The EPA RRP Model Certified Lead Renovator Courses do not address one of the critical tasks for an renovation project:  How to use and maintain the HEPA vacuum.  But if a renovator gets this wrong, then HEPA may not help cleanup dust.  Worse, it could spread dust and cause contamination and poisoning. 

  

Some suggestions:

• Cleaning:  If the filter - whether the HEPA filter or the prefilters - gets loaded down with dust and debris, the HEPA vacuum will not move enough air to properly and efficiently collect lead dust and lead debris from the renovation. The renovator must periodically clean the vacuum and replace the prefilter - and depending on the design - the HEPA filter. 

• Sealing: Before you turn off a HEPA vacuum, you need to cover the end of the air intake home with tape or bag the beater bar.  If you don't do this, the dust and debris in the hose will fall out and recontaminate the workplace or be released in the truck or someone else's home.  When you need to use the vacuum, turn the vacuum on and then remove the tape or bag.  Remember, when the unit is turned off, the air intake openings must be sealed.

• Training: When training workers consider the following:

• • Consider adding a demonstration about HEPA vacuum cleaning to the training.  Allow traineees to open up a HEPA vacuum and see how it works. 

  • Consider having the trainees practice with a new unused HEPA vacuum so you can observe and help them.  Make sure it has not been used and contaminated with lead. 

  • Watch the trainees during hands-on exercises to make sure they seal up the vacuum when it is turned off.  If they forget, dump the debris and dust on the cleaned up workplace for a great visual and have them reclean.

The Wisconsin Department of Health Services developed this great two-page fact sheet on "How to Safely Change a Lead Contaminated HEPA Vacuum Bag." They use a common canister vacuum to show how to change the prefilter.

 

 

Use the following link to view and/or download the fact sheet to your computer: How to Safely Change a Lead Contaminated HEPA Vacuum Bag

 

In an April 23 news release, the U.S. Environmental Protection Agency announced release of two new amendments to the EPA RRP Lead: Renovation, Repair and Painting rule regarding dust wipe testing and their intention to apply the rule to public and commercial buildings.

  The proposed amendments would change the lead rule as a direct result of a voluntary legal settlement with several environmental groups that challenged the original regulation.

According to the NAHB the proposed amendments would:

• Require abatement-style dust wipe testing and share results with home occupants and owners.This rule change will apply to certain remodeling activities and require the renovator to achieve the EPA's strict numerical limits for lead dust levels on window sills, window troughs, and floors. The EPA's numerical lead dust standards are the same as those dictated to lead-based paint abatement firms for achieving "clearance" under EPA's abatement rules. Depending on the outcome of this upcoming amendment, remodelers and other contractors may also be subject to additional regulatory restrictions at the state and local level triggered by the knowledge of disturbing lead-based paint. After this proposal is published, it will be out for a 60 day comment period with the goal of completing and finalizing this rule change in July 2011. Click here to view or save the proposed amendment as a PDF
• Apply the lead rule to public and commercial buildings. The EPA plans to amend the rule to expand its scope over both public and commercial buildings. NAHB will follow this development but expects the proposal to come out after the clearance testing amendment.  Click here to view or save the proposed amendment as a PDF

Prohibited and Restricted EPA RRP Work Practices:

The following information comes from the RRP Rule and preamble:

 

 

"The final rule prohibits or restricts the use of certain work practices during regulated renovations. These practices are open flame burning or torching of lead-based paint; the use of machines that remove lead-based paint through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, unless such machines are used with HEPA exhaust control; and operating a heat gun above 1100 degrees Fahrenheit.

EPA has concluded that these practices must be prohibited restricted during renovation, repair, and painting activities that disturb lead-based paint because the work practices in this final rule are not effective at containing the spread of leaded dust when these practices are used, or at cleaning up lead-based paint hazards created by these practices. Thus, the work practices are not effective at minimizing exposure to lead-based paint hazards created during renovation activities when these activities are used."

Note: The final rule does not prohibit or restrict the use of dry hand sanding or dry hand scraping. EPA has concluded that it is not necessary to prohibit or restrict dry hand sanding or dry hand scraping because the containment, cleaning, and cleaning verification requirements of the rule are effective at minimizing exposure to lead-based paint hazards created by renovations and the migration of dust-lead hazards beyond the work area when dry hand sanding or dry hand scraping is employed.

The following information is from the HUD Booklet titled Lead Paint Safety, A Field Guide for Painting, Home Maintenance and Renovation Work. 

 

 

Question:
If a general contractor hires a subcontractor to work at a renovation site, does the subcontractor need to be an EPA certified firm if the subcontractor does not disturb any paint? 

According to the EPA Website:

Firms performing tasks that disturb no painted surfaces whatsoever do not need to be EPA Certified Firms.  However, since conditions at the job site may be difficult to predict, EPA strongly recommends that all firms involved in the renovation be certified and use properly trained and certified personnel.  For example, a firm hired to install an HVAC system after demolition of painted surfaces has taken place may find that to complete the job painted surfaces need to be disturbed.  The HVAC firm may not engage in activities that disturb painted surfaces if it is not certified.  

As every renovation job is different, it is up to the firm acting as the general contractor to determine what activities are within the scope of the renovation and to ensure that other firms are properly trained and certified for the tasks they will be performing.  All firms, including the firm acting as the general contractor, are responsible for making sure the renovation is performed in accordance with the RRP work practice standards, including keeping containment intact and making sure lead dust and debris do not leave the work site.   General contractors should keep in mind that if a firm hires a subcontractor that fails to follow the work practice standards or otherwise violates the Renovation, Repair, and Painting rule, the firm that hired the subcontractor is also responsible for the violation.

If you are a certified renovator trying to figure out innovative, efficient and time saving production methods to protect profits on EPA RRP related projects you might want to consider a dust room.

Building a dust room, particularly on very dusty and or longer duration projects might be well worth the time and material costs to build one.  Lets say you need to re-fit existing doors because they bind or maybe change the hardware on a bunch of interior doors. A dust room can contain the dust in one space and prevent the work area in each particular room from exceeding the 6 square foot minimum. 

 

The following information is from the HUD Booklet titled Lead Paint Safety, A Field Guide for Painting, Home Maintenance and Renovation Work. 

The booklet also includes very thorough instructions, for working lead safe, specific to performing a variety of project types.  It could be a great resource for contractors trying to collect effective and innovative lead safe work practices, just be sure to stay in compliance with RRP rules.

 

Understanding the costs associated with EPA RRP work will help you price this work to keep it as profitable as non-RRP work. Costs usually include job-specific materials, labor, and general supplies (like poly and tape) that may or may not be assigned to a particular job. It's important to job cost for several reasons. First, you want to be sure you're not just making money, but making enough money to cover the costs of that job, plus that job's fair share of overhead, plus that job's fair share of profit. Can you really afford to accept a lower profit margin on RRP jobs? What are the implications for your overall profit if this happens? What about profit-sharing? If your profit-sharing or bonus plan depends (as it should) on achieved gross margins, is it fair to under price RRP jobs and then pass along your loss in the form of reduced profit sharing? If you have one lead carpenter who's your certified renovator, supervising RRP jobs is going to take up most of his time. Should his profit-sharing or bonus be reduced because of this? So be sure that you price your RRP jobs according to a plan in which the true costs in materials and labor are represented. If you do, your achieved gross margin shouldn't suffer as a result of your decision to work on RRP projects.

Note:  This information was contributed by Melanie Hodgdon of Business Systems Management.

Contractors who have made the decision to embrace the new EPA RRP Rule requirements can gain two benefits from creating a system to track time required to perform EPA RRP-related tasks.

First, to price a job, it's important to understand the difference (as measured by employee labor hours) between replacing a window on an RRP Rule job compared with replacing a similar window on a non-RRP Rule job. For example, requiring workers to log time spent on RRP-specific activities such as setup (including taping), removal, and cleanup (including disposal and testing) will provide valuable information for estimating and pricing purposes,

Second, collecting information on time spent on RRP Rule-related tasks can help prove that the right personnel were present at the right time on an RRP targeted project. Other than running a webcam at the jobsite (a potential can of worms!), what better way to prove that your certified renovator was present to supervise during designated times than by providing an auditor with time-based reports designed to demonstrate your compliance?

The challenge will be to set up your time tracking system so it's easy to use and (more importantly) will easily generate the reports that will support you in the face of an audit. The EPA isn't going to hang out at your jobsite; if they go after you, they'll get you in your office. The more detailed and compelling the reports you provide, the more competent and professional you'll look. The more professional you look, the less likely they'll be to nitpick.

Note:  This information was contributed by Melanie Hodgdon of Business Systems Management.

Despite the fact that the EPA passed the RRP lead-safe practices law back in 2008, the word didn't get out very effectively. As a result, the EPA RRP Rule caught many contractors unprepared and scrambling to get themselves certified by the April 22, 2010 deadline. Many companies are focusing on compliance (pamphlet acquisition and distribution, company certification, RRP training, acquisition of dust containment materials and HEPA Vacs), but fewer have thought about how the new law may affect daily practices. For example, a company that's not using daily time cards may find it difficult to quantify changes in the amount of time required to complete work according to the RRP regulations. Failure to understand exactly how much additional time it might take a crew to perform a task can lead to underestimating. Underestimating can lead to under pricing. Under pricing can lead to a cash flow crisis in an already challenging economy. Consistent under pricing can lead to financial failure. On the other hand, documenting time spent on a job (particularly those blocks of time associated with RRP compliance) can not only help with estimating future jobs, but provide a CYA support system.

Note:  This information was contributed by Melanie Hodgdon of Business Systems Management.