We knew our company would be ready for April 22, the date the EPA’s Renovation, Repair and Painting (RRP) rule took effect. But would our trade contractors? If they didn’t comply with all requirements, we as general contractor could be liable for fines of up to $37,500 per violation per day.
Moreover, would our clients be ready for the added costs and time associated with RRP compliance?
Here are some steps we took.
First and foremost, we as a company got the training and certifications the rule requires. My safety manager and I took the training and became EPA-Certified Renovators in January ($450 total). We mailed EPA our firm certification application ($300), and when the certificate arrived nearly two months later, we immediately copied and laminated it for posting at all jobsites in homes built before 1978.
We talked with our insurance company to see if we would be protected under the RRP. We also researched the materials we would need to comply (i.e., test kits, protective gear, HEPA vacuum, etc.).
With our trade contractors, we must accommodate the RRP’s requirement that a Certified Renovator (CR) train all non-certified workers on a pre-1978 jobsite, including staff and subs. In addition, a CR must be on hand at the start of the job to ensure proper setup and signage, and at the end to make sure the site is properly cleaned.
This leaves us with three options on pre-1978 homes. One: My safety manager or I, as CRs, can do all the prep work, testing, oversight, and cleanup that the RRP requires. Two: We CRs train our trade contractors in lead-safe practices, essentially by way of an in-depth tool talk. Or three: Each trade contractor designates a CR to oversee the company’s work at any time.
On notifying the public and clients, our e-newsletter explained the RRP (in April). We are explaining it orally in discussions about pricing and schedules. And we are considering itemizing direct hard costs with the growing list of non-negotiable charges we must pass on — not just RRP compliance, but also surveys, permits, new code costs, etc.
—Andy Hannan is production manager of Mark IV Builders, in Bethesda, Md.