Comments on: EPA RRP Proposed Changes: Clearance Testing

By: Jhjervis

Jhjervis — Sun, 25 Jul 2010 20:50:04 +0000

As usual, this is about the half-empty cup. Where to start? First, the Dust Sampling Technician Certification requirement has been lowered to 5 hours of training - and (unless a state has a different requirement and some 7 do) Dust Sampling Technicians can do a clearance test. So, each firm should train one person to be their Sampling Tech. Then pay the $8-$10 fee per test at the certified lab. The real problem (if there is one, and the one that is ignored here) is the requirement to do 3 per room (or a total of no more than 12 in a whole house).

Next: As far as legalities go, there is a wipe test, made by Esca-Tech (get it on certifiedrenovatorsupply.com) that will tell you if an area is clear. So, you don't send in a test that doesn't come back negative. No-brainer. Keep using the D-Wipes until you're clean. Then do the test. Have the owner sign off on the final paperwork (including the test) and any lead found later was there all along or came after you left.

Lastly, if you're doing windows, seal off the interior, do the work from outside and no final clearance is needed, jut visual.

And, let's not forget, clearance testing in this proposal isn't until half-way through 2011. A lot can happen before then.

Tough? Yes, but it is affordable. Look for the way, not just the mountain.

By: SLS Construction

SLS Construction — Sun, 25 Jul 2010 19:21:31 +0000

Sorry, but we do not allow vendors just trying to hawk their goods to leave links. I am quite positive that you guys just love selling more & more items, that do not do one thing o help protect the Homeowners, workers, etc…

As for wiping down an area until it comes back clean, I feel sorry for the contractor trying to do that on certain surfaces, as the EPA specifically points out that it will nearly be impossible to pass those tests unless one uses a special sealer or removes those items.

By: SLS Construction

SLS Construction — Tue, 29 Jun 2010 00:22:48 +0000

Interesting comment about the vacs – nothing changes though based on the language and they are simply stating the same standard over again – the machine must be designed as a HEPA vac (not a shop vac where you can install an aftermarket filter) & the filter must meet their requirments. While the “preamble” talks about keeping records of filter changes & filter testing results – their is nothing in their proposal.

By: RenovatingDeb

RenovatingDeb — Mon, 28 Jun 2010 18:58:51 +0000

The testing and clearance requirements of the new EPA rulings will indeed add extensive costs to even the smallest renovations. These are even of bigger financial import than the training requirements as the proposal also makes it illegal to use most of the HEPA vacs recently purchased for this purpose

A more complete analysis of the revision is posted at http://www.renovatorrules.com The EPA comment period ends July 6th. If you have concerns let the EPA, your US Senator and Congressmen know how you feel.