Festool vacs and the EPA RRP (Lead safe work practice)

[Chuck Kiser]

News Flash....

Hey guys I just completed my EPA Lead training class and found out a few things. First the EPA has not, and may not, specify a specific manufacturer for a HEPA vac. I know that the Festool vacs are going thru testing based on talks with Festool. My instructor stated that if you are following the rules and regulations to the best of your ability and using quality tools, it would be very difficult, if not impossible for any inspector to find you at fault.

Bottom line, until the EPA dictates a specific vacume, don't worry about it.

Second, once you use a Festool vac, or any vac for that matter, you will want to dedicate that vac and sander to lead work, and only lead work. No cross contamination allowed. This is really for your safety and that of your family. 

 

[WarnerConstCo.]

Never heard them say anything about keeping a vac just for that and not using it for anything else. 
Nor do I feel like buying another 500 vac.

RRP is completely stupid and may put the final nail in the coffin for many carpenters out there.

I should buy stock in a visqueen  company.

 

[score0matic]

Darcy,  If you are sanding and sucking up lead dust you may want to consider keeping that vac seperate from your family, and regular wood work.    I am speaking from an abatement standpoint but...... the most concentrated dangerious particals  are the dust that gets throught the filter bags and settles inside the vacuum compartment and filter.  If you use your extractor to work wood around a house with kids and forget that the filters are filled with lead dust from last weeks window job.....  You get the idea.  I have a bunch of little kids (at home) and my Cool vacs are the dangerous ones [scared]  The most dangerious, concentrated, breathable lead is in your Vacuum.    and NEVER bang out a dirty (lead) filter out in your front yard

Craig

 

[timcgibbs]

Hi there,

I'm a little worried about the new regulations as well.  In the class I took last month (RRP Certification) the instructor made it clear that only "HEPA vacs are approved - not just vacs with HEPA filters.  So I'm hoping that he was misinformed and Chucks teacher was right. 

We'll see....

 

[WarnerConstCo.]

I understand your point Craig but, it's just lead.
I use lead flashings still, I am sure I ingested more lead
and asbestos then a normal person. Like I said earlier,
this rrp could not have come at a worse time, it's hard
enough to get people to spend 30k on a kitchen gut withou
having to deal with the extra costs of containing lead dust.

The outside stuff is even more ridiculos. I am supposed
to wait untill there is no wind to work outside?

 

[Tim Morris]

I'm signed up to attend soon. How is the class in general? worthwhile? ridiculous? I'm also curious how are they going to enforce who is and isn't certified, especially on work with no building permits involved?

 

[WarnerConstCo.]

I have been using my vac for those kinds of tasks for the last 2 years.
Am I supposed to be scared into quarantining a vac just because I swept up some paint chips or dust that had lead in it?

I am ready for this whole thing but, I think it is another avenue the gov.'t created to let the homeowners sue us contractors for something else.

I am going to start requiring all family members that live in a house I am going to work, have a blood screen done before and after the work is completed.

See, that last sentence is pretty ridiculous huh?  Well so is some of the requirements for me to abide by their rules.  

 

[harry_]

I'm also curious how are they going to enforce who is and isn't certified, especially on work with no building permits involved?

Probably the same way the gov't enforces everything........ selectively, without rhyme or reason.

 

[WarnerConstCo.]

I'm signed up to attend soon. How is the class in general? worthwhile? ridiculous? I'm also curious how are they going to enforce who is and isn't certified, especially on work with no building permits involved?

They really have no idea how they are going to enforce the general residential remodeling.
The EPA says they will be hiring people with the money they collect from businesses registering.

Too bad only about 10% have done it by now.

They are supposed to be doing some sort of mass public campaign to bring it to everyone's attention.  Gee its almost april and I have yet to really see anything about it on tv or in print form.

They said they are relying on home owners to keep tabs on it and report it that way.
Too bad so many people are cheap and won't be willing to pay the extra it will cost for hiring a legitimate contractor.

Is there a head up arse smiley?

 

[Chris Hughes]

The EPA can kiss my aess!!!  I hope all my brother carpenters see this for what it is.  I have not been to this class and I will not be going to this class at any cost.  The EPA without any warning or consultation with our industry conger-ed a set of rules that are at best difficult but I would argue impossible to comply with.

If this allowed to stand with enforcement we will be put out of business quickly, but that's not the tragedy, the real shame is all of the standing housing stock that will fall into disrepair.  Who wrote this law do you think?  I would guess someone from our industry helped, but do you think it was anyone from a remodeling back ground?  I'm guessing no, in fact I would guess it was someone from the new housing industry.

Eitherway, I will not comply, I will not pay the fine, and I will fight this in court and in the mean time I hope all of you will contact your Congressmen and women regarding this injustice.

 

[Holzhacker]

I looked into taking the class last year and decided against it. Mainly because a Corp client was thinking of requiring it and then decided not to. I spoke to other contractors and inspectors around here and found there has been little call for it. After 2-3 decades of ongoing rehab around here I'm not sure how much could even be left in homes around here. Obviously in other areas of the country it could be a completely different story.
On the one hand this regulation is long overdue. We were discussing lead paint concerns on jobsites 20 years ago. On the other hand it seems a little goofy that it is finally happening. My guess is there will be some additional info/regulations or taxation that will come down the pipe related to this in coming years.
Granted everyone's body is different and I realize that people have gotten sick but if it were as bad as some would like to make it out to be, I would be long dead. BTW how's that lead water main working for you?
Maybe if the work volume exists in your area and you advertise as a specialist, one could dedicate tools specifically for this task. For the average contractor I don't see isolating such expensive tools for this task only as being feasible.
These Regs will obviously affect any rehab work that has government funding (which so much does these days). The discreet, non permitted, non english speaking work will keep dumping anything into the neighbors trash bin.

 

[Chris Hughes]

My local town hired two enforcement officers with stimulus money.  The new inspectors are former contractors.

 

[WarnerConstCo.]

The lead pipe water supply on my end of town is still working great.

Like I said, another avenue for us to get sued.
My insurance agent has no idea what to do with my policy.
He looked into an abatement rider but that jumped my premiums from about 1500 bucks to 6k.
I told him I was all right.

 

[Tim Morris]

He looked into an abatement rider but that jumped my premiums from about 1500 bucks to 6k.
I told him I was all right.
[/quote]
The bad thing is once the insurance industry realizes the requirements the government has put on us, and sees the potential for exposure/lawsuits, "I'm alright" isn't goint to cut it. It will be a mandatory rider, probably at a higher rate because of the realized exposure potential. All this is doing is brining the subject back into the public eye. The problem has been there for years and never really been a problem. This will just give homeowners another thing to scrutinize when something goes wrong on a project. BTW I want to talk to your insurance agent I pay 13K a year. [eek]

 

[harry_]

I want to talk to your insurance agent I pay 13K a year.

You must have some worker's comp in there. My liability runs about $800 to $1000 per year....

 

[WarnerConstCo.]

It's just me so I don't have comp.

My premium is getting near 1500 a year, because of these darn tools I keep buying and insuring.

 

[harry_]

Yeah, I have to have the comp because I do a lot of subcontracting... my prime's insurers require it.

 

[Tim Morris]

Unfortunately comp is correct. Plus a couple of work trailers, skid loader, 2000 sf cabinet shop, I think my insurance man loves me. I think I'm sending his kids to college. [unsure]

 

[harry_]

Tim,

Yeah. Now the price of your insurance makes perfect sense.

I think my insurance man loves me. I think I'm sending his kids to college.

He does, and at the very least you are buying their books

 

[Wonderwino]

The really insidious thing about RRP is to the minor landlord, such as myself.  I have one residential rental, a pre-1978 house that I collect $250/month on.  I have to take a $300 course 250 miles away, so that means a day and night on the road, + about $200.  If I provide the paint or let the tenant paint and deduct the cost of the paint from the rent, I still have to be certified, get a receipt for the pamplet, swab, keep records for 3 years (for now) and supervise the work.  The alternative is to let the property deteriorate, eventually demolishing it and taking it off the tax roles. 

If the EPA starts a big publicity campaign and tenants pay attention, they could turn in non-compliant landlords, perhaps getting a "commission" on the $32,500/day fine for non-compliance.