Contractor Gets Caught Violating EPA Lead-Safe RRP Rule

[Ben J. Gromicko]

The Brookline Board of Health visited a project in town and found a contractor violating RRP practices.

The BBOH asked to see the assigned Certified Renovator on site. The company had no CR on site. The workers said the Certified Renovator was available by phone. The town BBOH inspector said the CR has to be on site at all times in Mass. It turns out the contractor has 4 Certified Renovators but not one was on the job. The job was referred to the Division of Occupational Safety (DOS) and the contractor was asked to stop work until a Certified Renovator could be on site and other conditions were met.

Contractors who have not registered their firms or received the RRP training need to think about working on pre 1978 homes without them.

The company above was trained before Mass took over on 7/9/10 and said they did not know that the Certified Renovator had to be on site at all times during RRP work in Mass. They were following the EPA RRP requirement where the CR could leave the site after setting up containment and be available by phone. They claimed that no one told them about the Mass changes.

According to the EPA and DOS it is the responsibility of the Certified Renovator to check with the state to see if there have been any changes to the law.

InterNACHI's EPA-Approved e-Learning Lead-Safe Certified RRP Course
Lead-Safe Certified Classes for Inspectors and Contractors in Colorado
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[Ben J. Gromicko]

Originally Posted by jbushart

...I run across about three of them a week.

Agreed, but one would have to know what a 'non-compliance' issue looks like.

Properly trained property inspectors can act as observers, trained to oversee the lead-safe work practices of contractors.

The homeowner:
1. hires a contractor; then
2. schedules and pays for an inspection to oversee the contractor’s work practices.

The inspector would observe, document and report back to the EPA any compliance issues observed at the renovation work site. The EPA has developed an inspection checklist for this task. www.epa.gov/lead/pubs/samplechecklist.pdf

What can InterNACHI inspectors do?

1. Educate your clients. InterNACHI certified inspectors sit at the breakfast table with new homebuyers, eager to start renovation projects. Educate homebuyers and sellers, and their real estate agents, about the new federal law that protects not only small children, but also our environment. Right to Renovate PDF

2. Get trained. Take InterNACHI’s EPA-approved course at www.nachi.org/lead-safety-rrp-course, or watch NACHI.TV’s training video for inspectors at www.nachi.tv/environmental/lead-safety-renovation-inspection.

3. Keep informed. Read the latest news release by the EPA, and contact its author, Christopher Whitley at whitley.christopher@epa.gov. Inform the EPA that InterNACHI inspectors are willing to be called upon to help educate the American homeowner about lead-safe practices. Latest news: http://yosemite.epa.gov/opa/admpress...25786400606112.

InterNACHI has submitted a proposal to the EPA's Enforcement and Compliance Office. The EPA Office replied that they would respond within 2-3 days (that was April 4th, 2011; waiting...).

[James H. Bushart]

Good idea.

[Ben J. Gromicko]

Originally Posted by jbushart

Good idea.

It's an interesting link. EPA's Enforcement and Compliance Office.
The EPA could create a web-based reporting system for InterNACHI Lead-Safe Certified Inspectors.

The EPA Lead-Safe Certified RRP is a federal environmental law/rule/regulation.