RRP Question: Does Removing Aluminum Siding Fall Under the RRP Rule?
"Theoretically, aluminum siding came with paint on it…..and most was installed before 1978. Does anyone know if the factory paint on aluminum siding has lead in it? Intuitively, one would pull it off without concern for lead, but I have a client who has asked specifically."
Gregory A. Antonioli, GCP, President
The rule includes all painted or coated surfaces. So yes, the siding must be assumed to have lead until tested otherwise.
Note: My opinion as expressed above is based on the fact that the painted surface is being “disturbed”. Here is an interesting conversation about this topic on the JLC forum.
Aluminum siding during that era was manufactured by many different companies so it would not be wise to assume they all used the same paint or coating. Even if you test a product on one house and find it lead free, under the RRP Rule you must assume that same product might have lead if installed on any other building.
Here is one that might seem crazy. Along the same vein, even if you built an addition or deck at a home after 1977, and you know all the products you used were purchased and installed after 1977, if returning to work on the addition or deck you must still assume the addition or deck may contain lead. The only way around this is to test it to prove the absence of lead under the rule.
Something often missed or overlooked is if the original siding under the aluminum siding contains lead. If you have to remove that siding too or even just disturb more than 20 square feet of the old siding when removing the aluminum siding, then the RRP Rule will apply.
Here is what the EPA says at their RRP FAQ area about removing aluminum siding:
I am removing aluminum siding from a pre-1978 home. The aluminum siding was nailed over the top of painted wood siding that tested positive for lead. The underlying painted surface is greater than twenty-square feet. Must I comply with the Rule when removing the aluminum siding?
The work practices for exterior projects are based on a performance standard – if the activity disturbs a painted surface (generally, by creating paint chips or dust) in excess of 20 square feet, the work area must be contained so that dust or debris does not leave the work area while the renovation is being performed. In this case, if the removal of the aluminum siding results in the disturbance of paint in excess of 20 square feet, then the RRP Rule applies. However, if the removal activity could be performed in such a way that does not disturb 20 square feet of painted surface, then the RRP Rule would not apply.
EPA recognizes that this may be difficult to determine in advance of the renovation activity. However, the renovator is the person with the expertise and experience to make this determination on a case-by-case basis. In such a situation, a renovator should consider how factors like the condition of the underlying paint or the chosen method of removal may increase or decrease the likelihood for a disturbance of paint. If there is still uncertainty, EPA recommends that renovators err on the side of caution and be prepared to contain any dust and debris.