RRP Training Refresher: RRP Rule Interior Containment General Requirements

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:

• Posted 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.  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.
• Cover 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.

EPA Lead-Safe Certified Firm Logo Use Guidelines

Guidelines for use of the Certified Firm Logo provided by EPA must be followed to avoid fines.   Reading and understanding the following information can help make sure you are in compliance if you plan to use the firm logo on your vehicles, signage and or any marketing you do.

What is the Lead-Safe Certified Firm Logo?

The Lead-Safe Certified Firm Logo identifies a firm as certified under the Renovation, Repair, and Painting (RRP) Rule. The colors used to make the two-color logo are Pantone 362C (green) and Pantone 660C (blue). The font is Helvetica.

What are the guidelines for using the Logo?

The Logo must be reproduced so that all of its components are legible and includes your firm's certification number. The Logo must not be altered or distorted in any way.

You MAY --

• Use the Logo to identify your firm as an RRP-certified firm. Firms that are not RRP-certified may not use the Logo.
• Use the Logo in brochures, advertisements, Web sites, proposals, bills, signs, uniforms, vehicles and other materials promoting or identifying your firm.
• Use the Logo on documents or other materials in black and white or color (two-color or four-color versions are available).

You MAY NOT --

• Use the Logo in any manner that would imply EPA endorsement of a company, its products or services.
• Reduce the Logo to a size smaller than one inch wide by 0.687 inches in height.
• Allow a firm that is not RRP-certified (including your subcontractors) to use the Logo.

EPA will monitor the use of all Logos. If necessary, EPA will address failure to comply with these Logo Guidelines. To report a non-compliant use of the Logo, please contact EPA at 1-800-424-LEAD.

EPA will e-mail information regarding your custom Logo to the e-mail address listed on your firm certification application.

For further questions regarding your EPA Lead-Safe Certified firm Logo, please send an email to: EPARRPFirmLogo@battelle.org or send a fax to: (202) 566-0470. In your email/fax please include your EPA Firm Certification number (e.g., NAT-12345-1), Application ID (e.g., 12345), firm name, and firm mailing address.

EPA Lead-Safe Certified Firm Logo - Information for Training Providers

Accredited training providers may use the Logo on their site and marketing materials as long as it is used as a tool to guide renovators through the firm certification process (i.e., explain the difference between firm certification and individual training). Training providers may inform students that only certified firms will be provided a customized Logo exclusively for their use to advertise their businesses once their firm has been certified. Training providers may distribute the Logo only to principal instructors affiliated with the accredited provider, and only for the purpose of training as described above. Training providers may NOT distribute the Logo to unaffiliated entities. Upon request, EPA will provide to accredited training provider the Logo for their use. Requests can be made to the National Lead Information Center at 1-800-424-LEAD.

Principal instructors that advertise, provide training, and use the Logo must do so under the name of the accredited training provider for whom they work. They may also state that the organization that employs them, if different from the accredited training provider, is assisting with the training.

Information for Press and Marketing Entities

Press and other marketing entities may use the logo on their site and marketing materials provided it does not include a certification number. They may NOT:

• Distribute or provide a downloadable version of the logo
• Indicate association, endorsement or approval from EPA
• Imply lead-safe certification from EPA or any EPA-authorized state.

Upon request, EPA will provide the logo for use.

Note: The information shown above is from the EPA web site.   EPA has already and may again revise these guidelines.  Use this link to find the most recent info at the EPA web site.

RRP Training Refresher: What is Vertical Containment and When is it Required?

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.

What is Vertical Containment

Vertical containment refers to a vertical barrier consisting of plastic sheeting or other impermeable material over scaffolding or a rigid frame, or an equivalent system of containing the work area. Vertical containment is required for some exterior renovations but it may be used on any interior or exterior renovation.

Is vertical containment required for interior jobs?

No, the use of vertical containment is not required for interior jobs, but you can minimize the amount of floor containment needed by making use of vertical containment for interior projects.  Floor containment measures may stop at the edge of the vertical barrier when using a vertical containment system consisting of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls.  One advantage of vertical containment in addition to the reduction of floor area to be covered is the potential reduction of the floor area and other areas that will need to be cleaned on completion of renovations

Is vertical containment required for exterior jobs?

Yes, vertical containment, or an equivalent system of containing the work area, is required for exterior jobs where the property line is within 10 feet of the area of paint disturbance. In addition, vertical containment can also be used to minimize the amount of ground containment needed for a project.  Ground containment measures may stop at the edge of the vertical barrier when using a vertical containment system.

Creative Use of Vertical Containment

Constructing vertical containment can also allow the contractor to create a sealed working space within a room where the dust can be completely contained to a limited and controlled area.  The space created is referred to as a “dust room”.  This can be extremely helpful in reducing containment and cleaning costs in other work areas if painted components are brought to this area to be repaired or modified, and are then cleaned before returning them to their original location.  One example of this might be cutting down interior doors after the installation of carpeting.  Another might be ripping down head stops when installing replacement windows.

Additional Resources

What is a "Dust Room" and why consider using one for EPA RRP work?

Zip Wall video about creating a variety of vertical barriers using their products

RRP Training Refresher: Defining Work Area Containment

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.

Refresher: Defining Work Area Containment

What is Containment?

“Containment” is what is required under the RRP Rule to prevent dust and debris from spreading beyond the work area to non-work areas.  In general, there are many degrees of containment, ranging from simple plastic sheeting on the floor surrounding a small work area to a fully enclosed space. Some types of containment are more effective than other types.

Why is Containment Required?

Containment is required by the RRP Rule because it reduces the risk to you and residents. Following the work area setup requirements will protect you, your co-workers and residents by confining lead-contained dust and debris to a defined and demarcated area. Confining the lead is an important consideration in avoiding exposure. Reducing the risk to you and co-workers is also dependent upon use of personal protective equipment.  Requirements for the personal protection of workers are established by OSHA and can be found in the OSHA document titled “Lead in Construction”

Proper containment also facilitates efficient cleaning of the work area. The pre-work setup process is essential to keeping lead-contaminated dust confined to the work area where it can be easily cleaned. Proper containment of the work area helps to limit the area you need to clean after the job is complete. Knowing exactly where to clean is an important factor in saving time (and money) spent on cleanup. 

Controlling dust and debris may require more extensive containment than is specified in the rule if the job is particularly dusty. For example, small areas of ceiling work can spread dust over the entire room and are very difficult to control. 

Containing the Work Area Includes:

• Removing objects and furniture from the work area, or covering them with plastic sheeting.
• Covering floors (or the ground) with plastic sheeting a minimum distance beyond the surfaces being renovated (6 feet for interior jobs and 10 feet for exterior jobs).
• Vertical containment is required for any exterior renovation within 10 feet of the property line. 
• Larger areas of disposable plastic sheeting may also be necessary to prevent the spread of dust. 
• Smaller areas of containment may be used if additional precautions such as vertical containment are used to stop the spread of dust and minimize the area of cleanup. 
• Closing windows and doors, and using plastic sheeting to seal doors and air ducts in the work area. 
• Covering doors used to enter the work area with plastic sheeting in a manner that allows workers to pass through but contains dust and debris within the work area.

RRP Info for Property Owners of Rental Housing and Child-Occupied Facilities

Note:  This information came from an article on the ASAP Environmental web site and has been updated for the purpose of this post:

Property owners who renovate, repair, or prepare surfaces for painting in pre-1978 rental housing or space rented by child-care facilities must, before beginning work, provide tenants with a copy of EPA's lead hazard information pamphlet "Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools".

Owners of these rental properties must document compliance with this requirement ? EPA's sample Pre-Renovation Disclosure Form may be used for this purpose.

Beginning April 22, 2010, property owners who perform these projects in pre-1978 rental housing or space rented by child-care facilities must be certified and follow the lead-safe work practices required by EPA's Renovation, Repair and Remodeling rule. To become certified, property owners must submit an application for firm certification and fee payment to EPA. EPA will begin processing applications on October 22, 2009. The Agency has up to 90 days after receiving a complete request for certification to approve or disapprove the application. Read more about EPA's rules and lead-safe work practices in EPA's pamphlet Contractors: Lead Safety during Renovation Property owners who perform renovation, repairs, and painting jobs in rental property should also:

• Take training to learn how to perform lead-safe work practices.
• Learn the lead laws that apply to you regarding certification and lead-safe work practices beginning in April 2010.

• Keep records to demonstrate that you and your workers have been trained in lead-safe work practices and that you followed lead-safe work practices on the job. To make recordkeeping easier, you may use the sample recordkeeping checklist that EPA has developed to help contractors comply with the renovation recordkeeping requirements that will take effect in April 2010.

EPA Approved Lead Test Kit Instructions

Currently there are only two commercially available Lead Test Kits approved by EPA for use on RRP regulated renovations. The approved test kits are offered by Hybrivet Systems, Inc. and ESCA Tech, Inc.  Selecting a lead test kit should be an informed decision. 

Hybrivet Systems, Inc. manufactures and distributes the Lead Check test kit. 

ESCA Tech, Inc. manufactures and distributes the D-Lead Test kit. 

There is one more EPA-recognized test kit, called the Massachusetts Lead Test Kit.  The Massachusetts Test Kit is not commercially available and can only be used by trained professionals—risk assessors or lead abatement professionals

Below, I have included links to written instructions as well as video instructions for both test kits for your convenience.  I find the lead test kit videos particularly helpful because viewers can actually see how each test kit is typically used, what is involved and make a judgment about how long each test will take.

Lead Check Test Kit Video Instructions

Lead Check Test Kit Written Instructions

D-Lead Test Kit Video Instructions

D-Lead Test Kit Written Instructions

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.

RRP Rule Interior Containment General Requirements:

The 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.

•Posted 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.

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.

What States Have Taken Over Administration and Enforcement of The EPA RRP Rule?

Note:  This post was updated on 2/28/12 to reflect information available at that time.

The National Center for Health Housing (NCHH) maintains a list tracking the status of RRP for all 50 states to help renovators and training providers.  The list includes key links and highlights of rule status for each state as well as American Samoa, Guam, Puerto Rico, U.S Virgin Islands.

As of this post (updated on 2/28/12), the following states are either exploring adoption, are in process or are pending adoption of an RRP rule: District of Columbia,  Illinois, Michigan, Minnesota, Missouri, Tennessee, Virginia, California

The following information can be found at the EPA web site.  This information was current as of 2/28/12.  Click here to check the EPA web site for the most current information.

EPA Authorized State Programs

EPA has the authority to authorize states, tribes and territories to administer their own RRP program that would operate in lieu of the EPA RRP regulations. When a state, tribe or territory becomes authorized, contractors and training providers working in these areas and consumers living there should contact the appropriate state, tribal or territorial program office.

The following states have been authorized by EPA: Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin.

Information for States and Tribes

EPA headquarters has developed guidance documents to assist states and tribes that are applying to EPA for authorization to manage their own lead renovation, repair and painting programs (PDF) (122 pp, 257K).

EPA Releases Penalty Guidelines for RRP Enforcement

The EPA recently released a new government document, titled the Consolidated Enforcement Response and Penalty Policy (ERPP), laying out enforcement and penalty guidelines for the Renovation, Repair and Painting (RRP) rule.  The guidelines were announced in a memorandum from Rosemarie A. Kelly, Director of the U.S. EPA Waste and Chemical Enforcement Division, on Office of Enforcement and Compliance Assurance letterhead.  The memorandum was dated August 19, 2010.  The new policy was created because even though the RRP ruling was issued in April 2010, enforcement and penalty issues were not clearly defined and articulated in the ruling then.

In the memorandum, Rosemarie A. Kelly states:

"This Policy sets forth guidance for Agency officials to use in determining the appropriate enforcement response and penalty amounts for violations of Section 409 of TSCA resulting from failure or refusal to comply with provisions of the Pre-Renovation Education Rule (PRE Rule); Renovation, Repair and Painting Rule (RRP Rule); and Lead-Based Paint Activates, Certification and Training Rule (LBP Activities Rule). "

I suggest you check out the introduction section in the policy document.  Although the policy document is intended to provide guidelines for EPA Enforcement staff, the document introduction also states: 

"Enforcement staff should continue to make appropriate case-by-case enforcement judgments, guided by, but not restricted or limited to, the policies contained in this document”

View or download the the enforcement guidelines document (ERPP).

View or download the Final RRP Rule with Preamble

View or download the amendment regarding the Opt-Out and Record Keeping Provisions

View or download the June 18, 2010 memo delaying enforcement of certain certification requirements

For Large RRP Remodels; Renovate or Tear Down and Start Over?

Question from an RRPedia User:


“Shawn, We have met a number of times, most recently at the Rings End event, which was great, informative and overwhelming. I'm not sure where to go for the answer to this question and thought maybe you could direct me. We are bidding a sizable remodel and the architect has note for that bidders are to follow RRP guidelines. Its pre-1978, we will be disturbing 75%+ of the existing structure and it is unoccupied. I'm thinking that we don't need to address the tarping and cleanup because of the magnitude and vacancy. If we do then we need to consider a tear down. Any guidance you can give would be appreciated. I'm sure you get this all the time so I understand if you can't get to it. Best regards, Ray Gaines Sr, Gaines Construction Co. Inc.”

Ray:
Thanks for your message. This question has come up several times already from other contractors like you who are trying to do the right thing and interpret the EPA RRP rule correctly.

The fact that the property is unoccupied during the renovation makes no difference regarding whether the EPA RRP rule applies. This is confirmed on the FAQ page of the EPA web site. Because of the removal of the opt-out provision in July of this year, any residential property where people live or will live (referred to as target housing) now requires the lead-safe practices unless the home tests out negative for lead under the EPA guidelines.

Also under the EPA RRP Rule, unless the entire interior of the structure is gutted down to bare wood, with no coated or painted surfaces remaining, the project must be treated as an RRP project and again the work must be done using lead-safe work practices.  A full removal of all exterior finishes however does require the RRP Lead-safe work practices.  Again, this is confirmed on the FAQ page of the EPA web site.  Keep in mind, all documentation requirements apply as well.

As a side note, your message does say the building is pre 1978; however you do not say whether the property was tested for lead.  If it hasn't been tested, one option to the owner would be to test it.  Of course, if there is no lead, the rule would not apply.

The EPA approved test kits sold by LeadCheck are very accurate.  These tests reliably determine the presence or absence of lead.  If you use these tests the owner would know if any lead is present at all.  However, under the RRP Rule, the EPA says the rule exempts renovations that affect only components that a certified lead inspector or certified risk assessor has determined are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight. EPA further explains that the determination that any particular component is free of lead-based paint may be made as part of a lead-based paint inspection of an entire housing unit or building, or on a component-by-component basis.

So, if the property owner wants to know if there is any lead at all, the EPA approved LeadCheck test kits could be used to do so.  If the owner chooses to use the EPA's action level of lead paint amount to determine if the lead-safe practices would be required, then currently the only way to test for amount of lead would be to use a certified lead inspector or certified lead risk assessor.  

One way to think about this might be to relate it to eating fish.  The government often says that if you fish in certain bodies of polluted water, you can safely eat up to so many of the fish you catch without any health concerns.  If the government says you can eat up to 3 fish a year, how safe would you feel eating even one fish?  Using this analogy, how safe might the owner feel having renovations done if there is any lead present at all at their property?

If you have opportunity to interact with the property owner, I suggest you might find you would stand out from the other bidders if you could share what I have written here with the owners.  It is my opinion that the property owners should know the facts, know their options and then make a decision about how to move forward regarding lead at their homes.