mostly from paper and water will ruin it


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## DeanV

Also, the chain together of a non-hepa shop vac followed by a hepa filtered one (I do not remember if it was this thread or another) would not be legal either since the non-hepa vac would violate the rules and not be air tight.


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## bikerboy

By the time 1978 rolled around, most paints and therefore most houses were pretty much lead free. (P/T's Queen can probably provide the numbers) 

You can always test (and charge) for lead and then say no if it comes up positive.


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## johnthepainter

this is a great opportunity to make money.

if you cant stand the heat get out of the kitchen.


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## johnthepainter

RCP said:


> Never seen one, maybe the "thousands of pwers" will chime in.
> 
> 
> I did finally get an answer to my state's law on the disposal.
> 
> Basically need to put it in a barrell and taken to the water treatment facility of the job location and do whatever they require!
> 
> I doubt we will be doing any exteriors!


6516 members, im sure "thousands of pwers" are here. there is life beyond tract homes.


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## RCP

bikerboy said:


> By the time 1978 rolled around, most paints and therefore most houses were pretty much lead free. (P/T's Queen can probably provide the numbers)
> 
> You can always test (and charge) for lead and then say no if it comes up positive.


The paint industry started reducing the lead % and the use of lead paint in the 1960's, it was not banned until 1978.
Percentage of homes likely to contain lead:
Before 1940-87%
1940-1960-69%
1960-1978-24 %
Source- page 5

If you use Google Earth, it has a timeline feature and you can go back to 1978 and see satellite photos of your area. Not all areas are archived though.

I know you know BB, but I just have to remind that you have to be certified to test.



high fibre said:


> 6516 members, im sure "thousands of pwers" are here. there is life beyond tract homes.


:blink:


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## VanDamme

> Abatement companies aren't being sued all over the place and it will be similar for the Lead Safe contractors.


No reason to go after the established companies that know all the ins & outs when you can tag all the noobs that are starting out.

You know, the cops really don't pull you over for a traffic citation to generate revenue even though most tickets are what....$2-$300. 

Just like they won't be citing RRP contractors for revenue generation even though the fine(s) can be as great as $37,000+ Maybe you can tell me why the maximum fine is so damn high? $5,000 would certainly teach you a lesson if you screwed up, but not put you out of bidness or eat you alive with legal fees fighting it.

For the "premium" charged for RRP work versus the risk, no thanks! You can have all the jobs I pass up!


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## straight_lines

Abatement companies charge a small fortune, and I imagine their insurance is pretty hefty as well which was my two points on why I am staying away for now. The profit to risk seems high to me.

I am not just talking civil fines from local/state/fed, those aren't really that bad considering. I am worried about lawsuits when a child gets sick, pregnant homeowner find a birth defect, or some ambulance chaser finds that someones entire property is contaminated after I go there and do a few thousand dollars of work, or in the case of washing a few hundred.


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## VanDamme

> I know you know BB, but I just have to remind that you have to be certified to test.


Chris, Can you expand on this a bit?

If I get a call to look at a job, and the house was built pre-1978, does the law state I can't even use a lead test kit to see if I'm going to accept or turn down the job depending on results?


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## DeanV

Accordingly to the EPA, unless you are certified, you are not able to determine if there is a lead risk or not since you have not been trained by them in how to administer the test and demonstrated the ability to do the test in the class (the only hands on requirement in the class I went to).


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## bikerboy

VanDamme said:


> Chris, Can you expand on this a bit?
> 
> If I get a call to look at a job, and the house was built pre-1978, does the law state I can't even use a lead test kit to see if I'm going to accept or turn down the job depending on results?


The federal goverment in its infinite wisdom has decided you can't tell if the test is positive (the swab turns red) unless you are properly trained. 


RCP: I liked the "Queen" avatar. What did the "kids" chew up in the new avatar?


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## RCP

straight_lines said:


> Abatement companies charge a small fortune, and I imagine their insurance is pretty hefty as well which was my two points on why I am staying away for now. The profit to risk seems high to me.
> 
> I am not just talking civil fines from local/state/fed, those aren't really that bad considering. I am worried about lawsuits when a child gets sick, pregnant homeowner find a birth defect, or some ambulance chaser finds that someones entire property is contaminated after I go there and do a few thousand dollars of work, or in the case of washing a few hundred.


The funny thing is, RRP has no bearing on that. You can still be held liable now for any lead damage done on any property you have ever done, if you get sued and are found negligent. There are several lawsuits that are pre-RRP.
Most of the fines now being levied are because the Renovate Right pamphlet, (required since 12/08) was not signed.
The whole point of RRP is that the industry was ignoring LSP already in place thru OHSA and LSHR.



VanDamme said:


> Chris, Can you expand on this a bit?
> 
> If I get a call to look at a job, and the house was built pre-1978, does the law state I can't even use a lead test kit to see if I'm going to accept or turn down the job depending on results?


Dean is right.

(ii) On or after April 22, 2010, no firm may perform, offer, or claim to perform renovations without certification from EPA under §745.89 in target housing or child-occupied facilities, unless the renovation qualifies for one of the exceptions identified in §745.82(a) or (c).


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## RCP

bikerboy said:


> The federal goverment in its infinite wisdom has decided you can't tell if the test is positive (the swab turns red) unless you are properly trained.
> 
> 
> RCP: I liked the "Queen" avatar. What did the "kids" chew up in the new avatar?


Yeah, crazy huh! But a HO can buy a kit at HD and use a kit we are not allowed to use

That was a special neck pillow, Toby tore it up and enjoyed every minute of it while Zoe sat there and laughed at him! But Toby can do anything, he is Daddy's boy and getting old and spoiled!

And I have always been a Queen!


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## GHPainting

RCP said:


> RRP does not exclude pressure washing or hoses. It is only concerned with the control of the dust and chips. So you can wash all you want, but you have to control the lead that is in the water.
> If you let that lead paint tainted wastewater go down the drain, it is regulated by your State and local laws apply.
> 
> 
> EPA and Pressure Washing


I understand that we have to control the lead chips and lead dust filled water. I often go back and do a very light cleaning on my 4-5 year old paint jobs to keep mildew and dirt at bay. 90% of these are pre 1978 homes. I know (because I did the work) that lead paint or dust is NOT going to end up in my water run off on one of these light cleanings. Do I still need to contain my water run off? If so, that is absolutely ridiculous and is not in line with the intent of this law. Now, I am not dusturbing the paint so the law should not apply. Am I right?


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## PatsPainting

GHPainting said:


> I understand that we have to control the lead chips and lead dust filled water. I often go back and do a very light cleaning on my 4-5 year old paint jobs to keep mildew and dirt at bay. 90% of these are pre 1978 homes. I know (because I did the work) that lead paint or dust is NOT going to end up in my water run off on one of these light cleanings. Do I still need to contain my water run off? If so, that is absolutely ridiculous and is not in line with the intent of this law. Now, I am not dusturbing the paint so the law should not apply. Am I right?



I have yet to see any rules about what would be the minimum PSI from pressure washing has to be in order for these RRP guidelines to go into effect. So I would only assume, if your being compensated and using a garden hose, you should contain the water.

Pat


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## RCP

GHPainting said:


> I understand that we have to control the lead chips and lead dust filled water. I often go back and do a very light cleaning on my 4-5 year old paint jobs to keep mildew and dirt at bay. 90% of these are pre 1978 homes. I know (because I did the work) that lead paint or dust is NOT going to end up in my water run off on one of these light cleanings. Do I still need to contain my water run off? If so, that is absolutely ridiculous and is not in line with the intent of this law. Now, I am not dusturbing the paint so the law should not apply. Am I right?





RRP does not apply if you are not disturbing the paint. But "disturbing the paint" has not clearly been defined. 
From everything I have read, maintenence cleaning, (as opposed to prep washing) is ok.
As far as the runoff in general, that has been and still is regulated by the state's environmental department.


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## DeanV

Remember that the EPA considered pole sanding an interior wall where lead is buried beneath 10 layers of non-lead paint "disturbing lead paint."

Do not make the mistake of assuming they are allowing contractors to use common sense. The law is not written or being interpreted that way.


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## plainpainter

Unless things go back to the 'roaring' '90's. I just don't envision these laws being followed - if anything I think it will spawn more blobs of ooze into picking up a paint brush. Have fun giving some street urchin a 37k fine, they don't exist, they have no siezable assets, no home, no nothing. I may get the license, so I can at least test jobs that I think have a high probability of being free of lead and can allow me to work normally.


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## johnthepainter

just follow rrp and everything will be fine.

control your dust, kids lives are at stake.


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## GHPainting

high fibre said:


> just follow rrp and everything will be fine.
> 
> control your dust, kids lives are at stake.


 
I intend to follow the rules. I have 2 jobs lined up starting in September where I bid the job with using lead Safe Work Practices in mind. I have spent over $2000 so far on new equipment including this vacuum - http://www.industrialvacs.com/Attix_30_8_gal_AS_E_Super_Quiet_Wet_Dry_Vacuum_p/302004230.htm

I am trying to view these new regulations as an opportunity to further separate myself from the other guys. Unfortunately, many aspects of the law are vague at best. Kids lives are *not* at stake when I want to rinse off a perfectly sound exterior surface. Thunderstorms disturb more paint! I am amazed that so many of us (including myself) have no clue about many of these details. My wallet can't afford a fine and I'm not about to start skimping on prep. I have decided to start reading the actual law. That seems to be the only way to cut throught the confusion. I'll check in later if I learn something new...


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## RCP

GHPainting said:


> I intend to follow the rules. I have 2 jobs lined up starting in September where I bid the job with using lead Safe Work Practices in mind. I have spent over $2000 so far on new equipment including this vacuum - http://www.industrialvacs.com/Attix_30_8_gal_AS_E_Super_Quiet_Wet_Dry_Vacuum_p/302004230.htm
> 
> I am trying to view these new regulations as an opportunity to further separate myself from the other guys. Unfortunately, many aspects of the law are vague at best. Kids lives are *not* at stake when I want to rinse off a perfectly sound exterior surface. Thunderstorms disturb more paint! I am amazed that so many of us (including myself) have no clue about many of these details. My wallet can't afford a fine and I'm not about to start skimping on prep. I have decided to start reading the actual law. That seems to be the only way to cut throught the confusion. I'll check in later if I learn something new...


I like your attitude!:thumbsup:
Have you been to the Federal Register? This is the "legal" version of RRP. The EPA website has a lot of good info, especially in the Q and A section, but is not as accurate sometimes. 

As far as the fines, remember, they are up to 37k per day per violation, that does not mean you are going to fined 37k for not following a particular rule. Like OHSA, there are various fines for the severity of violation. From everything I have read, if you are following the rules and are certified, you should be ok. The EPA is focusing more on education than enforcement, and you can see how well that is going!

Make sure your paperwork is in order, take pictures and document your work. Good Luck!


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## GHPainting

Thanks for the link RCP. I am definitely checking it out. :thumbsup:


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## Last Craftsman

DeanV said:


> Do not make the mistake of assuming they are allowing contractors to use common sense. The law is not written or being interpreted that way.



Lol. The day laws are either written, or interpreted with any degree of common sense, is the day that I will be living in a completely different dimension.


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