RRP Lead Rule Schmed-Rule

Okay, so there's this thing called the RRP Rule.

In English, that means the Environmental Protection Agency's  Lead-Based Paint Repair, Renovation and Painting Program.
The EPA has this nifty pamphlet about it.

In short, it's a bunch of rules on how contractors are supposed to deal with paint on pre-1978 houses.
If you own a pre-1978 house you should download the pamphlet and know what the law is.

IF YOU OWN AN OLD HOUSE YOU NEED TO KNOW THE RRP RULES

Here are some important pages for contractors working on painting the exterior of a pre-1978 house.

What Are the Responsibilities of a Certified Firm?
Firms performing renovations must ensure that:

1. All individuals performing activities that disturb painted surfaces on behalf of the firm are either certified renovators or have been trained by a certified renovator.

2. A certified renovator is assigned to each renovation and performs all of the certified renovator responsibilities.

3. All renovations performed by the firm are performed in accordance with the work practice standards of the Lead-Based Paint Renovation, Repair, and Painting Program (see the flowchart on page 9 for details about the work practice standards).

4. Pre-renovation education and lead pamphlet distribution requirements of the Lead-Based Paint Renovation, Repair, and Painting Program are performed.

5. The program’s recordkeeping requirements are met.

Work Practice Requirements Specific to Exterior Renovations
The firm must:

(A) Close all doors and windows within 20 feet of the renovation.

(B) Ensure that doors within the work area that will be used while the job is being performed are covered with plastic sheeting in a manner that allows workers to pass through while confining dust and debris.

(C) Cover the ground with plastic sheeting or other disposable impermeable material extending a minimum of 10 feet beyond the perimeter or a sufficient distance to collect falling paint debris, whichever is greater. If a property line prevents 10 feet of such ground covering, then erect vertical containment or equivalent extra precautions to prevent contamination of adjacent buildings and property.

(D) In situations such as where work areas are in close proximity to other buildings, windy conditions, etc., the renovation firm must take extra precautions in containing the work area, like vertical containment.

(E) After the renovation has been completed, the firm must clean the work area until no dust, debris or residue remains. 
The firm must:
 1. Collect all paint chips and debris, and seal it in a heavy-duty bag.
 2. Remove and dispose of protective sheeting as waste.
 3. Waste transported from renovation activities must be contained to prevent release of dust and debris.

My favorite part:

Why Is Lead Paint Dangerous?

Lead gets into the body when it is swallowed or inhaled. People, especially children, can swallow lead dust as they eat, play, and do other normal hand-to-mouth activities. People may also breathe in lead dust or fumes if they disturb lead-based paint. People who sand, scrape, burn, brush, blast or otherwise disturb lead-based paint risk unsafe exposure to lead.

Lead is especially dangerous to children under 6 years of age.

Lead can affect children’s brains and developing nervous systems, causing:

• Reduced IQ and learning disabilities.

• Behavioral problems.

Even children who appear healthy can have dangerous levels of lead in their bodies.

Lead is also harmful to adults. In adults, low levels of lead can pose many dangers, including:

• High blood pressure and hypertension.

• Pregnant women exposed to lead can transfer lead to their fetus.

How frightening is that?

Now after reading the above I want y'all to take a look at some pictures I took of my across-the-street neighbor's house being prepped for painting.

These pics were taken mid-day on the 17th of June 2013.
I had watched two men work their way around the house scraping off paint.
The workers were wearing t-shirts and pants and no breathing gear. Wonder what OSHA would
say about that?
It looked to me like there were completely done scrapping the paint off the house.

What's missing in these photos?
It was a windy day and the houses on both sides are pretty close.

 Nice old house with paint that is in worse shape than ours..ahem.

 Look at how close the house next door is. Do you see any attempt at keeping the debris contained?

The vac you see on the top left of the stairs. Definitely not a HEPA vac.
Canvas is not allowed as it is permeable. 

 

Here's my fav pic. Look at all those paint chips on a canvas drop cloth.

The back of the house.

 Paint Chips in the Dirt!

Do you think that its a coincidence that the back of the house, which can not been seen from the street, is where all the chips were left to lie in the dirt?

Answer?
Every single fricken' thing that they were supposed to do according to the RRP Rule.

The Plot Thickens
During the entire day this work was going on there was a pretty strong breeze blowing from this house towards mine.
Where our bedroom windows are.. my 4yr old daughter's open bedroom window....
There are also 4 tween kids that live on the property, and one that lives in the grey house next door...which had its windows open.

The owner of the house comes home and I catch him in his car and ask him some sensible questions.   "Did the painting contractors test for lead?"
   "Lead? no I don't think so"
   "Did they talk to you at all about Lead Abatement?"
   "No."
   "Did they give you a lead paint pamphlet?"
   "No."
I talked to the owner about the RRP Rules and he was completely ignorant of them.
Now I am super-pissed off. I print out the page from the EPA RRP handbook about the contractor's responsibilities and give it to the owner.

I'm thinking these guys are trying to take advantage of a nice old couple who are not up on the current rules.
I immediately march home and file a non-anon complaint on the firm with the EPA.

Then, I call the number on the sign and ask to talk with someone in charge.
I get a woman on the line and start telling her what I am seeing and how I know that it is REALLY NOT OKAY.
She says, 'That there was a mix-up and there was not supposed to be any work done there that day. That they had all along planned on doing the RRP work, that the workers just got ahead of schedule.'
I tell her she is full of shit and hang up on her.

I think the owner called the firm also, as very shortly thereafter a 'painting SWAT team' showed up and started some serious scrambling.

SWAT Team In Action

Now they have HEPA vacs and are wearing respirators. You can't tell from this photo, but one of the workers is vacuuming the dirt behind the hedge. It looked like they were vacuuming the entire house and grounds with the HEPA vacs. I'm pretty sure vacuuming the dirt is not an official way to clean lead contaminated soil....

The Plot Gets Thicker
While I was taking the above picture two bigger-than-me-burly guys come across the street to 'talk' to me.
They both look pissed off and angry and they know I'm the guy that finked on them to the FEDS. Honestly, I'm thinking that these guys want to 'pound some sense' into me and I'm starting to steel myself for a fight. I've got my mobile set to call 911 and my finger is hovering over the button.....
They start in on the same B.S. line as the woman on the phone about how it was just a scheduling snafu and that they had meant to comply all along....

I cut them off and go into a rant;
"Stop bullshitting me, I know you never had any intention of doing this. You guys were the lowest bidder and you're trying to make the numbers pencil out by cutting corners with an ignorant client. What's your excuse for not doing all the pre-work requirements? Why does the owner not know a single thing about the RRP rule? You guys are full of crap and I've already reported you to the EPA and I hope to god you get dinged the $36k fine for at least one day!"
Grrr!
Now they are both looking pretty pissed off.
I turn on my heal and head back into my house before one of them can work up the nerve to take a swing at me.

Night Time Fun
The SWAT team works on the house till dark.
Around 9pm we hear some noises coming from across the street.
We peek out the window and this is what we see.

They've come back and are added plastic sheeting to the scaffolding. I'm sure this was there plan all along right?

'Cause, I'm sure it's standard practice from them to bring a small child to a RRP site?

You can just see him on the grass just below the street light. He was running around in and out of the covered part of the scaffolding trying to entertain himself. I'm sure that's safe....
Seriously though, if this ignoring of the RRP rule is standard practice for these guys...it's a good bet that that little boy has been exposed to excessive lead levels from the dust daddy brings home on his clothes after a hard day's work...that sucks.

The Next Morning
These guys were up working at 7am - much, much earlier than I've seen them before.
They are putting up the shade cloth that is supposed to help contain the lead if it's windy.
Note, this is all being done after all the scraping has happened.

Now, I wonder why they are replacing the scaffolding planks too? Hmmm...could they be worried about a visit from OSHA?

It looks like they are done.

Nice giant tear in the thing that's supposed to be keeping the dust contained.

Bunny Suits!

All morning there has been one worker on site. In the correct lead abatement gear: Bunny suit, shoe booties, and a respirator. He has been manically vacuuming everything with a HEPA vac.

Dear Readers (both of you);
Please, please, please, if you see anything like the above happening near you, file an anon complaint to the EPA.
Don't let unscrupulous contractors poison your neighborhood and children.

Please pass this blog post on to whomever you think could use it.

Now it's in the hands of the EPA. I'm going to file another complaint with the web address of this blog. I figure they can't ignore it if it's all over the web.

I think I've presented both sides of the story here. It's up to you, Dear Readers, to make up your own minds about what happened and if you would ever, ever use this firm.


  

We Need A New Roof!!!

And Now For Something Completely Different.

An entire post about roofs!

We've been talking with roofers recently about getting Chez 3.0 re-roofed....

Here's the situation.

The roof on the garage looks totally shot to us and you can even see where the cap shingles have disintegrated....

We've had two roofers come out so far and look at the house and they both said that the garage roof is completely shot. That the roof was most likely a cheapo 20yr 3 tab shingle that got cooked to death by the lack of venting. I have to admit the garages are SUPER freaking hot even when its not really hot outside.

Here's some shots of the roof of our house from space (don't you just love google!)

The West or front side of the house.

I didn't realize our roof line was so asymmetrical.

Do you see on the front of the house on the second floor between the two sets of bay windows what looks like a flat walkway? It's odd it a little flat roof that is tongue and groove!! Like a floor! Here's a pic.

It doesn't appear to be leaking now but wow, how to insure that it lasts a long time and still looks good?

Also, if you look closer at the little roof over the porch on the left hand side of the picture above you see some more interesting issues.

The north side is quite mossy.

The metal drip-rake edge is put on wrong. Its not supposed to be on top!

Here's you can see the built-up layers of roofing against the fish scale shingles. With no flashing in between. If water runs down that wall where's it going to go???

Here's another shot of the porch roof showing the condition of the shingles.

The East or back side of the house.

Looking out the little window in the gable you can see the shed roof. Which looks like this.

You can also see in the above the weird little flat roof the PO put on the house in the lower left corner. They enclosed an exterior stair well.

Here's a shot of the flat roof from the deck.

Here's a shot through the window.

Both roofers who have seen this say that its a piss-poor job and they are surprised that it doesn't leak.

One issue with fixing this roof is how close it comes to the existing window. Figuring out a way to flash this is going to be difficult I bet.

The North side of the house.

The South side of the house.

An odd thing about the south side of the roof. there is this little ledge that is covered in seriously deteriorated metal. Here's a shot of it through the window.

We've met with two roofers so far and have gotten back proposals from each...

Wow, getting this roof done right is going to cost a pretty penny.

I've got one more roofer scheduled to come by and quote the job but so far the two bids are about 10k apart.

The cheaper bid is from an older established roofer using what I think are old fashioned and slightly substandard materials and methods. The higher bid is from a younger guy and he appears to be using modern materials and methods that are more in line with what my research is telling me a quality roofing job should entail.

I told both roofers that I wanted a quality job that would look nice and be in character for the house/neighborhood and would last at least 40yrs.

Even though its more expensive I got a much better vibe from the younger guy. One thing I liked also about the younger guy was he thought the roofs on the house had a couple of years left in them...the garage shingles are dead he said but the house roof wasn't in super horrible shape.

What might possibly happen if we can't swing the roof is we'll band aid the garage roof through another rainy season and hopefully get the entire place re-roofed next spring.

We'll see what the third guy comes up with.

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