While attending a certification course for EPA’s new Renovation, Repair, and Painting (RRP) Rule, I tried to empathize with contractors that were outraged that the government would “force them out of business” due to the increased costs associated with requirements for notification, certifications, documentation, and environmental controls that would be mandatory with the RRP, which was enacted April 22, 2010 . Understandably, the new lead law, which applies to all residential jobs in homes built prior to 1978, raises concerns that certified contractors could not compete with the bids from the “chuck and a truck” one-man contractors that operate under the radar of building inspectors and state regulators. However, based on the devastating and permanent damage that lead exposure can have on small children and unborn infants, I would have felt much better about the restoration industry if the expressed fears dealt more with being concerned about causing harm.
I am not fully confident that governmental agencies should be regulating professional standards of care. Over the last ten years, the uninformed attempts that many state governments have made to set standards for mold exposures convinced me that politicians should not be allowed to “spin” scientific data for the purpose of getting votes. However, if as professionals, we cannot police our industry, some governmental intervention is necessary to raise awareness and protect the public.
I admit that numerous creative suggestions regarding avoidance of the RRP Rule arose during the class. One contractor suggested that the demolition part of a job for a home built before 1978 would be performed at no costs, while the re-build portion of the proposal would be elevated to cover the “free” demolition. This would supposedly eliminate the need to comply with the lead rule because the law applies to work performed “for compensation. “ Another attendee suggested that we should ban together as an industry and protest to Washington about too much governmental intervention. Too bad the same effort was not spent on trying to figure out how to expedite “doing the right thing”.
The bottom line regarding lead or any other hazards that might be present in the homes where contractors perform any type of repair, renovation, restoration, or remediation is that we have a professional obligation “to do no harm.” Ethically, this mantra should be part of every contractor’s written or implied mission statement. It is in fact, the number one cannon in the Code of Ethics for most professional indoor air quality associations, including the Indoor Air Quality Organization and American Industrial Hygiene Association.
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