I was preparing to write an in depth article about additional risk the training requirement delay presents for unwary contractors and property owners. Then I came across an article by Craig Webb at ProSales that covers the subject matter well. I will simply add:
While many are applauding the delayed implementation of the training rule as a win, it is not. In fact it exposes those who are not trained to greater risks. You still must comply with all other portions of the rule, but without benefit of learning what is required of you.
I have this vision of drunk football fans high fiving each as their team scores. Yet, their team is still down by 21 with two minutes and ten seconds remaining in the fourth. Likewise, as some are claiming a victory with the delayed training, they may not want to face the cold hard fact that instead of better, the EPA Renovation, Repair and Painting Rule may just become a whole lot worse due to the pending dust clearance rule.
Also note that the delayed enforcement of the training rules does not affect WI as our program is not run by the EPA. Same applies to IA, KS, MS, NC, OR, RI, UT.
So instead of celebrating – go get trained.
A valid question asked in response to the AASEW’s EPA comments:
Thanks for these comments. You devote a lot of energy to criticizing the rule. Given the health problems caused by lead-based paint, what kind of rule should the EPA write? Let me know, and thanks.
My reply (edited to remove at least a few of my many typos):
The very short version
Everyone who works on older housing should receive lead safe training. Such training could be accomplished in four hours and should be provided at no or low cost to anyone desiring it.
Our association provided this type of training to our members until our state health department required that only lead training course certified by them could be provided in WI.
A more detail explanation with support documents:
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Yes, folks, as we our industry and contracting community are barely getting a grasp on the two month old EPA Renovation, Repair and Painting [RRP] lead paint training and certification rule they want to up the stakes.
The real game changer is the proposal to require laboratory testing for dust clearance at a cost of at least $160 per job, but more realistically $480 for most jobs. This includes jobs as small as fixing a single window frame or broken door jamb.
Comment period to the EPA ends July 6th, 2010.
You can get a copy of the proposed rule, where to submit comments and read the Apartment Association of Southeastern WI, Inc.’s comments to the EPA at:
5-Day Notice, ATCP 134, CCAP, Collections, EPA Renovator Rule, Evictions, Fair Housing, Leases & Rental Agreements, Section 8, Security Deposit, Tenant Responsibilities, Tenant Screening, Utilities
Attorney Tristan Pettit is presenting the Landlord Boot Camp again this February. Prior Boot Camps were very well received, with positive feed back from all that attended
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Owners of pre-1978 properties: It’s going to get much more expensive to make repairs come next April due to the EPA Renovator Rule.
You may have heard the recent Window World ads for their $185 installed vinyl replacement windows. In the ad they warn you to replace your windows now because their price goes up by $100 in April 2010. Why is this?
It’s the new EPA Renovator rule
The rule affects most people who perform maintenance on residential properties, daycares and schools. Contractors performing work on owner occupied homes are also required to comply.
And no, this is not just a painter rule. Property owners, landlords, plumbers,electricians, HVAC, maintenance and handymen all will be affected by the new certification disclosure, documentation and training requirements, too. EPA documentation is at English (PDF)
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