NEW YORK, NY - In early December 2011, a contractor from one of our EPA Lead Renovator Certification classes in New Jersey showed me a letter he received from an Enforcement Officer of the EPA. It was obvious that the letter was causing my student much alarm, and he had every reason to feel this way. The letter was in actuality a Request for Information regarding a renovation he conducted back in July of this year.
Two important points can be taken from this occurrence: First, the EPA has the power to audit a renovation almost six months after the renovation was completed. In fact, they can retroactively audit you for paperwork for up to three years, according to the RRP Rule. Secondly, and the reason why my student was so concerned, the gentleman did not have his RRP certification at the time he completed that renovation in July, breaking the cardinal rule of the construction industry – having all of your certificates/credentials/permits updated and in-line.
It pays in the long run to do things by the book. As our contact from the EPA put it, “it’s better to pay up front,” considering it is the responsibility of the contractor to know the local, state and federal regulations governing the work they are being compensated for. And this most certainly applies to renovations in pre-1978 housing and child-occupied facilities that will disturb lead-based paint, like the job my student conducted back in early July. There is simply no “wiggle-room” when the health and safety of children hang in the balance, as there shouldn’t be.
So as a contractor, what do you need to take from this real-life example?
Submitted by Greg Jaskowiak, Certified Lead Renovator. Greg is a Primary Instructor and Course Developer at Green Education Services specializing in lead safety training.