A Carpenter’s Journal

July 15, 2010

EPA Certification Arrives

Filed under: Codes and Regulations — Tags: — Fran Maloney @ 6:08 pm

Heritage Construction Company received its official EPA certification in the mail yesterday.   It is valid within ” all epa administered states, tribes and territories” and it is signed by Chief, (yes chief),  Michelle Price.  It comes with a certification number.  There is a warning that I must only advertise myself as certified for purposes of section 402 of TSCA and an expiration date of July 23, 2015.   And there is a notice that I can display the EPA Lead Safe Certified Firms logo which must have my certification number on it.

We got our framing inspection today on the screen porch.

May 29, 2010

More on EPA RRP Rule

Filed under: Codes and Regulations — Tags: , — Fran Maloney @ 9:31 pm

I attended an all day training session in Woburn today put on by the Environmental Training Institute which is affiliated with the University of Cincinnati.    This class met the requirements to become an EPA certified renovator.  I should be receiving an official copy of the certification in the mail.  I will still need to register with the EPA  and pay a $300 fee.

It turns out that the real mover behind the new lead containment rules for renovators is not the EPA itself but an alliance of public interest groups including the Sierra Club which successfully sued the EPA to implement rules passed by Congress back in 1992.  Again, I am not sure yet of the extent or seriousness of the health hazard addressed by this rule.  The amount of remodeling on pre 1978 homes that has gone on since 1978 is astronomical and most of it has been done with little or no concern for lead contaminated dust.

The new rules require that any work done on a house built prior to 1978 where a child could conceivably live and any building visited by a child under 6 for more than 2 days a week, 3 hours a day must be tested for lead.   Any areas that are positive for lead paint that are to be disturbed by the renovation have to be done in a strictly prescribed manner designed to contain and remove the lead dust produced and, this work needs to be done under the supervision of  an EPA certified renovator.

I am not  sure how this is going to play out in the industry, in part because I am not sure how the EPA will enforce it.   It is rather quick and easy to change a window, especially to install a replacement window, so what is going to stop people from hiring a carpenter to do it without a permit and without the certification especially if it is going to save them $50 or more per window?    Home Depot and Lowes are having all their remodeling sub contractors get certified and I am sure they will pressure town and federal officials to make sure that the competition does the same.  Once their contractors are all certified, there will be a major public relations push by these companies to scare people away from uncertified independent contractors.   Insurance companies also may get into the act if they are possibly liable for children having elevated blood lead levels.  Also the state will inevitably get involved or even actually assume control of  administration and enforcement.  But, right now, being certified and following the rules is a major competitive disadvantage.

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