Working on Buildings Where a Child Occupied Facility Exists

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Several renovators seeking clarification about the EPA RRP Rule have asked me about working on buildings where a child occupied facility occupies part of the building, but not the entire building.  The most common example they ask about is a church.  The following question and answer are from the FAQ page of the EPA Web site.  Although not mentioned in EPA's answer, I suggest that play areas outside of the building would also be considered common areas where the required containment procedures and work practices would be required.

Question Posted to EPA Web Site: If a building contains a child-occupied facility, must all renovations in the building follow the RRP Rule?

EPA Answer: Not necessarily.  "Child-occupied facility'' means a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days within any week (Sunday through Saturday period), provided that each day's visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours.  Child-occupied facilities may include, but are not limited to, day care centers, preschools and kindergarten classrooms.  Child-occupied facilities may be located in target housing or in public or commercial buildings.

With respect to common areas in public or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only those common areas that are routinely used by children under age 6, such as restrooms and cafeterias.  Common areas that children under age 6 only pass through, such as hallways, stairways, and garages are not included.  In addition, with respect to exteriors of public or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only the exterior sides of the building that are immediately adjacent to the child-occupied facility or the common areas routinely used by children under age 6.

Areas of a building that fall outside this definition are not "child-occupied facilities" for purposes of the RRP rule.