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The Occupational Safety and Health Administration (OSHA) has issued the long anticipated new Silica Rule.  Many of us in CA have been complying with many aspects of the rule for the past 8 or ten year already – but there are some new aspects that may make what we have been doing, less than adequate.  For California, Cal/OSHA has about 6 months to come into compliance with this rule.

read more on Osha’s final rule on Silica

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Soil

In this bustling builders economy it’s often necessary to expedite plans in order to keep to a busy timeline, but a common oversight can lead to costly change orders and unexpected delays. Waiting to the last minute to classify soil proposed for excavation and off-haul can be a very expensive mistake if the soil ends up being profiled as hazardous waste. A trained geologist can help identify whether your soil is hazardous or not, and if you’ll need to plan for special transportation as well as proper disposal.

WHAT TO KNOW
In an effort to protect our precious groundwater supply The State of California and the State of California Water Board created strict rules around soil disposal (CCR Title 27, division 2, and CCR Title 23, division 3). A soil report signed by a California-registered Professional Geologist or Professional Engineer is typically required by waste disposal sites prior to accepting contaminated soil.

In order to characterize soil as waste, representative samples must be collected and analyzed by a state-certified laboratory. The number of samples and sampling methodology vary pending the depth and volume of soil proposed for off-haul. In order to adhere to State and Federal regulations, accepting facilities typically require a wide array of laboratory analysesfor purposes of waste profiling.

TYPICAL SOIL WASTE CLASSIFICATIONS AND
MINIMUM CONTAINMENT

Waste Classification, Class I:
Hazardous Waste (per CCR Title 22, Chapter 11), Significant amounts of Hazardous Materials have been found in the soil and pose a water quality threat.

What this means for your project:
Cost for disposal is much higher. There are only two Class I Waste Disposal Sites in California so it’s important to plan ahead, notify the disposal site (they fill up) and prepare for appropriate and safe transportation. There are potential scenarios in which soil waste is considered hazardous by the State of California but non-hazardous in accordance with Federal regulations. In some situations it may be more cost-effective to haul hazardous soil out of state by rail.

Waste Classification, Class II:
Contaminants found in the soil but demonstrate a lower risk to ground water quality than Hazardous Waste

What this means for your project:
Cost for disposal is still higher but significantly less than Hazardous Waste. Proper disposal methods still must be followed and landfill
must have a Class II designation.

Waste Classification, Class III:
Soil does not pose a significant threat to ground water quality so normal disposal steps may be taken

What this means for your project:
Ideal situation. While transportation of soil still must be arranged Non-hazardous Waste is accepted at a reasonable cost and there are variety of Class III landfills within the state. Some Class III soils can be reused off-site, however additional sampling is typically recommended in order to fully assess the usability of the soil and to minimize liability to the generator.

Need help troubleshooting your project?

Our Professional Geologist, Ian Sutherland is available to help navigate through your project needs. Please call 510-638-8400 x 110 or email, isutherland@accenv.com

ACC Environmental Consultants

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Understanding New Phase I ESA Standards: Interview with Julia Siudyla, Staff Geologist

Julia Pict3

When not sailing the seas, Julia provides ACC and our clients with top notch Environmental Services.

What is a Phase I ESA?

In the US a Phase I ESA is a report prepared for a real estate holding that identifies potential or existing environmental contamination liabilities.  An ESA typically addresses both the underlying land as well as the physical improvements to the  property. 

Why is it important to conduct a Phase I ESA?

Bottom line, Environmental Liability Protection – if a Phase I ESA is conducted and existing environmental contamination is identified before a property purchase, liability for existing contamination can be eliminated.      

Who creates the Standards and what’s changed?

The EPA All Appropriate Inquiry (AAI) and ASTM E1527-13 define the Phase I ESA standards.  Recently the ASTM has adjusted their standard: 

ASTM Overview

The American Society for Testing and Materials (ASTM) set out to clarify ambiguous language in the existing ASTM E1527-05 Phase I ESA standard.  On December 30, 2013 the EPA approved the new ASTM Standard 1527-13 making it the new baseline for Phase I Environmental Site Assessments (Phase I ESAs).

What has changed?

The biggest revisions were updates to definitions of Recognized Environmental Conditions (REC) and Historical Recognized Environmental Condition (HREC).  A new term, Controlled Recognized Environmental Condition (CREC), was also added to address scenarios when past releases have been addressed but allow the contamination to remain in place with certain controls.  Additionally, Vapor Migration Screening is now referenced as one of the forms of hazardous substances movement in the subsurface.   See the full updated definitions on our blog:

REC

“The presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment.”

HREC

“A past release of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls (e.g., property use restrictions, AULs, institutional controls, or engineering controls).  Before calling the past release an HREC, the EP must determine whether the past release is a REC at the time the Phase I ESA is conducted (e.g., if there has been a change in the regulatory criteria).  If the EP considers this past release to be a REC at the time the Phase I ESA is conducted, the condition shall be included in the conclusions section of the report as a REC.”

CREC

“A REC resulting from a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority (e.g., as evidenced by the issuance of a NFA letter or equivalent, or meeting risk-based criteria established by regulatory authority), with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls (e.g., property use restrictions, AULs, institutional controls, or engineering controls)… a CREC shall be listed in the Findings Section of the Phase I ESA report, and as a REC in the Conclusions Section of the…report.”

Vapor Migration

Environmental Professionals (EP’s) are now required to assess vapor migration as a form of movement of hazardous substances or petroleum products in the subsurface.  Consultants will use similar assessment guidelines to those related to groundwater migration when identifying if Vapor Migration is connected to a REC.

Who determines what is a CREC versus REC?  

It will be up to the Environmental Professional to make this determination so choosing a detailed oriented firm that upholds strict practices and stays on top of the current standards is key in protecting your Environmental Liability.

How is ACC adapting to the new changes?

ACC has always maintained strict standards when conducting Phase I ESA’s and in anticipation we migrated the revisions into our standards far before they were mandated. 

What can a Geologist do for your company?

Beyond the nitty gritty of looking for contaminants on your property a Project or Professional Geologist can aid you in Risk Assessment and management when looking at long-term development, potential new acquisitions and all environmental property transfer and redevelopment issues.

To receive a Phase I quote or to learn more on how ACC can address your property’s environmental needs, Click here.

Other helpful resources:

Visit ASTM to order the full E1527-13 Standard
Visit the EPA to learn more on EPA AAI
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Keep your Employee and Safety Records Current
By Heather Sobky, Business Development

H_Photo

Tracking employee training, health and safety records, human resource activities to maintain OSHA compliance is a difficult and time consuming process.  Many records are required to be maintained for decades making it easy to lose information and fall out of compliance.  Companies become vulnerable to OSHA fines and citations that can cost an organization thousands of dollars and a health and safety manager their job.

The Solution:


SMART Employee Information Management System

SMART is an easy-to-use management software solution that stores, manages and provides easy access to all of your employee training records, OSHA required employee health and safety records, human resource activities as well as managing and tracking your equipment servicing program.

Benefits

  • Reduces costs by providing quick and easy access to employee training records.
  • Reduces the risk of regulatory fines and citations by managing training records and tracking refresher training.
  • Manages respirator issuance, fit test records, personal protection issuance records, medical surveillance records, exposure monitoring records, and industrial hygiene sample results.
  • Track equipment such as vehicle servicing, equipment inspection, HVAC system maintenance, laboratory equipment servicing and calibration, computer maintenance and produce alerts when service is needed.
For more information on SMART Software contact Heather Sobky, 510-638-8400 x 11
 EcoLogic Systems
ACC Environmental Consultants

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How to avoid exposure

Interview with Tim Falling, COO/Vice President, Mark Sanchez, Vice President and Ian Sutherland, Staff Geologist

 

Caution sign

Q.  What is PCB and what is it used for?

A: Polychlorinated Biphenyls are part of a broad family of man-made organic chemicals known as chlorinated hydrocarbons.  PCBs were manufactured from 1929 until banned in 1979.   PCBs have a range of toxicity and vary in consistency from thin, light-colored liquids to yellow or black waxy solids.

Q.  What are the common products and materials that I may have at my building that still contain PCBs? 

A: Caulking, electrical components, florescent light fixture ballasts, insulated coolant (transformers), as well as many paints can have PCBs.  It also can be found in adhesives or any type of coating.  PCBs are especially present in older buildings (50s through 70s).

Check out the EPA for a complete list of PCB containing materials.

Q.  Do PCB containing materials pose a risk to tenants, employees or vendors that work in the building?  If so, what are the risks and in what circumstances would there be an issue?

A: Yes, one example of a risk is Inhalation and Ingestion Exposure Routes:

PCBs are added to product to help maintain flexibility but these products are subject to wear and will breakdown over time.   If people touch these materials and then eat without washing their hands, they may be exposed.  Dust from renovations, repairs, and maintenance work may contain PCBs and can cause exposure if not properly identified and controlled.

Another is Bio-accumulation:

PCBs move their way up the food chain through accumulation in plants and animals.   When ingested they don’t break down so if you consume food contaminated with PCBs the contamination spreads– in Japan there have been studies linking PCB contaminated fish to human birth defects.

For more information on health effects visit the EPA

Q.  What population is at risk in a commercial building and am I required to notify them of the presence of these materials? 

A: No notification requirements exist yet pertaining to tenants or employees, etc., but, the EPA reviews waste manifests and may question means and methods if they see PCB waste on a manifest.  Currently, the EPA does have guidelines that offer approaches for how to manage PCB’s.  There is a growing awareness among building owners and many are taking a more pro-active approach to identifying and managing PCB waste.  This trend is especially prevalent on the East Coast.  More commercial buildings are electing to test and remove PCBs when testing for other hazardous materials.

Q.  How do I manage PCB exposure in a renovation/ construction/ demolition project if the material is going to be disturbed?

A: First sample materials suspected to contain PCB, if they contain hazardous material establish handing & disposal procedures and then remove it safely.

In a recent demolition project ACC learned a lot about working with the EPA and their direct oversight methods. The building was filled with caulking from the mid-60s that our testing showed contained 50-60,000 parts per million.  Once identified our focus was the complete removal of the caulking as well as impacted concrete in contact with the caulking and ultimately soils near the drip line of the building that were also affected.

There are some defined abatement options in the EPA guidelines.  Although for materials that are going to be recycled there are no guidelines, so, our project team performed a pilot study to ensure our abatement methods met the EPA’s stringent guidelines.

The Abatement Plan

The affected materials coated with PCB containing caulk were both porous (concrete) and non-porous (metal and glass).  the Pilot Study determined that PCB contamination had penetrated up to four inches into the porous concrete in contact with PCB caulking.  ACC, in close consult with the EPA, created a work plan to guide the contractor’s activities that included means and methods to remove the PCB caulk from the materials, cleaning of the non-porous materials and removal of contaminated porous materials to allow for demolition and re-cycling of concrete and metal.

Soil Contamination

Due to the concentrations in the caulking there was a concern that the PCBs ran into the soil and again ACC worked with the EPA to determine remediation goals.  We sampled exposed soils around the building within 1-4 feet out from the foundation and then beneath the surface at varying depths; this resulted in finding PCB concentrations above the EPA established criteria in some locations prompting excavation of the soil to a depth where no contaminate was detected.

Q.  Can any contractor remove or clean up – PCB containing Materials or spills?

A: Cal/OSHA has training requirements (e.g. 40 Hr. HAZWOPER or similar training) to protect workers during the handling of hazardous materials.  Training also includes proper documentation of air sampling and proper tools used, etc….

For more information on Cal/OSHA training visit their website.

Q.  Are there laws and regulations that I should be aware of that require me to discover if I have PCB’s materials at my building for management purposes or for renovation/demolition?

A: There are requirements to identify Hazardous Materials in general.  PCBs are included in those requirements but there aren’t specific regulations yet, only guidelines set by the US EPA, however, once identified you’re required to deal with the material if the concentration is equal to or higher than 50 mg/kg.

PCBs are governed under The Toxic Substance Control Act (TSCA).  TSCA tends to manage a higher level of hazardous material.  It’s important to make sure the people handling the waste and management are familiar with TSCA regulations and guidelines.

http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/laws.htm

Landfills are also beginning to add disclosure of known PCBs into their screening requirements.  So even though there aren’t requirements PCBs are starting to be regulated in other ways.

http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/waste.htm

Q.  If I do find out if I have PCB caulking or other materials that may contain PCB, what am I required to do with them?  In what circumstance would I be required to remove these materials?  Do I need to notify local, state or federal regulators of the presence or possible disturbance of these materials?

A: If the material isn’t being disturbed then it needs to be kept it in a good condition.  So, for example, if it’s an exposed ledge on an exterior of a building, then it needs to be safely contained.

The EPA is currently conducting an effort to broaden awareness of PCB contamination, health effects as well as guidelines in managing the contaminated material.  The biggest focus surrounds schools and maintaining the health and safety of children.

For more on best practices for managing PCB containing materials in schools visit the EPA.

Once PCBs get into soil it isn’t very mobile so it doesn’t migrate too deep but since it doesn’t easily break down it may remain for a long time and potentially cycle between water, air and soil, spreading contamination.

If it’s present in the child’s play area, especially at a shallow level then it is hazardous.

As far as notification, EPA’s requirement is to notify the County and State officials.

It’s important to review workplace risk management procedures for proactive or reactive approach and determine when it is the best time to sample.  Be sure to understand if vendors have waste criteria that require PCB identification.

Q.  Can my in-house maintenance/engineering staff personnel disturb or clean up PCB contamination?  In what circumstance would this be allowed and what training are they required to take?

A: In-house maintenance/ engineering staff would be required to be properly trained on handling and managing the PCB Hazardous Materials.  This training is covered in Cal/OSHA’s HAZWOPER trainings.

Q.  Where and how are PCB wastes disposed of?

A: All waste should be characterized and analyzed before being shipped to the disposal facility to avoid it being returned.

TCSA regulations state that PCB product waste must be disposed of in one of three ways:

Performance-based disposal: this includes, incineration, disposal in TSCA chemical waste landfill, a RCRA hazardous waste landfill.

Disposal in solid waste landfills: certain waste, such as PCB-containing caulk may be disposed in non-hazardous waste landfills permitted by States.  However, EPA recommends that you determine prior to shipment that the landfill is willing and able to accept the PCB waste.

Risk-based option: this allows for a site-specific, risk-based evaluation to determine if waste may be disposed in a manor other than disposal in landfills or performance-based disposal.

For more on waste disposal options, visit http://www.epa.gov.pcbsincaulk/caulkdisposal.htm

Q.  What experience do you have addressing EPA guidelines?  Any key lessons learned?

A: PCB containing material is something that needs to be identified early on in a project.  It’s important to allow plenty of time to deal with the EPA guidelines and develop a strong management plan. It is also imperative to work closely with Labs to make sure they are analyzing as determined by the EPA.

Q.  Are there situations where there may be other hazardous materials present in the same materials that contain PCB?

A: Yes, some examples are, Asbestos, Lead, as well as other metals.  Soils can have pesticides (chlorine containing compounds) that are based on the same chemistry of PCBs so that can interfere with some of the methods used to detect PCBs.

Other helpful resources:

ACC Environmental Consultants

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How To Protect Your Tenants From Smokey Environments

Interview with Jorge Guerrero, CAC, CDPH, Southern California Division ManagerJorge

Jorge is responsible for large client accounts in the Los Angeles office. He has extensive experience managing numerous asbestos, lead, indoor air quality and mold remediation projects.

How do wildfires affect the Indoor Air Quality of my building?

Wildfire smoke is primarily made up of carbon dioxide, water vapor, carbon monoxide, hydrocarbons and particulate matter. Particulate matter is typically the major pollutant of concern from wildfire smoke, as the particulate from smoke tends to be very small. This fine matter are respiratory irritants and in high concentrations can cause persistent coughing, production of phlegm wheezing and physical discomfort in breathing. Persons with compromised respiratory, cardiovascular and immune systems tend to be more seriously affected, triggering asthma, bronchitis, and reduced lung functions.

Secondary concerns are volatile organic compounds (VOC) that are present in the smoke from byproducts of combustion. These compounds, most commonly, acrolein and benzene, are also irritants, which can produce respiratory symptoms as well as other symptoms, such as, stinging or tearing eyes and nausea.

What steps should you take to prevent the outdoor smoke from getting inside?

The immediate response to wildfire smoke and impacts to indoor air quality for buildings and occupants is to minimize the amount of outside air (thus particulate and other compounds of concern) from entering the building, which is done primarily through controlling HVAC systems.

Follow these key steps:

Close fresh air intake and seal with tape and plastic sheeting, until fire situation has stabilized.
Replace all HVAC filters. Install charcoal filters or use charcoal pre-filters, when available.
Install sticky walk-off mats at all egress locations and change them frequently to help control tracking dust from outside.

wildfire

Who is most vulnerable in smoky conditions?

Not everyone who is exposed to wildfire smoke will have health problems. Extent and duration of expsure, age, individual susceptibility and other factors play a significant role in determining whether or not someone will experience smoke-related health problems. However, as indicated in the answer to question #1, persons with compromised respiratory, cardiovascular and immune systems tend to be more seriously affected, triggering asthma, bronchitis and reduced lung functions.

What precautions should be taken/ guidelines should be followed to protect yourself as well as these high-risk individuals?

When air quality warnings are issued by government agencies, the EPA recommends staying indoors and filtering air through an air conditioner, or leaving the area until the fire is suppressed or the winds have shifted. The EPA also recommends wearing a respirator rated for fine particles, but this would require prior medical approval and proper fit testing and training.

Can you give an example of a job that you handled related to this issue? What lessons learned would you pass on?

In 2009, the Los Angeles area was struck by major wildfires that impacted seven properties belonging to one of our clients. At the time, we immediately mobilized to the impacted properties to perform visual inspections for site conditions, which included inspecting the interior and exterior of the buildings for the presence of ash; inspecting the HVAC system (along with the HVAC contractors, to ensure the units were sealed up properly and filters were replaced); and sampling the indoor air for the presence of carbon monoxide, carbon dioxide, VOCs, and particulate matter.

We generated a detailed initial response document for our client, which included specific instructions of activities to follow in order to protect the buildings, prior to and following a wildfire. To the point that the property/ site managers no longer need for us to perform site visits. The property managers simply follow the instruction in the document to ensure their sites remain safe.

For more information on wildfire safety visit:

http://www.epa.gov/naturalevents/wildfires/index.html

ACC Environmental Consultants

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By Heather Sobky, Business Development/EcoLogic Systems Project Manager

Heather Sobky leads ACC’s business development and marketing team and supports ACC’s in-house databases. Additionally, Heather is responsible for EcoLogic Systems sales, customer relations, technical support and product customizations.

Today’s Challenge: Managing asbestos, lead, indoor-air-quality problems and abatement activates is a difficult task. Building owners and managers have numerous notification requirements. Under OSHA regulations, building owners and managers are required to provide tenants, contractors and maintenance personnel with proper notification regarding the location of asbestos containing material in the building. The EPA has enacted numerous regulations designed to protect children from exposure to lead. Many indoor air quality issues can be avoid through proper periodic inspections and preventative maintenance activities.

The Solution: ADAM Environmental Information Management System

  • ADAM manages information regarding the locations of asbestos in a specific building; store and access asbestos survey and sampling data, update remaining locations following abatement activities.
  • ADAM manages information regarding locations of lead-paint, store and access lead-based paint surveys, testing and abatement information.
  • ADAM stores indoor air quality management samples, complaints and corrective actions, tracks system maintenance and periodic inspection activities.

Benefits:

  • Saves time and reduces risk by providing easy access to records and information.
  • Reduces the risk of litigation and citations by helping ensure that hazardous materials are not inadvertently disturbed.
  • Saves time by producing OSHA compliant reports and notifications.
  • Eliminates the need for periodic re-surveys by tracking the remaining locations of asbestos abatement activities.
  • Stores electronic reports and documents, drawings and photographs.

To learn more about ADAM please contact Heather Sobky at (510) 635-7400 x112 or visit www.ecologicsystems.com.

About EcoLogic Systems


EcoLogic Systems is a subsidiary of ACC Environmental Consultants, Inc. The staff of EcoLogic Systems includes experts in the areas of software design and development, as well as environmental health and safety. As a result, we know what information is required to meet regulatory requirements and improve safety. Our goal is to develop software that is powerful, affordable and easy-to-use. Over the past 15 years, our staff has created a wide variety of software applications that are designed for use by Human Resources Managers, Environmental Health and Safety Managers, Asbestos Program Managers, Environmental Consultants and Air Balancing Contractors to save time, reduce costs, improve their environmental health and safety programs and comply with regulatory requirements.

Our software is used worldwide by environmental consulting firms, Fortune 500 companies, school districts, colleges, and public agencies.

Our systems are sold in modules, so our customers only pay for the products they need. In addition, modules can be easily combined into complete employee and environmental data management systems.

ACC Environmental Consultants

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Interview with Justin Graham, Senior Project Manager

Justin is headquartered in ACC’s Southern California Office.  He is a CertifiedAsbestos Consultant and Lead/Paint Inspector/ Risk Assessor, with over 12 years of survey, project and construction management experience.  Mr. Graham is the primary Southern California instructor of our EPA Lead RRP certification courses as well as other training courses offered by ACC.

Who is subject to the EPA – Lead – Based Paint Renovation, Repair and Painting Program Rule?
Anyone who works for compensation in pre-1978 housing and child-occupied facilities, including, but not limited to, painters, general contractors, remodeling contractors, HVAC contractors, etc.

In what type of situations would it be necessary for my contractor to have EPA certification and training?

The RFP rule applies to Target Housing and Child-Occupied Facilities.  Target Housing is defined as any pre-1978 housing.  Exceptions to the definition of Target Housing are:

  • Zero-bedroom dwellings, such as a college dormitory or studio apartment.
  • Housing for the elderly.
  • Housing that has been tested by a California Department of Public Health licensed Inspector/ Risk Assessor and found to be free of lead-based paint.

Definition: Child-Occupied Facility – is a building, or portion of a building, constructed prior to 1978, visited by the same child, 6 years of age or under, on at least 2 different days within any week, provided that each day’s visit lasts at least 3 hours, the combined weekly visit lasts at least 60 hours.  Such facilities may include, but not limited to, day-care, care centers, preschools and kindergarten classrooms.

How does this regulation change the way repair work is done?

The EPA RRP Rule requires anyone performing remodeling, renovation and painting contractors and most other trades who work in pre-1978 housing for compensation and who might disturb painted or coated surfaces to become an EPA Certified Renovator by taking one-day Lead Safe Work Practices RRP class from an EPA accredited training provider.  The class instruction goes over all the rules and regulations pertaining to working in pre-1978 housing and child occupied facilities along with the requirements on how painted/ coated surfaces should be handled.  Students will be advised on not only regulations, but how to properly control the spread of lead dust, proper work area/ containment set up, proper dust control procedures during the conduct of their work and proper clean up when finished and final inspection procedures.

What are the consequences of not being certified in Lead RRP/ hiring an uncertified firm?  Can you provide an example?

EPA may fine contractors/ firms up to $37,000 for non-compliance and both firms and contractors can be found negligent in a court of law.

To learn more on Recent Violations visit,

http://epa.gov/compliance/resources/cases/civil/tsca/lrrprule.html

Do all pre-1978 buildings contain lead-based paint? In what circumstances is abatement necessary?

No.  In fact a majority of the lead-based paints were voluntarily phased out of the housing stock by the 1960’s.  Upon performing hundreds of lead inspections over the years, I have discovered that most housing built between 1960-1978 contains little to no lead-based paint.  A property owner can have a California Department of Public Health Lead Inspector/ Risk Assessor to determine what (if any) lead-based painted components exist.  A property owner should have their properties inspected and tested to determine whether or not they can qualify for exemption in 24 CFR part 35 and 36 CFR part 745 for target housing being leased that is free of lead-based paint, as defined in the  rule.  Even if it turns out that one or two components contain lead-based paint, only those components would need to adhere to the RRP rule if impacted.

Abatement in the form of removal, encapsulation, enclosure or interim maintenance controls are required for any known lead-based paints in a deteriorated conditions that is causing it to chip, flake or peel away from it’s substrate.  Otherwise lead-based paint may remain on a property as long as it is maintained intact.

Do you have additional questions about the EPA RRP Rule? If so, please contact Justin at jgraham@accenv.com or check out the EPA website at http://www.epa.gov/getleadsafe/.