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The RRP Training: a Debriefing
This past Friday, I took the EPA’s Lead: Renovation, Repair, and Painting course and became a Certified Renovator. As owner of a remodeling company, incoming president of the Eastern Massachusetts NARI chapter, and your humble blogger, I feel obligated to report my parting impressions and my personal plan of action.
To summarize: At the very least, the course taught me what I need to do to keep my nose clean and avoid fines. Over the short term, my task within my own company will be to assess where I am willing to risk fines while simultaneously containing lead dust, keeping my crew motivated and safe, and keeping my dumpsters from being 35% filled with plastic sheeting and "disposable coveralls.”
I've been taking some crap lately for pitching the lead law as a potential boost for market share and/or sales. Taking this crap only makes me more confident that I'm right. Because if you think it will hurt your sales, it will.
First Words: High Time, and No Big Deal
First, I agree in concept that something significant needs to be done to force our industry to protect homeowners who hire us. We didn't take the initiative to protect them from lead exposure, so the EPA did.
Second, the certification process is easy…maybe too easy. While most of the complaining about the law isn’t about certification itself, I feel compelled to address those of you who object to the mere concept of having to get certified: See what it takes to become a licensed hairdresser. Gain some perspective.
Third, the lead-containment practices taught in the course – were I to implement all of them – would not significantly increase my job costs. Obviously, the smaller the job, the larger percentage increase there would be, but I can't see my average job costs increasing by even 1%.
Conflicts and Clarity, Overkill and Oversight
As for the quality of the training and the intent and clarity of the law, I do have some issues. A better trainer might be able to clarify some of my remaining gray areas.
Purely objectively, I know that my company's current dust control practices are better than those taught by the RRP course. The course never mentions negative air pressures in the workspace. I will be upgrading my company's exhaust fans to HEPA filtered fans, but I will not be following the EPA's practice of closing all windows; I need an open window for exhaust.
I am pretty darned sure that there is a conflict between RRP and OSHA over the practice of covering floors with plastic sheeting, especially when workers are required to put disposable booties over their feet. My classmates used the term "ice rink" over and over during our hands-on (and booties-on) training.
I learned that workers "should" wear disposable coveralls, a painter’s hat, booties, gloves, and a respirator. I also learned that lead is not absorbed, but rather inhaled and ingested orally. The argument for disposable clothing is not so much for the protection of workers as for their families, via the spread of lead. A study in Maine (cited in the class) traced the source of three children’s lead poisoning to their fathers' vehicles.
While this is a serious concern, I will be searching for other means of addressing this risk while minimizing disposable stuff and maximizing my crew's comfort, safety, and efficiency. When I asked my instructor whether I'd be subject to a $32,500 fine if I considered and rejected the recommendation that my crew "should" wear disposable clothing, he gave one of many non-definitive answers. I see this as my biggest implementation hurdle. I seriously think people will leave the trades if required to wear "disposable coveralls" through the summer.
As I'm writing this, I realized that the only clothing that was not disposable during the hands-on portion of my training was the gloves…..seemingly the most lead dust-covered item. Hmmmm.
Landfill Ironies, Green Setbacks
My biggest concern, and the thing I find the most ironic, is that the practices mandated by the "Environmental Protection" Agency's regulations will cause an enormous increase in the amount of polyethylene sent to our landfills. To bag and/or wrap and tape every bit of waste for the trip from the workspace to the landfill is to overemphasize the means instead of the end result.
When I asked my instructor whether these were “recommended” practices or mandated practices (with a $32,500 fine if violated), I got two different answers. As I see it, these bagging/wrapping/taping means, if practiced, would result in major step backward in the green remodeling movement.
Just the use of plastic and duct tape used in conducting the trainings is worthy of an environmental impact study. I salvaged two 10-x-20-foot, perfectly clean and uncut sheets from the trash after my training. This was about a third of the total used in the course – and it will soon appear on a jobsite near Boston.
Wish List and Commitment
Personally, I would like the training to include a bit more education about the issue of lead poisoning. I believe that the majority of my classmates ended the day without any philosophical shift about the need for better lead containment. This is a huge lost opportunity. At the very least, anyone who takes this class should “graduate” better-equipped with the knowledge to sell lead-safe remodeling.
As a final thought, I am choosing to view the current law as a "first draft.” I intend to be a more active participant in the ensuing dialog with EPA and whoever the enforcers happen to be. I believe the intent of the RRP is spot-on. We need to play a more proactive and positive role in achieving the goals of lead containment without sacrificing worker safety, environmental sustainability, and economic viability for our remodeling brethren.
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