Comments on: EPA RRP Updates – The New Record Keeping Requirement

By: SLS Construction

SLS Construction — Wed, 23 Jun 2010 21:22:34 +0000

First Shawn, it was nice talking to you for once, as compared to us simply typing responses back and forth. For everyone else, here is a quick synopsis of the article above...

While the EPA believes that they mandated this new record keeping requirement apply to all pre78 jobs (located in the pre-amble), they obviously do not know how to write a regulation.

Per the regulation, they only require the additional form to be handed out when a third party dust clearance exam is done (745.86 D), or when a CLR uses the Lead Check swabs & a component tests positive (745.86 C).

As I mentioned in the article, in both the cases listed above it is mandatory for the form to be given out. For all other jobs, I do not see it being necessary, but I will gladly give them a copy if requested.

By: Shawn McCadden

Shawn McCadden — Wed, 23 Jun 2010 18:38:25 +0000

Sean:

I am confused regarding what you are trying to point out and or suggest here. Can you summerize or give me a call?

By: Remodel Crazy

Remodel Crazy — Sat, 12 Jun 2010 02:34:39 +0000

RT @SLSConstruction Posted late last night… EPA #RRP Updates – The New Record Keeping Requirement — http://tinyurl.com/32su56q

By: Christopher Wright

Christopher Wright — Sat, 12 Jun 2010 02:32:31 +0000