All Forum Posts by: Tim Lee

I am looking at a house that has one nasty case of mold. From the initial looks of this, I'm thinking gut the entire inside to the studs and considering dry ice blasting, and then test to get a clearance letter before hanging new drywall, new insulation, flooring, etc. Some of the articles I'm reading seem to point to dry ice blasting as the quickest and surest way of getting it clean enough to get a mold inspection clearance letter and keep it out. I have no idea what this costs. Anyone had experience with it? pros/cons? Costs? This is a 3 bed 2 1/2 bath, split foyer with about 2000 SF in NE TN. This is the first one I've dealt with that requires major remediation so I would appreciate any suggestions. Thanks, Tim

New memo from EPA:

Link to new memo from EPA:
http://www.connorinstitute.com/webdocuments/contentlibrary/public/rrp/EPA_OfficeofEnforcementandComplianceAssurance_06182010.pdf

Brochure to be used by certified renovator to field train workers:
http://www.epa.gov/lead/pubs/steps.pdf

Brochure to be provided to client:
http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf

Bill, Good point. Our instructor pointed this out. When the word came down that lead based paint was to be nixed, many painting contractors, large and small, industrial/commercial/PHA's stocked up on the paint because it was so durable. The key to all of this string is to TRY to get EPA's attention. That only will happen if we load up the comments board identified in my first entry. Go to "http://www.regulations.gov"; click on the tab near the top labeled "submit a comment"; in the drop down window for "select document type' click on 'proposed rules', and then enter the rule no. 'EPA-HQ-OPPT-2005-0049'.

To Chris: I 'think' the owner occupant portion was rescinded effective July 6 (see copy of email from Connor below). That was going to be my 'out' as a rehabber. Not so, according to the instructor. Please correct if I mis-interpreted. Also, How do we get this info to the other forums on BP? The best defense is to bombard EPA with complaints. A; I believe that this was begun back during the first Bush's admin and B, typical of any regulatory agency, they are inept at notifying/educating about upcoming reg's and then expect everyone to comply. I first started hearing about this about 4 months ago, found few sources that knew anything about it and even fewer certification training sources. If you're going to do this, educate and transition please!

Dear Certified Renovators and Interested Parties,

On May 6, 2010, the EPA published changes to the requirements presented during the EPA Certified Renovator (RRP) course. The changes go into effect on July 6, 2010, and Certified Renovators will then need to comply with the new requirements in 40 CFR 745 (the original regulations are found in Appendix A in the CONNOR Course Manual). You may download a copy of the Federal Register in which the changes were published by clicking HERE. Additionally here is a brief summary of the changes that directly impact Certified Renovators:

The “opt-out†clause (page 2-5 in your course manual) has been eliminated. Owners can no longer (July 6, 2010) sign a statement allowing Renovators to perform renovations in the owner’s pre-1978 residence without following lead safe work practices.

The Renovation Firm must now provide a copy of all of the required records to the owner of the residence, as well as notifying the affected units/parents/guardians of where they can obtain a copy of the required records at no cost to the affected units/parents/guardians. Copies of these records must be provided within 30 days of completing the renovation or issuing the final invoice.

The EPA clarified which reports you can accept to determine a property is lead free.

The EPA extended the expiration date of Certified Renovators who took the course prior to April 22, 2010. If you took your course before April 22, 2010, your certificate is now good until July 1, 2015.

As always you should verify this information by personally reviewing the attached documentation. The changes are listed on pages: 24818 and 24819.

As requested EPA’s Renovate Right pamphlets can be obtained at EPARenovateRightPamphlets.com

Additional EPA Certified Renovator (RRP) course offerings are available at EPACertifiedRenovatorClasses.com

I recently completed the EPA Certified Renovator Training. Today, I received the Email below. Now, the EPA is not satisfied with the certified renovator. They now want to add another layer of inspection ($$$, delays, red tape, etc.) Here is your chance to voice your concern. Please pass on to all investors/sub-contractors you know.

Dear Concerned Members of the Renovation Community,

CONNOR has just recently released another communication, so please be aware that we appreciate your patience and attention in receiving this one. However, we believe you will agree with our assessment of the urgent nature of its content, given the deadline for EPA’s acceptance of your feedback.

On May 6, 2010, the EPA proposed several significant changes to the Renovation, Repair and Painting Rule. The EPA is requesting public comment on the proposed changes, and these comments must be received by the EPA on or before July 6, 2010.

This is your opportunity to voice your concerns regarding the additional costs and complexities that the changes will bring to your renovation projects. By providing feedback to the EPA, you can help ensure that the viewpoint of the Renovation Community is taken into account as the EPA decides what changes to enact. Do not allow outside interests to direct your work practices.

There are two major areas that the proposed changes will affect:
1.The EPA is proposing to require Dust Wipe Testing after many renovations.
2.The EPA is proposing a Renovation, Repair, and Painting Program for Public and Commercial Buildings.

Under the first proposal, the EPA would require Dust Wipe Testing in a variety of circumstances, including:
1.Use of a heat gun below 1100° F
2.Removal or Replacement of Window or Door Frames
3.Scraping of 60ft2 or more of painted surface
4.Removal of more than 40ft2 of Trim, Molding, Cabinets or other Fixtures
5.Use of Machines designed to remove paint through high speed operations
6.The Demolition or Removal, through destructive means, of more than 6ft2 of plaster and lath building components

Cleaning Verification would still be required. However, upon successful completion of the Verification Procedure, a Certified Lead Inspector, Certified Lead Risk Assessor, or a Dust Sampling Technician would have to complete a Dust Test Wiping.

Please see the Federal Register/Vol. 75, No 87/ Thursday, May 6, 2010/ Proposed Rules page 25038 for further information on this first proposal.

Under the second Proposal, the EPA is asking for comment on the Development of a Renovation, Repair, and Painting Rule to apply to:
1.Exteriors of Public and Commercial buildings
2.If lead-based paint hazards are determined to exist, Interiors of Public and Commercial buildings

Please see the Federal Register/Vol. 75, No 87/ Thursday, May 6, 2010/ Proposed Rules page 24848 for further information on this second proposal

Comments must be submitted by one of the following three ways:
1.Online at the Federal eRulemaking Portal: http://www.regulations.gov
2.Mail: Document Control Office (7407), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Ave, NW, Washington DC 20460-0001
3.Hand Delivery: OPPT Document Control Office (DCO), EPA East Building, Rm 6428, 1201 Constitution Ave, NW, Washington, DC; Attention _____________ (appropriate Docket Number)

Please ensure that you annotate the appropriate docket number for the proposals on which you are commenting:
1.Dust Wipe Tests— EPA-HQ-OPPT-2005-0049
2.RRP for Public and Commercial Buildings— EPA-HQ-OPPT-2010-0173

For your convenience, EPA’s Renovate Right pamphlets may be obtained from EPARenovateRightPamphlets.com
Additionally, EPA Certified Renovator (RRP) course offerings are available at EPACertifiedRenovatorClasses.com

Thank you,
Rob Dowse
[email protected]
CONNOR Institute

I have a house I'm rehabbing that the exterior is in good shape except the prior owner had a window a/c through the wall right next to the front door. I need to replace 2 pieces of 4'x8' 3/8" thick textured reverse board and batten plywood siding with 12" O.C. 1" wide grooves. Everything I'm finding now is 8" O.C. w/ narrow grooves. I've tried everywhere I can think of and internet search. Does anyone know of a source that still makes this siding. It was common when this house was built back in the 70's. Thanks

I have a house that I'm working on that has an addition on a pier foundation. I'm trying to come up with a way to seal in the foundation perimeter, similar to manufactured housing skirting. I'm trying to find out if you can frame in between the piers with treated lumber, covered with treated plywood, add lathing, and then parge the addition and the rest of the house to blend in. I'm trying to find a quality solution to avoid having to pour a footer and install concrete block to seal the perimeter. Ideas? Will the wood and parging solution meet code? Thanks

Doug, thanks for the quick response on sending me your forms. Good stuff!