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Your Interactive Resource for EPA RRP Information

RRPedia logoLooking for accurate information about the EPA RRP rule?

RRPedia has been created by Shawn McCadden to help remodelers and others affected by the New EPA Renovation Repair and Painting Rule. 

Please read RRPedia Use and Contribution Information before using or contributing to RRPedia.

 


You Can Browse For RRP Topics By Using The Tags List To The Right

Refresher: RRP Rule Interior Containment General Requirements

Posted by Shawn McCadden on Wed, May 16, 2012 @ 06:00 AM

RRP Training Refresher: RRP Rule Interior Containment General Requirements

RRPedia Refresher Key

 

It’s probably been a while since you took your RRP Certified Renovator Training Class.  This blog post is offered as a refresher topic to help you keep important details about the RRP rule top of mind when selling, estimating or performing RRP renovations.

 

RRP Rule Interior Containment General Requirements:

  • RRP SignsPosted signs: These must be posted on all sides of the work area to define the work area, must be in the primary language of occupants, must be posted before the beginning of the renovation, and must remain until cleaning verification is achieved.
  • Contain the work area: Before renovation, isolate the work area to prevent the escape of dust. During work, maintain the containment integrity and ensure that containment does not interfere with occupant and worker egress from the home or work area.
  • RRP Containment for furnatureRemove or cover furniture/objects: Remove (preferred) objects like furniture, rugs, window coverings; or cover them with plastic sheeting with all seams and edges taped.
  • Cover floors: Cover floors including carpets in the work area with taped down plastic sheeting or other impermeable material to 6 feet beyond the perimeter of surfaces undergoing renovation or to a distance sufficient to contain dust, whichever is greater.  Remember, if vertical containment is used floor containment measures may stop at the edge of the vertical containment.
  • Close windows, close and seal doors: Close windows, close and seal doors in the work area with plastic sheeting or other impermeable material. Doors used as entrances to the work area must be covered with plastic sheeting that allows workers to pass through while confining dust to the work area.
  • RRP Containment for duct openingCover duct opening: Close and cover all HVAC vents in the work area with taped down plastic sheeting or other impermeable materials (e.g., magnetic covers).
  • Remove dust and debris from everything leaving the work area: Use precautions to ensure that all personnel, tools and all other items are free from dust and debris before being removed from the work area.

 

Topics: Production Considerations, EPA RRP for Dummies, RRP for Dummies, Work Practices, Signage, Refresher Information

Guest Blog: New Understandings About The Required RRP Work Practices

Posted by Shawn McCadden on Tue, Mar 20, 2012 @ 05:00 AM

Making RRP Easier - New Understandings About RRP Work Practices

 

Dean Lovvorn, lead inspector

 

 

Guest Blogger:  Dean Lovvorn is a residential remodeler who has done numerous RRP projects.  He is also a Lead Inspector, Lead Risk Assessor and EPA RRP Renovator Instructor. 

This blog post is a follow-up to a previous RRPedia Guest Blog where Dean listed several differences between the work practices taught in the required Certified Renovator class and what he found is actually required in the RRP rule.

 

Making RRP Easier - New Understandings About RRP Work Practices

RRP ideas

 

 

Back in April 2010, I had an exterior remodeling job that was put on hold for a day because of heavy rains.  In my boredom, I decided to read the actual RRP law from start to finish.  I soon discovered that what I was taught in my 8 hour class and what was in the student manual wasn’t necessarily in the actual law itself.     

 

I was probably dozing off in the 8 hour renovator class, but after these discoveries, I began to clarify some new understandings.

  • On exterior containment set-ups, all I really needed to do was put plastic on the ground, be sure windows & doors were closed, cover any doors within 20 feet with plastic and put out a warning sign.  If there are no doors and/or windows within 20 feet, simply put plastic on the ground and a warning sign up.  Nothing else needed.
  • On interior containment set-ups, I just needed to do the same as the exterior (except 6 feet out from where I was working).  If there were no furniture/objects or ducts within the 6 foot area … I didn’t have to go any further.  Be sure to tape down the plastic on the floor.

Of course, if I was doing some really dusty work, I made the containment (work area) larger, but other than that, it was pretty quick, easy and simple if you were to ask me.

 

Following are some examples of how reading the actual law has helped me.

Siding Replacement

RRP Vertical containmentIn this example, I would place 3.5 mil plastic (from Home Depot), instead of the 6 mil plastic 10 feet out on the ground.  Then, I would make sure doors/windows were closed, put plastic over any doors and then put up the warning sign.  I would also run a plastic runner out to the dumpster and surround the ground around the dumpster with plastic.  Doing the containment this way, saves me from having to wrap, bag or HEPA vac the siding (or myself).  This is because I can dump the siding without ever going outside the containment area.

If exterior vertical containment is needed a simple solution (pictured to right) can be done.

Replacing Door Slabs

If my job is to replace 15 door slabs, I simply do this without following RRP.  This is because the only area I am disturbing on each door is the hinge area and since it falls under the Minor Repair and Maintenance Activities, RRP is not required.  This insight came from the FAQ section of the EPA web site.

Bathroom Remodel (Total Gut)

RRP Work Area Containment for a BathroomI can demo the tile, tub, shower, toilet and remove the demolition debris without doing any RRP.  After that has been done, I cover up ducts with plastic,  make sure windows are closed, close doors and cover with plastic, put up a warning sign and then cover the subfloor with plastic (6 feet out from where I will be working). 

I put the demoed walls, cabinets and trim into trash cans (with lids on top) and HEPA vac the outside of the trash cans (along with myself) before taking them out of the containment area.

Note:  If I’m lucky and there is an exit door (to the outside) close by … I could run plastic to the door, then outside to the dumpster.  This way, I wouldn’t need to worry about containing the demolition debris.

Normally, I do the final clean-up, visual inspection and cleaning verification after demolition; so that I can officially end RRP and let non-certified electricians/plumbers/sub-contractors into the work area.

 

Conclusion

Selling RRPIt very well could be that if you did a little homework by reading the actual law, you could reduce the cost of compliance on many jobs to less than 5%.  Few contractors will lose a job because they are higher by less than 5%.  Plus, with the cost less than 5%, I don’t even mention RRP to my clients during the estimation process anymore, which has helped to improve sales. 

 

Topics: Production Considerations, EPA RRP for Dummies, Containment Considerations, Subcontractor Considerations, Sales Considerations, Compliance Options, Work Practices, Opinions from Renovators, Guest Blogs

Guest Blog: The RRP Training Suggests More Than The Rule Requires

Posted by Shawn McCadden on Fri, Mar 16, 2012 @ 05:00 AM

Guest Blog: Making RRP Easier – The RRP Training Suggests Doing Way More Than The Rule Requires

Dean Lovvorn

 

 

 

Guest Blogger: Dean Lovvorn is a residential remodeler who has done numerous RRP projects.  He is also a Lead Inspector, Lead Risk Assessor and EPA RRP Renovator Instructor.

 

Making RRP Easier – The RRP Training Suggests Doing Way More Than The Rule Requires

RRP work Practices

 

Back in April 2010, I had an exterior remodeling job that was put on hold for a day because of heavy rains.  In my boredom, I decided to read the actual RRP law from start to finish.  Honestly, it was like watching paint dry (incredibly boring). 

However, as I continued reading, I soon discovered that what I was taught in my 8 hour class and what was in the student manual wasn’t necessarily in the actual law itself.

 

 

My Discoveries - In the actual law I found:


  1. RRP RespiratorThere was no mention of having to wear disposable suits, dust mask, booties or headwear. (Still might need to comply with OSHA)
  2. That I didn’t have to put construction debris in a heavy duty plastic bag.  I had to at final clean-up, but not when taking out demolition debris.
  3. There was no requirement to put plastic over windows.
  4. That there was no mention of putting yellow warning tape at 20 feet out on exterior jobs.
  5. That on many jobs, the only paperwork required was a signed receipt of the Renovate Right booklet and completing the record keeping checklist.  This takes me about 5 minutes to do.
  6. Homeowners ignoring RRP RuleIt didn’t say I had to use 6 mil plastic, which made me happy since the 3.5 mil plastic sold at Home Depot cost less.
  7. I didn’t have to mention (if I didn’t want to) anything about RRP during my sales presentations or while giving estimates.  This was especially helpful, because clients don’t want to hear about being lead poisoned … they want to hear about their beautiful renovation.

Watch for Dean's next guest blog where he describes the work practices he now uses to make RRP easier at the job site


Topics: Production Considerations, EPA RRP for Dummies, Certified Renovator Training, Containment Considerations, Compliance Options, Work Practices, Opinions from Renovators, Guest Blogs

Information, Resources and Instructions About Working Lead-Safe

Posted by Shawn McCadden on Tue, Feb 28, 2012 @ 05:00 AM

Information, Resources and Instructions About Working Lead-Safe

Lead safe linksThe following is a partial list of links you can use to find information, resources and instructions for working lead safe.  This information can be used by renovators, landlords, tenants and homeowners.  I suggest checking them out.  I found many good work practices, ideas and options to consider that were not offered or discussed in the required Certified Renovator Training class.  Renovators may also find some of the documents valuable to share with prospects and clients when discussing pre-1978 renovations and or if the prospect is considering doing all or part of the work themselves.

 

If you know of other links to value information worth sharing please leave a comment at the end of this blog and I will add them to the list below.

 

Lead safe work practicesLinks to Information,Resources and Instructions About Working Lead-Safe

A Guide to working safely with residential lead paint

Field Guide for Painting, Home Maintenance and Renovation Work

How to Safely Change a Lead Contaminated HEPA Vac Bag

OSHA standards for cleaning a respirator apply to EPA RRP work

What do I need to know about Respirators when doing EPA RRP work?

What You Don’t Know About Respirators and Probably Would Rather Not Know

Restricted Practices and Prohibited Practices under the EPA RRP Rule

RRP Demo and Asbestos Removal Share Similar Risks and Work Practices

A Fast, Clean and Safe Way to Remove Lead Paint

How to Safely Use a HEPA Vacuum and Change a Contaminated Bag

 

Topics: Production Considerations, Compliance Options, Work Practices, Info for Landlords

RRP HEPA Vac Options That Meet EPA Requirements

Posted by Shawn McCadden on Tue, Feb 07, 2012 @ 06:00 AM

RRP HEPA Vac Options That Meet EPA Requirements

The following information comes from the EPA RRP Info page of my web site.   It is included at the end of an article titled “Choosing The Proper Commercial/Industrial HEPA Vacuum Cleaner”, written by Barry Cohen, the owner at Absolute Air Cleaners, Air Purifiers, & Allergy Products

DRRP HEPA Vacisclaimer: This post is shared for informational purposes only.  I have no experience or any financial arrangement with these companies. 

These links were suggested by others in the industry as options to consider when searching for a HEPA vac.  Feel free to suggest additional sources and or suppliers of HEPA vacs to include on RRPedia.  If you are a renovator doing RRP work feel free to post a comment about your experience with a HEPA vac.

If you are a HEPA vac manufacturer and you would like me to try out and review your product feel free to contact me.   

Festool

All current Festool CT Dust Extractor models have been independently tested and certified to be FULL UNIT HEPA Dust Extractors. When you purchase a new Festool CT Dust Extractor, regardless of model, you will find a printed certificate in the box as well as labeling on the dust extractor documenting its Full Unit HEPA certification.

Nikro Industries Inc.

Nikro offers a complete line of critical filtered vacuums for use in removing asbestos, lead, toxic, and nuisance dusts or other applications were H.E.P.A. filtration is a must.

Dustless Technologies

One of the big advantages of the Dustless HEPA Wet/Dry Vacuum is the optional Micro Pre-filter that greatly extends the life of the HEPA filter. The Micro Pre-filter is an inexpensive disposable filter that captures the vast majority of the dirt and dust before it reaches the more expensive HEPA filter.

Industrial Vacuums

Industrial Vacuums has supplied vacuums to industry, contractors, home users, fire departments, and federal, state and local government agencies since 1992. 

Pullman-Holt

Pullman-Holt HEPA Vacuums are designed for the efficient recovery of asbestos, lead, mold and many other hazardous materials. Each model meets or exceeds all EPA, OSHA and RRP filtration requirements.

 

 

Click here for other helpful RRPedia posts about HEPA Vacs

 

Topics: Production Considerations, Tools and Supplies, HEPA Vac Info

OSHA to Target Residential Construction Industry, Enforce Lead Standards

Posted by Shawn McCadden on Fri, Dec 03, 2010 @ 04:17 PM

OSHA to Target Residential Construction Industry, Enforce Lead in Construction Standards

Lead in ConstructionOn December 2nd, 2010 I attended an OSHA Respirator and Worker Safety Programs Workshop put on by The Contractor Coaching Partnership and Safety Trainers.  The purpose of the workshop was to help contractors involved in RRP work with the OSHA requirements they needed to comply with when their employees or sub contractors are exposed to lead during construction activities.  Check this previous RRPedia article for more on OSHA requirements for RRP work and conflicts between OSHA regulations and the RRP rule.

Safety Trainers logoAt the workshop Joe Ceccarelli, a trainer with Safety Trainers, shared some information with the attendees regarding OSHA’s plans to step up inspections and increase fine amounts related to the residential construction Industry.  He told us that OSHA Region 1 has hire 250 new additional field inspectors and 40 of those have been assigned to Massachusetts alone.  I was quite taken back when Joe told us he had learned that 72% of OSHA violations levied against residential construction businesses were for what OSHA calls “serious or willful violations” and resulted in fines ranging from $3000 to $70,000.   

Joe told me he learned this information when he attended a session presented by Martha Kent, Region 1 area Director for OSHA, at the ASSE Region VIII New England Area Professional Development Conference and EXPO on November 30 – December 1, 2010 at the Sturbridge Host Hotel in Sturbridge, MA

In the video below Joe talks about what he learned at the conference and wanted to share with contractors.  Joe warns contractors; "They are coming, they are out there and they will be stopping by your jobsite"

 


Topics: Production Considerations, OSHA Considerations, Enforcement and Inspections, Legal Considerations, Videos

RRP Rule Interior Containment General Requirements

Posted by Shawn McCadden on Wed, Sep 29, 2010 @ 08:43 AM

RRP Rule Interior Containment General Requirements:

Lead Test KitThe RRP rule requires that dust and debris be controlled in the work area while working in homes built prior to 1978 unless all effected components of the renovation are properly tested and lead is not found.  You can find information about the legal definition of lead paint and the accuracy of testing methods here.

 

In general, renovations that involve only a small amount of paint disturbance create less dust than jobs that involve larger areas of paint disturbance. However, in addition to the size of the area of paint disturbed, the work practices (e.g., sanding) and equipment used will also affect how much dust is created and how the dust migrates. The location of the work activity also has a bearing on the amount of dust that is distributed. For example, small areas of ceiling work can spread dust over the entire room and are very difficult to control.

Zip Wall containmentRequired containment is similar for all jobs, but jobs that generate more dust and debris may require protection of larger areas. While the Rule does not require vertical containment, such systems may be helpful in limiting the size of the area affected by the work and may reduce the area that must be cleaned at the end of the job. Pre-engineered containment systems (purchased and home-made) are very helpful in cutting time spent on the job erecting containment and are easier to install than hanging plastic sheeting with tape. These systems also allow the contractor to create a sealed room within a room where the dust can be completely contained to a limited and controlled area.   Click here to download a helpful list of tools and supplies for RRP work.

Remember, you are responsible for making sure that dust and debris remain inside of the contained work area. When planning containment, keep in mind how, how much, and where the work practices to be used will create dust, and plan accordingly.  This information should also be considered when estimating the cost to do the work.

General requirements for interior containment:

Warning signPosted signs: These must be posted on all sides of the work area to define the work area, must be in the primary language of occupants, must be posted before the beginning of the renovation, and must remain until cleaning verification is achieved.
Contain the work area: Before renovation, isolate the work area to prevent the escape of dust. During work, maintain the containment integrity and ensure that containment does not interfere with occupant and worker egress from the home or work area.
Remove or cover furniture/objects: Remove (preferred) objects like furniture, rugs, window coverings; or cover them with plastic sheeting with all seams and edges taped.
Cover floors: Cover floors including carpets in the work area with taped down plastic sheeting or other impermeable material to 6 feet beyond the perimeter of surfaces undergoing renovation or to a distance sufficient to contain dust, whichever is greater.
Close and seal doorways and close windows: Close and seal doorways and close windows in the work area with plastic sheeting or other impermeable material. Doors used as entrances to the work area must be covered with plastic sheeting that allows workers to pass through while confining dust to the work area.
Cover duct openings: Close and cover all HVAC vents in the work area with taped down plastic sheeting or other impermeable materials (e.g., magnetic covers).
Remove dust and debris from everything leaving the work area: Use precautions to ensure that all personnel, tools and all other items are free from dust and debris before being removed from the work area.

If you are looking for forms and signage to help you with comply with the EPA RRP rule, I recommend you check out what The Lead Paint Forms Store has to offer.

Topics: Estimating Considerations, Production Considerations, Containment Considerations, RRP for Dummies, Work Practices, Tools and Supplies

Contractors and Subs Doing EPA RRP Work Will Need to Work Things Out

Posted by Shawn McCadden on Fri, Sep 03, 2010 @ 01:50 PM

Renovators And Their Trade Partners Will Need To Work Out And Agree On Who Will Do What

Confused RenovatorMany contractors seeking to comply with the new EPA RRP rule are reporting concerns and challenges about finding trade partners who are willing to operate in compliance.  Many renovators have told me that their trade partners have flat out refused to get their businesses and workers certified.  Others have said their trade partners have committed to do so but have been slow to get it done due to the related costs.  This has become quite an opportunity for some trade partners who have become certified and are marketing their certifications and services to general contractors. Several are actually offering to sub-contract the set-up, containment, demo, clean-up, cleaning verification and all related and required documentation for general contractors.

A surprise to me, but also a no-brainer, was one electrician’s comment that he was having problems finding general contractors to work for who were in RRP compliance.  Just as general contractors need to find new compliant trade partners to work for them, many trade partners are finding they can no longer rely on the volume of work they got in the past from contractors if those businesses choose to operate illegally.

Liability risks may also drive compliance.  Renovators and their trade partners will need to work out and agree on who will do what.  Here are a few examples:

  • Renovate Right PamphletWho will take care of the notification requirements and documentation of same before the job begins?  Under the rule, either can do so, but the business under contract with the property owner must maintain the required documentation.

  • If a trade partner or his employees are not certified renovators, will the renovator take on the responsibility of training and supervising the trade partner and or his employees?  If so, at what level of risk? And, will either business’s insurance company allow such a relationship in the future?  

  • Who will create the required renovation checklist?

  • Who will make sure the homeowner and or tenant receives a copy of the required renovation checklist after completion of the work? 

  • In Massachusetts, who will maintain the required log documenting who comes in and out of the containment area during the course of renovations?

Finger pointingThe first time a RRP fine is accessed for a violation the finger pointing will start, causing one or both businesses to get serious about certification and compliance.  The first time a renovator is sued by a client or neighbor as a result of the actions of a trade partner, the tactics used by the lawyers will cause both businesses to have a new and different outlook on RRP compliance, insurance coverage amounts and indemnification clauses.  Attorney Mike Sams of Kenney & Sams, P.C., told me that failure of a business to be properly certified under the RRP rule on its own is evidence of negligence should a homeowner or insurance company take the contractor or trade partner to court.  Taking this a little further, a contractor hiring a non-certified trade partner might also be considered negligence if that trade partner is allowed to work unsupervised.

IRS LogoTo confuse matters even further, under their definition of the difference between an employee and an independent contractor, the IRS says that a contractor cannot supervise the work or workers of a sub contractor.  Doing so might result in the IRS labeling the sub contractor as an employee. If this were to happen it could trigger addition payroll taxes and workers compensation costs for the general contractor.

Topics: Production Considerations, Subcontractor Considerations, Notification Considerations, Compliance Options, Enforcement and Inspections, Legal Considerations, Documentation Considerations, MA RRP Lead Rules, Shawn's Predictions, Insurance Considerations, Effects of the RRP Rule

EPA RRP Renovators May Be Blind-Sided by OSHA Requirements

Posted by Shawn McCadden on Tue, Aug 03, 2010 @ 12:39 PM

Frustrated Contractor

Renovators Intending to Comply With EPA RRP Rule May Be Blind-Sided by OSHA Requirements

The following article, written by Dick Hughes of Excellence In Safety, was forwarded to me last week by a colleague.   Dick credits his sources at the end of the article.  I also verified the accuracy of the information through one of my contacts at the Massachusetts DOS. 

 

OSHA Logo

The article lists a variety of OSHA considerations that may likely blind-side well intentioned renovators as they attempt to comply with the new EPA RRP Rule.   The RRP Rule and OSHA requirements are in conflict with each other in many ways.  One EPA contact shared with me that EPA and OSHA did not collaborate on the rule while it was being written.   This one consideration alone should raise serious doubt and concern for business owners about business liabilities and potential fines. 

OSHA and RRP ConfusionIf an EPA enforcement employee and and OSHA Field inspector show up at one of your jobsites, at the same time, there is no way you will be able to satisfy both.  I suggest this is another example of shortsighted leadership within both organizations.  It also points out the lack of knowledge and awareness our political leaders in Congress have as it relates to understanding the construction industry and overseeing the creation of regulations that affect businesses of all sizes.

The Article:
Big Compliance Problems Ahead for Worker Safety

On April 22, 2010, the Environmental Protection Agency (EPA) implemented a rule that requires contractors that are hired to perform renovation, repair and painting (RRP) projects in homes, child care facilities, and schools built before 1978 that disturb lead-based paint to be certified and follow specific work practices to prevent lead contamination. This rule is expected to impact hundreds of thousands of employers and millions of employees.

EPA is already proposing an expansion of this rule into pre-1978 commercial facilities. That change will significantly expand the scope of employers and building owners covered by this new regulation. Failure to comply with this new regulation can result in fines as high as $65,000 per violation, including a potential prison term. The EPA will enforce violations of the new regulation starting on Oct. 1, 2010.

The new EPA rule includes the following requirements:

• The new EPA regulations require “firms” that disturb more than 6 square feet of paint per room (or more that 20 square feet on the exterior) in these pre-1978 buildings to become certified with the EPA and employ certified renovators who would train workers and oversee these projects.

• Firms include contractors who are hired to perform renovation, repair and painting work where paint is disturbed in the targeted housing.

• Building owners whose maintenance staff also disturb painted surfaces in targeted housing must also be certified and use certified renovators.

• Certified firms must send a supervisor or “renovator” to an 8-hour class where they become certified to oversee work covered by the RRP rule.

Here’s the rub: The 8-hour class only covers the EPA requirements and completely ignores OSHA worker protection rules. Therefore, safety professionals might find that “Certified Firms” are violating OSHA lead regulations because they were not taught about OSHA requirements for worker protection. This is going to be a huge issue for employers whose employees are exposed to lead hazards during work covered by the new EPA RRP rule.

EPA Rule Doesn’t Fulfill OSHA Requirements
Employers and building owners should be alert to the fact that OSHA rules differ significantly from the EPA RRP regulations. OSHA lead regulations apply to any work where employees come into contact with any level of lead or lead bearing coatings. They should also note the following worker protection and/or OSHA omissions in the new EPA lead-based paint rule:

• Lead-based paint. The EPA RRP rule defines lead-based paint as containing more than 0.5 percent lead by weight. Lead coatings below this threshold are exempt from any special EPA certification, training or work practices. However, OSHA regulates lead in any amount. Therefore, many employers will believe that lead-coated surfaces below the EPA standards of 0.5 percent by weight are not regulated when in fact they may still be regulated by OSHA.

• Regulated areas.OSHA mandates under 1926.62 that employers establish “regulated areas” when lead or lead-coated surfaces are disturbed. A regulated area requires specific OSHA signage. The EPA signs required by their new RRP rule do not meet OSHA requirements for a regulated area.

• Written compliance program. OSHA regulations require a detailed compliance program listing specific requirements for employers to document. The EPA RRP rule does not have any requirements or discussion of a written compliance plan.

• Mandatory respirator use. OSHA lead regulations require monitoring for employees exposed to lead dust or fumes during work. OSHA has established three work class tasks for which certain exposures above the permissible exposure limit (PEL) must be assumed when employers fail to perform exposure monitoring. All of the work practices covered by the EPA RRP rule require employee respiratory protection under OSHA. However, the EPA required training only discusses respirator use as optional. The EPA training does not discuss OSHA regulations for a written respirator program, medical clearance, respirator training and fit testing for employees who are required to wear respirators.

• Protective clothing. OSHA lead regulations require protective clothing when work tasks disturb lead coatings (without a negative exposure assessment). OSHA requires either disposable clothing or employer laundering. The EPA RRP rule lists disposable clothing as optional and trains workers to use HEPA vacuums to clean clothing before going home. OSHA also requires employers to notify other employees or employers who would launder the contaminated clothing. The EPA RRP rules do not provide any awareness for employees who launder their own contaminated work clothing.

• Annual training. OSHA regulations require annual training when airborne levels of lead dust or fumes exceed their action level. EPA’s new RRP rule only requires training every 5 years.

• Hygiene facilities. OSHA regulations require a separate area to change from work clothing to street clothing as well as providing for hand/face washing facilities. The EPA does not address change facilities and suggests that workers wash their hands and face prior to leaving the work place.

• Medical surveillance and biological monitoring. OSHA mandates biological monitoring for employees exposed above the action level for airborne lead dust and fumes. The EPA RRP rule briefly mentions that the only way to detect lead in your blood is with a blood test and does not inform the workers of the OSHA requirement for biological monitoring.

The new EPA RRP lead-based paint rule is an important regulation for reducing the unacceptable levels of elevated lead in children’s blood in certain areas of the country. However, this huge piece of legislation has done a disservice to the millions of workers who will be impacted by lead during common renovation, repair, and painting activities in residential and child occupied facilities by ignoring mandatory worker protection requirements mandated by OSHA. Contractors and building owners must take extra steps to ensure that their workers or employees of contractors disturbing lead bearing substances in their facilities are thoroughly trained and protected in all applicable regulations; specifically OSHA worker protection rules for lead.

Thanks to:

Jeffery C. Camplin, MS, CSP is president of Camplin Environmental Services Inc., a safety and environmental consulting firm based in Rosemont, Ill. He is a licensed lead risk assessor and accredited EPA lead-based paint instructor for abatement courses and the new RRP rule training.

Useful links related to this article:
• July 21 Virtual Audioconference: EPA’s New Lead Paint Regulations Will Get You in Trouble with OSHA http://www.workplacetrainingcenter.com/Prod-2067.aspx

• EPA information on the new RRP rule for lead-based paint can be found at http://www.epa.gov/lead/pubs/toolkits.htm

• HUD information on lead safe work practices for renovation work can be found at http://www.hud.gov/offices/lead/training/rrp/rrp.cfm

• OSHA information on worker protection for employees exposed to lead-bearing substances can be found at http://www.osha.gov/SLTC/lead/construction.html


About the author:
Dick Hughes
Excellence In Safety
24 Spring Bars Road Falmouth, MA 02540
Web: www.excel-in-safety.com
capesafetyguy@aol.com
1-508-548-0866
cell: 1-617-653-4950

This article was originally published at Work Place Magazine

Topics: EPA RRP Lead Rules, Production Considerations, Worker Training, OSHA Considerations, Personal Protection, Compliance Options, Enforcement and Inspections, Legal Considerations, Work Practices, OSHA - EPA Challenges

EPA RRP Considerations for Demolition of All or Part of a Structure

Posted by Shawn McCadden on Fri, Jun 18, 2010 @ 09:40 AM

House demolition

 

Question from RRPedia visitor Dan Tibma of Tibma Design/Build"Under the EPA RRP rule, if I demo an attached garage completely, except for the foundation, what site and debris containment measures do I need to take?"

Dan, thanks for visiting my web site and for your question.  I hope you are well.  I had already started a post about this topic, so you motivated me to finish it and get it posted.  Thanks!

I had asked the EPA a similar question in the list of questions presented to the EPA Region One Office on January 6th, 2010 on behalf of the Eastern MA NARI Chapter.  Eventually, on April 7, 2010, EPA answered the question in the FAQ section of their web site.

Here is the question I asked:

Does the Renovation, Repair, and Painting (RRP) Rule apply to demolishing and disposing of:

  • An entire pre-1978 home or building?
  • An entire, non-attached free-standing structure on the same property such as a garage, shed, or gazebo?
  • An attached but segregated section of pre-1978 home or building such as a sunroom, addition, two-story porch, or garage attached by a breezeway?

Here is the EPA's response:

Garage demolition"The RRP Rule covers renovations, which are defined as modifications of existing structures or portions of structures. The rule does not apply to demolitions of an entire free-standing building or structure.

The RRP Rule does apply to renovation activities that modify portions of existing structures. Waste from these activities must be contained to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal. If a chute is used to remove waste from the work area, it must be covered.

At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work are an d prevents access to dust and debris.

When the firm transports waste from renovation activities, the firm must contain the waste to prevent release of dust and debris."


 

Topics: RRP Questions, Estimating Considerations, Production Considerations, Work Practice Exclusions, Containment Considerations