KBB Collective | The Designers' Corner

Sep 10 2010

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Wiggle room in the EPA RRP lead law? … or only in the brain?

I have taken TWO EPA lead law courses now, and friends and colleagues have taken some, too. The best I can say is that it’s like a game of telephone around a campfire. By the time everyone injects their brand of denial, horror and interpretation, you can ask 100 people about what it all means and get 150 different answers. One of my plumbers the other day said “Oh, that doesn’t apply to me/us (meaning plumbers)” Hmmmm? A heating contractor said the same thing. Others said, “We’re not working on pre-1978 houses anymore.” As I stand there in disbelief, I ask them to explain. That is a huge waste of time! Were we talking about the same law?

As a general contractor, it seems it all falls to me. If I get a job in an 1820s home or any pre-1978 home for that matter, I’m going to stand there and look at it and say, “I’m all alone here.” I got a letter from a lady who read my editorials, and she said two contractors so far have told her, “Look lady, this law is a killer. Therefore, we’ll do your work for you, but NO written contracts … and NO checks.” Nice!!

I still haven’t received my “Firm” certification back from EPA. I’ll bet they cashed my check for $300.00 though. I bought special “DANGER” signs that include: no eating, no drinking, no smoking, no entrance, etc.—$282.00 worth in case I have a huge job with multiple entrances, or two or three going at once. My stupid little stockpile of masks, suits and filters and gloves that cost a thousand dollars will be good for about one day. I think I may buy a couple cases of Depends adult diapers, too—one for the workers so they don’t waste a suit “setup” every time they have to pee, and one for me in case an EPA inspector ever shows up on the job site, or, calls my office about a job I did three years ago, to tell me they’re coming in immediately to look at my records!

If you look up the EPA regional offices, mine—for Connecticut—is in Boston. This makes me think a bit. Did they impose such huge fines, $37,500.00 per violation per day possibly because it will be like an execution if they ever catch somebody, or intentionally go after somebody to make an example of them, destroy them and discourage the rest of the herd from trying to escape the bureaucracy? I have to think that’s the right answer. So, you take in all the varying info, create your own anti-poison plan from your imagination, try to implement it the best you can, and take your chances.

The bottom line is to protect your workers and present and future inhabitants of the buildings we work on from lead exposure. “Control your dust and debris!” they say.


We will all (well, some of us will) try to do our best with the info and our plans, as we always have, scared to death now of screwing up even once. If any lessons came out of this for me, it’s twofold:

1. Lead is dangerous under certain conditions. (Like if you EAT it or breathe its burning fumes)

2. Whenever the government tries to be Big Brother, well, it’s a cluster-you-know-what, and it costs lots of money.

In my humble opinion,

Mark Brady

This entry was posted on Friday, September 10th, 2010 at 6:00 AM and is filed under Business. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.


  1.  ZipWall |

    Thank you for the article, Mark. You make some great points. The Renovation, Repair, and Painting (RRP) regulation went into effect in April, 2010, but some contractors still don’t know about it. Also, as you noted, people interpret the rule in different ways because it is confusing. We have RRP FAQs answered by EPA on our website http://www.zipwall.com/lp/EPAFAQ.html which I think will help contractors understand some of the nuances of the new regulation.

  2.  EPA RRP Certified Renovator, Lead Safe Training Course |

    Protect your family and be sure you only employ a contractor who’s in a Lead-Safe Certified Firm.

    Just be aware that a dwelling has lead-based paint couldn’t tell you if there’s a hazard.

    To cut down your child’s exposure to harmful lead, get your child checked, have your dwelling examined (particularly if your home has paint in poor shape and was made-up before 1978), and fix any hazards you may have.