Ken,

    There are new EPA rules regulating work done in pre-1978 structures that bear a closer look as to how they will affect security and integration contractors.  The Federal Register link is: http://www.epa.gov/fedrgstr/EPA-TOX/2008/April/Day-22/t8141.pdf

     According to an article in the newspaper a couple of days ago, the penalty for doing work in target structures without certification amounted to $37,500 per day for each day out of compliance.  I don't know how accurate that is, but it certainly got my attention.

    There are, of course, exemptions...such as disturbing less than 6 square feet of material, but from someone who has tangled with my own state's Department of Environmental Quality in the past, I know that many of the employees of the various regulatory agencies seem to have a God-complex and can make your life miserable.  A couple of years ago, they tried to shut down one of my jobs and threatened to fine me $10,000 per day even though there was no asbestos present in the building, simply because I hadn't paid for a survey to have it checked for asbestos before beginning.  Their rules stated that an asbestos survey was not necessary if less 160 square feet of potentially-asbestos-containing would be disturbed.  I pointed out to them that (assuming I could drill a square hole) I could drill 144 one-inch square holes in one square foot.  Multiply that by 160 square feet, and I would have had to drill 23,040 one-inch-square holes to reach the 160 square foot threshold.  They weren't interested in the math, but they were hell-bent on making an example of me because I had not had them test the site before I began (even though common sense would dictate that a 16-camera job would not require more than 23,040 holes to be drilled).  They eventually dropped the matter after I threatened to call a friend who happens to be a U.S. Congressman, but the point is that the regulatory folks are not to be trifled with.

    The training course for lead-based certification is a one-day (8-hour) course, so it would be foolish NOT to take the course, but I would be interested to hear your thoughts on any problems you see with the new lead-based paint certification requirements.

LH, Ark.

************

Ken,

    Good resources on Legal Issues involving Lead Paint:

http://www.remodeling.hw.net/lead-paint/legal-and-insurance-issues.aspx

Mike Sokoly

***********

Ken-

    Please clarify. I thought I read in your forum that alarm installers were granted an exception to these new lead paint standards. That is drilling a hole in a window sill with lead paint could be a violation. I now understand in NY that a local distributor is offering a 4 hour class that is "mandated for all alarm installers to be in compliance".

Thanks.

James

************  There is no exemption.  Alarm installers need to comply like everyone else.  The real issue is - does your work trigger the application of the statute?  The house needs to be pre 1978 and your work needs to disturb more than 6 square feet