Seven Debates of RRP

In the 12 months since RRP has been in effect, I've noted seven areas of discussion that have emerged. 1. RRP is still in flux.  As evidenced by changing rules and regulations, the instability of RRP has most of the contractors who are willing to comply, still confused.  If they were trained early on in the RRP process, they could be behind in the most up-to-date directives on how to conduct proper RRP (i.e. opt-out provision). 2. RRP is being largely ignored.  From comments I've received from contractors and renovators, I sense that there are a number of homeowners who are contracting with non-lead-safe certified contractors purely based on cost.  I have also heard from contractors who are just flat out refusing to work on pre-1978 residences.  I would not be surprised if some contractors are acting as if the opt-out is still in effect. 3. Contractors are still waiting for a "stay of execution on appeal."  As each story of a lawsuit, letter, or group action hits the media, it seems to serve as defacto permission to wait while the industry appeals the decision. 4. Records are the least understood aspect, raising the most questions. I continue to have contractors ask questions about record-keeping.  Our webinar last month drew tremendous interest and many questions about record-keeping.  If you missed our webinar, you can access it here from our home page/archives. 5. Fines for failure to properly notify residents of target housing is the primary enforcement threat.  Over the last few weeks, has published news accounts of contractors receiving EPA fines for non-compliance with the notification requirements.  The distribution of "Renovate Right" is such an easy step to complete.  You can even provide it in an email, as we described in one of our December issue. 6. EPA seems understaffed, and is making the conscientious effort to turn this program over to any state that will take it on.  There are now 11 states that have obtained EPA authorization and are implementing their own RRP program.  For more information and links to the state information, visit the EPA lead-safe site and to "EPA Authorized State Programs." 7.  The industry is missing a positive result test.  Even though the industry is still striving to have a test process that will prove the positive presence of lead, the EPA is wanting to demand higher standards of clearance testing, matching those tests of HUD and OSHA.