10 days to go – Some praise, some links, and a WTF?

As many of you may recall, less than a month ago the EPA reversed course and finally decided to put the list of certified firms online. At that time, there was only 1806 firms registered, and as of 10 days ago, they had only managed to register 2272. Well it appears they have ramped up their production in this last week and have managed to almost double all the certified firms.

For this, I really have to say – way to go, but please remember that you need to get a lot more of them pushed out quickly. While I already have my certifications and the April 22^nd deadline does not affect me, for many of those firms that you have not entered yet – per you’re regulation, they will simply not be able to work until you get them certified.  

Quick break down of Certified Firms by state:

Some quick links:

Find a Certified Contractor near me
EPA’s LEAD FAQ’s
Title 40 – Part 745 (the actual regulation)

Ok, I know you are not stupid, but this is getting ridiculous:

From their FAQ’s, I found this nice little gem:

How much will it cost contractors to comply with the Renovation, Repair, and Painting (RRP) Rule?

Your answer as of today:

Information collected by EPA for the purposes of the rulemaking indicates that many contractors already follow some of the work practices required by the rule, such as using disposable plastic sheeting to cover floors and objects in the work area.  These estimates do not include the costs of those practices.

EPA estimates that the costs of containment, cleaning, and cleaning verification will range from $8 to $167 per job, with the exception of those exterior jobs where vertical containment would be required.  This includes:
·     Costs of equipment (for example, plastic sheeting, tape, HEPA vacuums and tool shrouds – the equipment varies by job).
·     Costs of labor (for example, the time required to perform cleaning and cleaning verification).

In addition to work practice costs, your costs will include training fees and certification fees.  The costs include:
·     Training costs to individual renovators working in pre-1978 housing or child-occupied facilities who must take a course from an accredited training provider (cost is set by the training provider; estimated to be about $200 for a 5-year certification).
·     Certification costs to firms to obtain certification from EPA ($300 fee to the U.S. Treasury for a 5-year certification.  (This fee is required by law to cover program administration).

First – most contractors are not stupid enough to use plastic sheathing on the floors in dusty or wet conditions. Most contractors utilize re-usable drop clothes, reusable plastic or carpet mats, rosin paper, luan plywood, or semi sticky protective products depending on the conditions. Therefore, with the exception of the last group, you just increased everyone’s prices, while saying it is already accounted for.

Next, you are conveniently leaving out some hard costs like the filters required, the brochures, the new insurance required, the barrier tapes and signage, etc… You also seem to leave out the period of time that the CLR spends informing the homeowner, filling out and filing your required paperwork, and the one-hour’s worth of downtime recommended to allow the dust to settle before daily cleanup procedures should be done. This also does not seem to take in to account OSHA’s requirements as discussed in the series on OSHA and the RRP. Taken directly from OSHA’s own review…  

Compliance with the standard is estimated to add between $300 and $400 to any work on a pre-1978 housing unit to cover the cost of initial monitoring. If lead dust is present above the action level, but below the PEL, compliance is estimated to cost an additional $100 to $900 per job. If exposures are above the PEL, compliance cost per jobs would increase from $500 to $1,800. Costs will vary with the number of LBP jobs done and the length of the job. Costs would be lower for small jobs and higher for those that require more surface preparation.

I find it hilarious that you as an agency, that needs $300 to enter a Certified Firms form into a database and it takes you 90 days to accomplish it, can even fathom what our true costs are. Need I remind you of your initial report which is linked to in this article 67 days and counting… an open letter, where you figured out the costs as being between $22.67 to $527.89 per job without the paperwork or insurance requirements.

Come on; quit doing a disservice to not only the Homeowners that read that but also the contractors that are abiding by your regulations. Isn’t it bad enough that you are fulfilling one of your own major concerns about this program? (another quote from your own review)

 “If the regulation is not accompanied by education efforts and enforcement, then we could unintentionally drive up demand for non-compliant renovation projects.”

I guess no one mentioned to you what happens to the real contractors when give more business to “non-compliant” contractors. You might want to really think about that…

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