I'm writing in response to William Wiehe's letter ("Interpreting the RRP," 4/12) about my earlier Q&A regarding whether the RRP rule applies to situations in which a homeowner does demo work before a remodeling contractor comes to the job ("When the Homeowner Does the Demo," 2/12). I certainly agree with Mr. Wiehe's first point - that if the rule doesn't apply to a job, then firm certification would not be required. However, for this to be the case, there must not be any disturbed painted or coated surfaces within the work area, or the site must have been pretested by a lead-testing professional to confirm the absence of lead-based paint.
Mr. Wiehe also mentions emergency work as an exception to the rule. While it's true that emergency work is excluded from the required work practices, cleaning and cleaning verification are still required after the emergency work has been completed. Therefore a certified firm must do this part of the project and keep documentation.
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