Our sales volume has allowed us to renegotiate our shipping costs with UPS and subsequently has allowed us to lower small item shipping via the United States Post Office. If our shipping prices have,in the past,  turned you off please try Check4Lead.com again for all of your RRP needs.

If you have any suggestions to improve our checkout process, or if you have any difficulty with the checkout procedure, please feel free to contact us by email or phone. Our customers are the most important part of our business.

Thank You

Art Turman

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Some RRP trainers believe that you should assume there is lead present and simple follow the RRP practices. Here are a few key reasons they give:

1) Lower your cost
2) A cleaner job site
3) A safer jobsite
4) Families will not get poisoned from the worker.

Let’s take it item by item and maybe you should test for lead

1) The added cost of the RRP procedure per project is about 8 to 15 percent. Tell me how the cost of the project is cheaper. see hw.net
2) A clean job site is determined by the work practices required by the contractor.
3) A safer jobsite is also determined by the work practices enforced by the contractor
4) If lead is not present, no lead contamination can be conveyed by the worker

In addition, there are other factors that should be mentioned

1) If a contractor assumes there is lead present and does not test for lead, the home owner does not have an obligation to disclose that his home has lead, which may reduce the market value. Why would one think that a mortgage lender would not also make the assumption the home has lead. I believe the real-estate market will adjust to the new RRP dynamic.
2) Should litigation arise concerning lead prevention, I wonder how that will work out when the contractor assumes lead was present on his project.
3) If a contractor always assumes lead is present, how can he be competitive with contractors that test for lead and only add the rrp procedure cost when necessary?

Art.

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I thought I would give a few more details on D-Lead®. Lately we have had a several questions concerning best practices and how long D-Lead takes for negative and positve results.  My favorite thing about this product is that you can simply drop a sample into the provided cup. Other lead tests really only allow you to test the surface of your sample. The bottom line is D-Lead® Paint Test Kit is EPA Recognized for use on Wood as well as ferrous Metal, Plaster and Drywall surfaces.

With minimal practice, the D-Lead® Paint Test Kit is simple, fast, and easy to use. It takes 1 to 2 samples to acquire the knack of collecting a sample with the provided sample tools. A positive test is usually instantaneous. The test time is the same regardless of the form of lead present and this includes detection of chromate bearing paints. The lower end of the time range (3 minutes) covers most positive tests and includes preparation, sample collection, testing and recording the results.

A positive test result is instant unless one of two events occurs:

(a) The lead layer is covered by substrate collected with the sample, or if

(b) The lead layer is embedded in the middle of several layers.

Now concerning a low or negative result, then you set the sample aside for 10 minutes before taking a final reading. The 3 – 13 minute range is the time frame observed by Battelle Memorial Institute during the independent third party ETV Testing Program.

Regardless of which kit is used the same amount of time is required to clean the sample area, your sample tool, score the paint and recording the results.

Now with Lead Check the instructions say that a test takes 30 – 60 minutes to confirm a negative result.

Lead Check “It is a good idea to reexamine a test site that is suspected to contain lead chromate 30 minutes after the initial test and then 60 minutes after the initial test. If there is still no red or pink coloring, then the negative test result is correct.”

How does one suspect when lead chromate is present? Paint color is not a reliable indicator. There is insufficient data to make the assumption that lead chromate paints were rarely used in residential construction. With the D-Lead® Test one does not need to suspect anything as the test will tell you if any form of lead, including chromate is present in less than 13 minutes

To get the full story from the EPA site go here.

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The EPA has come after companies with deep pockets and published there enforcement action in an effort to frighten contractors into compliance. This sounds like the IRS strategy. Back in October 2010, a video was taken of multiple violations of a repainting project and sent to the EPA for action. No action was taken until May 2011. I have talked to many RRP compliant contractors that are very upset about the uneven enforce by EPA. They will bid a job based on the RRP procedures that must be followed. An illegal contract will come behind them and get the job based on a reduced price without having the expense of the added procedures.

It is only fair that the law should be enforced equally for everyone. The action taken against the Rockland, Maine renovator indicates a start in the direction of level playing field for the contracting industry.

Note: Mark over at http://www.thecontractorcoachingpartnership.com gave me the heads up on the below YouTube video. Thanks mark!

Art Turman

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Before I get started please take a moment to help us stay on top of any fines or audits that you have either heard about or experienced in your area

Who Is At Risk?

You may be subject to an EPA audit if you repair, renovate, or paint structures that were constructed before 1978. The EPA has hired contract auditors to extend their enforcement arm. In addition, the EPA can request your Lead Records Documentation be sent to them without visiting your company-and give you a limited time to respond.

The EPA Will Use Your Records to Evaluate Your Compliance (The EPA’s Secret Weapon)

Record keeping is the low hanging fruit – the EPA says that they will use your records to evaluate your compliance with the RRP law. You are required to keep records for each job and to maintain the records for 3 years. The fines for failure to create and maintain records are about $20,000 per project. In addition, if one of your projects, for one reason or another, should be a part of a lawsuit pertaining to lead, you may be required to produce records for that project.

This Problem Can Be Completely Solved For $49.96

We have the best solution to an aggravating, time consuming, and potentially expensive problem for the very small price $49.95. The LEAD RECORDS ORGANIZER-with simple-to-use forms for every situation and easy step-by-step instructions-will help you to keep lead records in accordance with EPA’s requirements. The LEAD RECORDS ORGANIZER is a complete system that leads you through every step of the RRP record keeping process. If, for any reason, you are not satisfied with the Lead Records Organizer, we will refund your money within 90 days after purchase.

EPA ENFORCEMENT ACTIVITY

• A residential property management company based in South Portland, Maine has agreed to pay $35,426 in fines & penalties. The federal Pre-Renovation Education Rule requires painters, contractors, carpenters, property-management companies and others involved in remodeling or renovation of pre-1978 housing to provide home owners and occupants with an EPA Renovate Right lead hazard information pamphlet. If Window World had used a lead records management system this would have never happened. (See Article)

• College Works Painting has agreed to pay $32,508 in fines & penalties. The federal Pre-Renovation Education Rule requires painters, contractors, carpenters, property-management companies and others involved in remodeling or renovation of pre-1978 housing to provide home owners and occupants with an EPA Renovate Right lead hazard information pamphlet. If Window World had used a lead records management system this would have never happened.(See Article)

• Window World of St. Louis, Inc. has agreed to pay $39,577 in fines & replacement penalties. A $19,529 EPA fine, plus $20,048 to cover the cost of replacing the old windows with lead. If Window World had used a lead records management system this would have never happened.(See Article)

Please Help Us Stay on Top of Any Fines or Audits That you Have either Heard About or Experienced in your Area

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Here at Check4Lead.com we have had many questions concerning when to use D-Lead® or LeadCheck^® and what are the main differences between the two products.  Both have their strengths but the bottom line is that the EPA has only approved D-Lead® for plaster, drywall and ferrous metal. It is also my opinion that D-Lead® is also a bit harder to use. LeadCheck^® is a snap to use everywhere else and the results are relatively clear.

D-Lead®

• Obtain sample with the supplied sampling tool
• Transfer the paint sample to a bottle of test solution 1
• Add 5 drops of test solution 2 to the bottle of test solution 1
• Shake the test bottle for 10 seconds

So if no lead is present you end up with a clear solution. If the sample contains lead you end up with a liquid that has varying degrees of brown. If the solution ends up being darker then the clear brown strip you see on the bottle then you have a sample that is above the allowed lead level and you must follow RRP practices.

LeadCheck®

Now with LeadCheck® you simply crack the two vials in the swab and shake. Then simply rub the swab on the test area and the swab is either red or it’s not.

 

Red means lead.

So the bottom line is that  LeadCheck® is easy to use but it’s not approved for drywall and plaster.  D-Lead® is a little more work but it’s approved for drywall, plaster and ferrous metals.

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Check4lead.com is always striving to be a better advocate for contractors. We recently created an interactive map where contractors could read about and share their experiences with EPA audits.  For our next project we are looking for evidence, personal stories and/or studies that relate to the amount of lead contractors are at risk for on the job. We would also like hard numbers on children that have been exposed to lead during renovations. Since contractors are more often in contact with lead, it is important to understand how lead effects the body. Lead is cumulative in the body, and the more you are exposed to lead the the more likely you are to experience lead related health problems.

Symptoms

Symptoms may be different in adults and children; the main symptoms in adults are headache, abdominal pain, memory loss, kidney failure, male reproductive problems, and weakness, pain, or tingling in the extremities. Early symptoms of lead poisoning in adults are commonly nonspecific and include depression, loss of appetite, intermittent abdominal pain, nausea, diarrhea, constipation, and muscle pain. Other early signs in adults include malaise, fatigue, decreased libido, and problems with sleep.An unusual taste in the mouth and personality changes are also early signs (Wikipedia).

If you have ever experienced any of the symptoms above please get tested.

I also found a study that claims that cognitive function in adulthood may be affected by relatively low lead doses. Your health is more important than money. This statement is very easy for desk jockey such as myself but you can take steps to protect yourself.

If you know of any studies that back my opinion /conclusion please call.

Stay Safe,

Scott Turman

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Written by this months guest blogger,
Mark Paskell
The Contractor Coaching Partnership
“Training immediately followed by implementation ensures that what is paid for and learned in the classroom makes it to the field.”
Mark’s e-mail
Marks blog
The New Sheriff in Town is not the EPA. It’s OSHA

Contractors following EPA RRP Rules must also comply with The OSHA Lead in Construction Standard. The eight hour EPA RRP Initial Certified Renovator curriculum produces EPA Certified Renovators. The training states CR’s are to follow OSHA Lead in Construction Standards and local and state regulations. The 8 hour RRP course does not go over the OSHA requirements. This presents a dilemma for most residential contractors. Contractors in the residential industry have little or no exposure to OSHA training.  OSHA enforcement and training is more prevalent in the commercial construction industry.

There are several conflicts between RRP and correlating OSHA requirements. For example OSHA requires a written compliance program that requires employers to document specific requirements where the EPA requires none. OSHA requires mandatory use of respirators, personal protective equipment and medical monitoring unless the employer proves through air monitoring that the hazard is below the permissible exposure limit (PEL). RRP recommends the optional use of respirators and PPE. Contractors trained on RRP are being set up where they will fail an OSHA inspection.

Note; In Massachusetts Certified Firms are required to have a written medical monitoring respiratory plan in place in order to qualify for a Certified Firm License.  We were told by Massachusetts RRP officials that several states are thinking about modeling their plan after the one in Mass.

Now read on for more good news.

New Sheriff in Town

Last summer there was a new development at OSHA headquarters in Washington D. C. Labor Secretary Hilda L. Solis issued a new directive. This new directive, OSHA Penalty and Fine Structure, changes the emphasis from education first to penalizing and fining first. OSHA believes that long standing education first efforts are woefully insufficient to deter or change contractor behavior.  They stated that the fine structure in place for 30 years needed t be updated. OSHA fines and penalties have been increased.

On September 24^th I attended an OSHA seminar at U Mass Amherst with Shawn McCadden and we heard from OSHA officials that they will fine and penalize first and educate second. OSHA representative Mary Hoye stated inspectors are directed to stop by any work site and look for violations.

Joint Enforcement Between Agencies

Also in attendance at the seminar were representatives from the Massachusetts Division of Occupational Safety (DOS). The DOS is in charge of the RRP Law in Mass. We were told that both OSHA and DOS would be helping each other enforce. If OSHA is on a job and they see RRP violations they would refer them to DOS. If DOS was on a RRP job and they saw a OSHA violation they would refer it to OSHA. Yikes!

Wait there is more…….

New Target Industry ; Residential Construction

We learned that OSHA added the residential construction industry to the targeted industry list. This means for the next 3-5 years OSHA inspectors will be focusing on residential construction jobs. They do not need any reason to stop by and inspect. They are instructed to go up to jobs without notification.

Wait there is more…….

OSHA Fall Protection Directive

On December 16, 2010 OSHA issued a new directive rescinding the fall protection standard form 1995. The new directive requires that contractors have a written fall protection plan in place on or before June 16^th 2011. Essentially any work on residential structure above 6 feet must include fall protection. This directive removes former loop holes in the old standard.

Wait there is more……

Safety Manual

We have been receiving numerous calls from contractors who were just visited by an OSHA inspector looking for safety manuals. All companies are required to have a customized safety manual for their company. Safety manuals need to be put in place with the help of an OSHA expert.

Recap

What does this mean for the residential contractor?

1. EPA RRP Training

2. OSHA Lead in Construction Training

3. OSHA written medical monitoring plan

4. OSHA written respiratory plan

5. Blood lead testing

6. Pulmonary testing

7. Respirator fit testing

8. Personal Protection Equipment Training and purchase of equipment

9. Hazcom training

10. Fall protection training

11. EHS Manual for all residential construction companies…….

12. Meeting with your insurance agent to see if your protected

13. Meeting with your lawyer to review and update your contracts

And they said it was just a program to protect kids under 6 and pregnant women.

Please don’t shoot the messenger………………

Mark the Coach

“one voice for the residential construction industry”

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Release date: 04/12/2011

Contact Information: David Deegan, (617) 918-1017

(Boston, Mass. – April 12, 2011) – A residential property management company based in South Portland, Maine has agreed to pay a penalty of $3,542 and will perform a lead abatement project valued at $31,884 to settle EPA claims that it violated federal lead-based paint disclosure requirements at buildings in Freeport and Portland. These violations potentially put tenants at risk of exposure to lead hazards.

Preservation Management, Inc. provides residential property management services at approximately 70 properties, totaling about 7,000 housing units, in 13 states. The company manages almost 700 pre-1978 housing units in the New England states of Connecticut, Maine and New Hampshire.

According to allegations in a recent agreement, Preservation Management violated the federal Lead Disclosure Rule when it failed to disclose information about lead paint to eight tenants when leasing units at its Lafayette Square apartment building in Portland, and its Maplewood Terrace complex in Freeport. Specifically, Preservation Management failed to provide records or reports regarding lead hazards and to make sure that the lease included a statement disclosing the known or unknown presence of lead-based paint.

In addition, EPA alleged that, also at Lafayette Square, Preservation Management failed to provide a tenant with required information prior to renovation taking place.

In addition to paying the fine, Preservation Management will perform a lead abatement project at Lafayette Square, a 97-unit facility that has significant lead paint in its common areas. Specifically, the project will include removal of the trim from the 14 elevator doors, and removal of the interior trim from the 10 common area hallway windows. All abatement work will be performed in accordance with all applicable laws and regulations.

The Disclosure Rule is meant to give tenants adequate information about the risks associated with lead paint so that they can make informed decisions before signing a lease agreement. Similarly, the federal Pre-Renovation Rule is designed to inform tenants of potential lead hazards prior to renovation taking place.

Infants and young children are especially vulnerable to lead paint exposure, which can cause developmental impairment, reading and learning disabilities, impaired hearing, reduced attention span, hyperactivity and behavioral problems. Adults with high lead levels can suffer difficulties during pregnancy, high blood pressure, nerve disorders, memory problems and muscle and joint pain.

Federal law requires that property owners, property managers and real estate agents leasing or selling housing built before 1978 provide the following information to tenants and buyers: an EPA-approved lead hazard information pamphlet, called Protect Your Family from Lead in Your Home; a lead warning statement; statements disclosing any known lead-based paint and lead-based paint hazards; and copies of all available records or reports regarding lead-based paint and lead-based paint hazards. This information must be provided to tenants and buyers before they enter into leases or purchase and sales agreements. Property owners, property managers and real estate agents equally share responsibility for providing lead disclosure information and must retain copies of records regarding lead disclosures for three years.

Original EPA Article

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(Seattle – April 6, 2011) College Works Painting, a company operating in Oregon, has agreed to pay $32,508 penalty for alleged violations of the federal pre-renovation rule. The U.S. Environmental Protection Agency alleged that the Irvine, California based company violated the federal pre-renovation rule while renovating nine properties in Portland, McMinnville, and Hillsboro, Oregon.

The federal Pre-Renovation Education Rule requires painters, contractors, carpenters, property-management companies and others involved in remodeling or renovation of pre-1978 housing to provide home owners and occupants with an EPA Renovate Right lead hazard information pamphlet. In 1978 lead was banned from paint used for housing.

Read Entire EPA Article…

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