In case you are looking for a reason to celebrate, February 16th, marks the 300th day anniversary that the RRP went into effect. If you happen to live in Alabama, I can pretty much guarantee you, that you are probably livid at this moment, as I will explain in a few minutes. If you are tired of all the paperwork, still laughing at their cost estimates of compliance, and want to left off some steam – well the EPA is ready to oblige you… whether it wants to or not.
EPA RRP Paperwork Reduction – Request for comment:
In a nice twist of fate, the EPA has to certify their “estimates of time required” by allowing for public comments per the Paperwork Reduction Act. They are particularly interested in hearing from Small Business Owners (less than 25 employees) on how to reduce the paperwork burden & these four main criteria:
- Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the Agency, including whether the information will have practical utility.
- Evaluate the accuracy of the Agency’s estimates of the burden of the proposed collection of information, including the validity of the methodology and assumptions used. (3 minutes per job & 4.8 total hours per year per firm it is pretty confusing how they calculated this – it could also read 3 min per pre-renovation form & 4.8 hours of paperwork per job – but then they only list 1 job per firm – somewhere there is a major disconnect)
- Enhance the quality, utility, and clarity of the information to be collected.
- Minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses.
If you would like to comment, the location is on the Regulations.gov site, with the directions, time estimates, and other supporting documentation listed. The public comment period is open until March 28th.
Sweet Home Alabama?
As I mentioned in our December 4th article on a surprising email from the “Alabama Safe State” program about an Alabama RRP Takeover, that there were quite a few issues. Two of the items I mentioned was a lack of official notice to any of the contractors from the AHJ, and besides not having the program ready to roll – is that they did not include any reciprocity, making everyone in the State working on “target” housing a law-breaker.
In an email today to “undisclosed-recipients” from ADPH_Renovation_Contractor_Updates/DPH%ADPH@adph.state.al.us with a subject of: New Renovation Contractor Rule Friendly Reminder; on behalf of;
This is a friendly Reminder!
If You’re Not Lead-Safe Certified, Lead Paint Could Cost You Big Time.
For the convenience of state contractors/renovators and firms, the state of Alabama has received an authorization to run the Renovation, Repair and Painting (RRP) program from the EPA effective Nov. 16, 2010. Firms must now obtain certification (License) from the Alabama Dept. of Public Health instead of the EPA and pay a fee. Firm certification is good for one year and must be renewed annually. Individuals of firms who have taken a one-day training course from an Alabama or EPA-accredited training provider must register with the Safe State of Univ. of Alabama to become an Alabama accredited renovator. The training is good for three years but you must register annually for an Alabama accredited renovator. The firm must have at least one accredited renovator to obtain the Alabama Renovation Contractor Certificate. Mindful of the small added costs that may result from complying with this important rule, the State and EPA has launched an on-going consumer campaign designed to raise awareness of the dangers of lead paint poisoning, and encourage consumers to choose only contractors who are Alabama Lead-Safe Certified.
For additional information including how your firm can get Alabama Lead-Safe Certified and where to find an Alabama-accredited trainer in your area, visit www.adph.org/lead or renovatealabama.com or call 334-271-5881 or 800-421-7141LEAD today.
Well scratch the “no official notice” as I did list email as a valid means in the article above. Unfortunately, the links in the original message were messed up, and I pasted it exactly as received. The valid ones are actually www.adph.org/lead & www.renovatealabama.com. It appears to have generated quite a stir as both sites were down for a good 10 minutes this afternoon.
Seriously, it has nothing to do with supposed kids safety, better ability to promote, enforce, or anything else but our convenience? I guess you are right, it sure was inconvenient worrying about that EPA mandatory class we had to take every 5 years – 3 years is definitely more convenient. Oh cool, we no longer have to worry about checking that training cert in case the date magically changes, because we now have a University to do that for just a low fee of a $100 a year. I must also state how happy I am that I also no longer have to worry about renewing my certified firm certificate every 5 years @ $300 a pop – oh wait, I know have to renew it yearly with you for the same price? Well I guess that “convenience” does have a price. (Amazing how in the first Public Comment meeting the reason was to “protect” contractors from excessive EPA fines)
Well, well they finally posted one, even though it is not part of the Alabama Code – but there is one.
Renovation and sampling technician firms that presently hold an EPA certification will be granted a one-year reciprocity term from the date when the firm was issued certification from EPA.
How nice, a firm that barely just got theirs – has almost a full year to comply, while my firm & numerous others that complied when we were obligated to, have at minimum 2 days to comply (yep – Feb 17 for mine, I saw another 6 days after that)? Oh but wait, it gets better…
However, the firm must submit an application to the Alabama Department of Public Health to preclude any regulatory violations. All rule requirements for renovation project notifications, pre-renovation education requirements, renovation work practices, and record keeping rules still apply.
Seriously, why don’t you pull your collective heads out of the sand, and send all 432 (wow an additional 59 firms have been added in 2 months) “Certified Firms” a cliff note version of the regulation changes includes? (i.e. what a project notification form is & how much each one runs) While you are at it, why don’t you also give a legitimate reciprocity date for everything – say 1 year from when you were authorized to run the program?
Who know’s maybe if you did this, and actually start a legitimate “on-going consumer campaign designed to raise awareness of the dangers of lead paint poisoning” some of us may decide it is worth it, instead of just pulling a “forget about it”, we just won’t work on those houses. Does it really do you any good to penalize the ones that obvously cared enough in the first place to comply, or are you just after some convenient money?