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On Lead, Abdication May Not Be an Option
Shawn McCadden
I just took a full-day training class to become a Certified Renovator according to the EPA’s Lead: Renovation, Repair and Painting law. I am so glad I did. The class was presented by Rob Dowse of The Connor Institute. Rob was well informed, offered practical advice and compliance methods, and did a great job keeping the discussion on focus.
If you own a remodeling business, you’d better take an RRP class too, as soon as possible. Do not abdicate this responsibility. There is too much at stake to risk not being adequately informed about how the new regulations will affect your entire business. April may seem like a long way off, but once you realize what you need to do to get ready, you might wish you had more time.
A Short, Serious List
Here’s my short list of what you and your business will need to consider and/or plan for before you consider working on homes that were built before 1978:
- As a general governing philosophy, decide if you want to continue to do renovations on homes that require you to comply with the regulations – that is, on any home that was built before 1978!
- Register your business as a “firm” under the regulations before you perform the work. The EPA says the turnaround time for this will be 90 days from the time you submit your paperwork. Keep in mind that those are “government days,” and consider adding a safety margin.
- Calculate whether you’ll need to make staff additions or changes to comply with the law. For every applicable job, you’ll need a Certified Renovator to supervise. And you’ll still need to meet your production volume requirements!
- Have each Certified Renovator on your staff train those working under him or her and keep records of all the skills that have been trained. Know that all RRP work must be supervised unless the person performing it has been trained in those specific tasks. They will need classroom as well as on-the job training experience. Do this training before the ruling takes effect on April 22nd.
- In your estimating, change your assumptions about the labor and material-related costs associated with any lead-related work. If you have a backlog of work, make sure the work you plan to start and/or complete after April 22nd is priced appropriately to cover your additional compliance costs.
- Re-evaluate and revise your business systems. All of the following will need to change: your production scheduling methods, how your jobs are supervised (including how often a certified individual will need to be on-site), how to ensure that your subcontractors are also registered firms (and have certified employees), your sales process, and how you explain things to prospects.
- Accept that compliance will means a lot of paperwork and documentation for each project. Complying with paperwork requirements will significantly increase your overhead costs, particularly if your business is technology-challenged and will depend on paper, file cabinets, and employee oversight to manage. You will need to complete, deliver, collect, and store the required paperwork in an accurate and timely manner.
- Be serious about complying with all of the regulations. A lackadaisical approach can expose you and your business to the risk of fines of up to $32,500 per violation: per job, per individual requirement, and/or per employee.
The $32,500 Killer
Remember that I said this was my short list. There is plenty more to consider about the lead law. In this tough economic environment, one $32,500 fine might put you out of business. Get educated now and start making plans to do the work within the regulations.
Or, start planning for how you will make up for the lost volume if you choose to stop working in pre-1978 housing.
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