Is everyone ready for the new lead testing requirements?

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Door&WindowPlus
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Is everyone ready for the new lead testing requirements?

#1 Post by Door&WindowPlus » Fri Jan 15, 2010 3:56 pm

Our installers will be certified by the end of the month.

Is anyone else going thru the certification process?

TLHWINDOWS
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Re: Is everyone ready for the new lead testing requirements?

#2 Post by TLHWINDOWS » Thu Jan 21, 2010 2:46 pm

Were can I find out more info on this?

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Re: Is everyone ready for the new lead testing requirements?

#3 Post by TLHWINDOWS » Thu Jan 21, 2010 3:03 pm

Nevermind I found it.

I love this:
The rule applies to renovation, repair or painting activities. It does not apply to minor maintenance or repair activities affecting less than six square feet of lead-based paint in a room or less than 20 square feet of lead-based paint on the exterior. Window replacement is not minor maintenance or repair.

I'm not sure I've ever disturbed 6sqf of paint in a basic window replacement.

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Re: Is everyone ready for the new lead testing requirements?

#4 Post by Skydawggy » Thu Jan 21, 2010 3:22 pm

If you remove 2 windows you have disturbed more than 6 sf.

http://www.epa.gov/lead/pubs/rrpfactsheet2008.htm

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Re: Is everyone ready for the new lead testing requirements?

#5 Post by TLHWINDOWS » Thu Jan 21, 2010 4:11 pm

I guess maybe if they are wood windows. We mostly replace aluminum windows here, and on ocassion wood.

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Windows on Washington
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Re: Is everyone ready for the new lead testing requirements?

#6 Post by Windows on Washington » Thu Jan 21, 2010 5:36 pm

As you posted up in your quote...windows are excluded from the minimums and are by default, required to use lead safe practices.

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Re: Is everyone ready for the new lead testing requirements?

#7 Post by TLHWINDOWS » Sat Jan 23, 2010 6:20 pm

Good catch, noted that window installations were not minor but didn't put the two togethor. I've got to decide on how to approach this situation. Classes are far an few between and none in my area so I have to travel.

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Re: Is everyone ready for the new lead testing requirements?

#8 Post by Integra » Tue Jan 26, 2010 12:19 pm

Take the time to watch the webinar. It runs about an hour, but it's well worth it. Here's the URL:

http://kachinaleadpaintsolutions.com/webinar/index.html


I'm concerned that the new lead rules will really hurt the recovery that our industry is experiencing. Essentially, very few contractors are going to want to touch a home built before 1978. If they do, the price will probably be double.

The real concern here - and no one has asked this question is...

Homeowners have been living in these houses for many, many years and being exposed to lead. Now, all of a sudden we as contractors will come in, replace their windows, and siddenly you can bet that we're going to be exposed to litigation because of their exposure to lead.

I just can't believe that our industry just let this legislation pass without a fight. We're on the doorsteps of a nightmare. Mark my words.

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Re: Is everyone ready for the new lead testing requirements?

#9 Post by shamu » Tue Jan 26, 2010 8:02 pm

I tend to agree with Integra, in my area alot of pre-1978 homes are desparately in need of window replacement but are either rentals or in low income areas. The owners, I feel, are not going to want or be able to absorb the extra cost that lead abatement will require. On one hand the gov't is offerring incentives to make homes more energy efficient and on the other they put into affect regulations that ultimately could deter homeowners from doing so.

Another question I have - will casings and stools have to be replaced also? Or will we just be allowed to leave those in place along with the lead paint on them? What about the lead paint that remains on walls, baseboards, door casings/frames etc....

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Re: Is everyone ready for the new lead testing requirements?

#10 Post by Bill » Wed Jan 27, 2010 1:13 pm

You are performing the work using lead safe work practices as taught in the certification program. You are not performing lead abatement, the existing walls and trim with lead paint can remain.

We plan on doing what WOW wrote somewhere, we will be covering the opening with plastic on the inside and doing the removal and install from the outside.

Yes this is additional work but the real expense and headache begins if they require third party testing after completion.

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Re: Is everyone ready for the new lead testing requirements?

#11 Post by shamu » Wed Jan 27, 2010 7:47 pm

Thanks for clarifying Bill.

I still can't quite understand the logic if larger sources of lead are still present after the window replacement. I don't know about anyone else, but when replacing wood sash DH's, I create very little dust or debris as most of my installs are from the outside. I was also told that there will be requirements for proper disposal of any job debris. I need to get on the ball with getting up to speed with the program. My wife says I am a procrastinator.

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Re: Is everyone ready for the new lead testing requirements?

#12 Post by Door&WindowPlus » Thu Jan 28, 2010 2:56 pm

Here is a link to get certified in each state.

http://www.epa.gov/lead/pubs/trainingproviders.htm

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Re: Is everyone ready for the new lead testing requirements?

#13 Post by Door&WindowPlus » Fri Jan 29, 2010 4:23 pm

The fine is not going to be cheap:

up to $32,500 per violation, per day

http://www.remodeling.hw.net/codes-and- ... rival.aspx

The question and answer link is helpful
http://www.remodeling.hw.net/lead-safe- ... afety.aspx

Of the question and answer I found this to be interesting.
REMODELING: Will homeowners, contractors, people in general be encouraged and empowered to report noncompliance?
EPA: Yes. The public will be encouraged to use the lead hotline(1-800-424-LEAD) to report instances of non-compliance. These calls will be followed up by EPA staff.

Here is another one.
REMODELING: Many remodeling contractors believe that the EPA has grossly understated the cost of compliance. They feel that compliance will add much more than $35 per job (EPA’s estimate) when training, equipment, materials, much slower man-hours, paperwork, etc., are included. How did the EPA get that figure of $35 per job, and in what scenarios does the EPA feel that number applies?

EPA: For jobs where lead-based paint is present, EPA has estimated that the costs of containment, cleaning, and cleaning verification will range from $8 to $167 per job, with the exception of exterior jobs where vertical containment would be required. These are incremental costs attributable to the rule.

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. EPA's cost estimates only include the additional steps that those contractors would have to take as a result of the rule.

In addition, in developing the rule, EPA was particularly concerned with having reasonable record-keeping requirements for renovation firms. As a result, the record-keeping requirements specific to the RRP rule are designed to be completed by a typical renovator in 5 minutes or less. EPA believes that the records pertaining to the RRP rule will make up only a small portion of the records renovation contractors typically keep for each renovation job.

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Re: Is everyone ready for the new lead testing requirements?

#14 Post by Integra » Wed Feb 17, 2010 2:06 pm

You can bet that anyone that has gone to all of this hassle and loses a job to someone who hasn't, is going to be ringing the EPA phone line off the hook. Contractors in our area are concerned about losing work to illegal immigrants because they'll just flee the country if they get caught. My concern is that very few contractors and homeowners are even aware of this new rule. I think this is going to get real ugly - real quick.

Whomever came up with the estimates of costs/time really needs to go into rehab.

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Re: Is everyone ready for the new lead testing requirements?

#15 Post by fhi windows » Tue Feb 23, 2010 6:03 pm

I came up with $50 a window extra and $200 per job for stuff like: lead testing sticks, plastic wrap, filters, garbage bags, tape, signs, caution tape, training, jumpsuits, booties and a bunch of other stuff to stay compliant.

If the EPA can show me how it can be done for less I'm all ears :D

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