Welcome to RRPedia
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

Instructions For Using LeadCheck Test Kits On Drywall And Plaster

Posted by Shawn McCadden on Wed, Mar 28, 2012 @ 05:57 PM

Instructions For Using LeadCheck Lead Test Kits On Drywall And Plaster

EPA Lead Paint Rule

EPA has recently updated recognition of the 3M™ LeadCheck™ for use on drywall and plaster. Currently-recognized test kits, with information including substrates upon which they can be used, can be found at http://www.epa.gov/lead/pubs/testkit.htm.

 

Lead Check Lead Test Kit

Please note that all EPA-recognized test kits must be used following the manufacturers’ instructions for the applicable substrate.


NOTE: FOR USE ON PLASTER AND DRYWALL, users of 3M™ LeadCheck™ should download updated instructions for using the test kit on plaster and drywall. The updated procedure for testing plaster and drywall is slightly different than the procedure used previously.

 

Instructions for using LeadCheck on drywall and plaster

Download the instructions here

 

3M™ LeadCheck™ test kits shipped to retail outlets after April 1, 2012, will contain the updated instructions. Kits purchased prior to April 1, 2012, or that contain the older instructions can still be used but the user must follow the updated instructions when testing plaster and drywall.

 


Topics: Tools and Supplies, EPA RRP Rule Updates, Lead Test Kits and Testing, EPA Announcements

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

Labels, Signs and Printers for RRP – and Beyond: Guest Blog

Posted by Shawn McCadden on Thu, Jul 14, 2011 @ 06:00 AM

Labels, Signs and Printers for RRP – and Beyond

 

Steve Stephenson, Duralabel

 

 

 

 

Guest Blogger: Steve Stephenson is the Managing Director for Graphic Products at DuraLabel

 

You’ve been reading about the Environmental Protection Agency (EPA) rule which requires contractors performing renovation, repair and painting (RRP) projects that disturb lead-based paint in dwellings where children under six and/or pregnant women live to be certified and follow particular work practices including using signs and labels to prevent lead contamination.

EPA 40 CFR 745.85 states that firms must post signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area. These signs must be in the primary language of the occupants. The signs must be posted before beginning the renovation and must remain in place and readable until the renovation and the post-renovation cleaning verification is completed.

The EPA says that signs and labels must adhere to this hierarchy:

  • The word “Warning” must be placed at the top of the sign
  • Underneath “Warning,” the sign must say “Lead Work Area”
  • Under that, “Poison”
  • Finally, under “Poison,” the sign must say “No drinking, eating or smoking”

These types of warning signs and labels typically may be purchased pre-printed in bulk. Other types of signs are also often required. These are custom signs and labels for commercial jobs, final inspections and re-labeling painted pipes and drains. There are a number of approaches to making these signs and labels, too.  

Consider:

  • How frequently you’ll need to create new signs and labels
  • How critical is visibility? Weather-resistance?
  • Sign and label placement – indoors or outdoors?
  • The ability to bring your printer to the jobsite for on the fly labels

The new DuraLabel Toro printer, for example, is battery-powered for mobility, comes with software for pipe marking and custom label design and prints one half inch to four inch wide labels at any length. Light adhesive tape supplies are repositionable and adhere to a variety of surfaces and textures – important when you need to place a label on a wall or in a kitchen that you’re in the midst of preparing to paint.

“I think that being able to re-apply the signs is a huge advantage as walls and finish surfaces tend to change during construction,” said Geoffrey Shafer, PEGASUS Design-To-Build.

As many contractors fit the DIY profile, we’re pretty sure that they’ll opt for creating their own signs and labels when they need them.

 

For more information about the DuraLabel family of mobile printers and rugged supplies for contractors, contact Steve Stephenson, Managing Director, Graphic Products and visit www.DuraLabel.com.

Topics: OSHA Considerations, Compliance Options, Tools and Supplies, Guest Blogs, Signage

A Fast, Clean and Safe Way to Remove Lead Paint: Guest Blog

Posted by Shawn McCadden on Sun, Apr 10, 2011 @ 06:00 AM

A Fast, Clean and Safe Way to Remove Lead Paint

Catherine Brooks

One Person’s Opinion: Catherine Brooks, MBA is the owner of a small business, Eco-Strip LLC since 2003. Previous to starting this second business, she owned a consulting practice and worked for 20 years with small private companies, local and state governments, and OSHA. Her specialties were public health, recycling, and executive training. She comes from the Eastern Shore of the Chesapeake Bay. There she learned the hard way that moisture can destroy a paint job. She regrets that she power-washed her older home several years ago and SOON will now have to repaint it.  

 

A Fast, Clean and Safe Way to Remove Lead Paint

Good painters know that surface preparation before repainting is critical for quality and longevity of new paint. They also know that thick paint removal is a pain. Plus, most paint applied before 1978 is lead-based. With the new EPA's RRP rule, dry abrasive methods such as power sanding, power planing, and mechanical scraping without vacuum attachments are prohibited; so is high temperature heat gun usage. These methods create and disperse lead dust, chips, and vapors which are seriously harmful to children and adults. Some contractors are upset with the requirements imposed by RRP, but the US is way behind European countries in regard to lead paint safety.

 

Airborne leaded dust chart

 

In the late 1980s, a safer and more eco-friendly method was developed in Sweden by a historic restoration painter. This method uses mid-range, infrared heat waves to heat both the substrate and the paint at a lower temperature. Therefore, it greatly reduces the hazards of removing lead-based paint in three ways:

  1. Metallic lead vaporizes at 1,100°F (the temperature at which high heat guns operate). The mid-range infrared heat waves heat the paint and wood only to 400-600º F. Dangerous lead fumes are not released. 
  2. Containing lead dust is difficult and costly but critical to prevent operator, building occupants, and the environment from being contaminated. The scraping of the soft paint created by the infrared heat generates minimum dust; dry scraping, sanding or shaving paint creates lots.
  3. The soft paint scrapings clump together and drop onto a plastic sheeting; they are easier to contain and bag up. While pressure washing surfaces may be faster, it leaves water full of paint chips in the work area’s soil, making it difficult to clean up without removing the top soil itself. Use of toxic or non-toxic chemical paint removers leaves messy goo also difficult to contain.

Dry scraping lead paintAnother key consideration in paint removal is the impact on wood, especially old, more valuable wood. Chemicals leach out natural resins and leave residue even after rinsing. High heat (1,100ºF) guns force paint pigment back into the wood and risk scorching and igniting wood. Sanding and shaving leave gouge and burn marks if not done skillfully. Pressure washing and new steam paint removal methods often leave irregular surface marks in the wood, drive moisture back into the wood, and create layers of “gray wood” which must be scraped away and or they will threaten the adherence of new paint.  All of these methods can damage wood.

Infrared heat paint removal can be the gentlest process on the wood. The infrared heat penetrates into the wood and pulls up natural resins, paint, and moisture deep within and rejuvenates the old wood. Yet, the lower temperature of 400-600° F. minimizes the risk of scorching the wood or catching it on fire. The stories of these heat gun fires are legendary.

Infrared paint removal The time for the entire surface preparation process is reduced using the infrared heat method. Set up, operation, and cleanup are faster than with other methods. There is no extra time for rinsing, neutralization, drying, or sanding the wood; it is immediately ready for primer.

Since there are several brands of infrared paint removers on the market, look for these qualities:

  • UL listing to verify safety testing.
  • Shock absorbers to reduce bulb breakage.
  • Automatic, overheat shut-off mechanism to prevent damage to the machine and the wood and to prevent paint overheating.
  • Built-in safety shields extending beyond the infrared bulbs that set the correct distance between the bulbs and the painted wood. These shields eliminate the operator’s guesswork about what distance is safe yet effective and also reduce overheating.
  • Comprehensive instruction materials and training videos to assure quick operator proficiency, safe operation, and proper maintenance of the machine.

Infrared heat for paint removal is a new technology whose time has come. Preservation of older homes rather than demolition is growing. People are choosing to rejuvenate their old homes for aesthetic, historic, and ecological reasons. Infrared paint removal offers a safer, gentler, and more ecological method to remove lead-based paint and bringing old wood back to life.

Contact: Catherine Brooks, Eco-Strip LLC with questions at cbrooks@eco-strip.com. Further information is at www.eco-strip.com

Topics: Technology for Remodelers, Work Practice Exclusions, Compliance Options, Work Practices, Tools and Supplies, Guest Blogs

Costs Of RRP Challenging Many Businesses And Likely To Go Higher!

Posted by Shawn McCadden on Tue, Jan 11, 2011 @ 06:00 AM

Costs Of RRP Compliance Challenging Many Businesses and Likely To Go Higher!

Renovators have justified their concerns about the additional costs of complying with the EPA RRP Rule based on two different but interdependent reasons.  First is the cost to the business.  Businesses that do comply have to pay to become a certified firm, pay training fees for the required certified renovator training, pay the wages of the certified renovator while he/she trains non-certified workers, pay the wages of employees while they attend training, and must purchase all of the tools, related equipment and personal protection equipment needed by workers to do the work.   Second, they cite the additional labor and material costs to perform the work.  

RRP Challenges and RRP Problems

 

These additional costs might not be all that burdensome if all contractors doing RRP work shared the same burdens and where able to recover these costs through the selling prices of their jobs.  But, the additional costs become an extreme burden for many businesses if and when they are in competition with illegally operating businesses that avoid the additional costs and therefore are offering lower prices to consumers.  Many contractors are reporting that the additional costs are putting them out of business.

 

Ready for some more bad news?   The costs of compliance are likely to go up even higher, for complying businesses as well as for consumers. 

  • First, the proposed dust wipe amendment, if approved, will definitely increase projects costs and will result in delaying when the consumer can get back into the renovated space. 
  • Second, in addition to the costs related to the dust wipe testing, because contained areas cannot be re-inhabited until the tests show no lead dust, consumers may need to seek alternate living arrangements while waiting for test results to come back from laboratories. 
  • Third, because of the lack of a cost effective lead test kit that will recognize lead based on the legal definition of lead equal to or in excess of 1.0 mg/cm\2\ or 0.5% by weight, many projects that would not require lead safe practices must still be performed using lead-safe practices. 

Here is excerpt from the final rule preamble:

RRP Costs“Number of events and individuals affected: In the first year that all of the rule requirements will be in effect, there will be an estimated 8.4 million renovation, repair, and painting events where lead-safe work practices will be used due to the rule. As a result, there will be approximately 1.4 million children under the age of 6 who will be affected by having their exposure to lead dust minimized due to the rule. There will also be about 5.4 million adults who will be affected. After improved test kits for determining whether a painted surface contains lead-based paint become available (which is assumed in the analysis to occur by the second year of the rule), the number of renovation, repair, and painting events using lead-safe work practices is expected to drop to 4.4 million events per year. No change in the number of exposures avoided due to the rule is expected because the improved test kit will more accurately identify paint without lead, thus reducing the number of events unnecessarily using the required work practices.”

So, because the EPA falsely assumed that the improved test kits would be available by September 2010, 4.4 million RRP projects will bear the additional cost of lead-safe practices that would not be required if the improved test kits were available.  That one bad assumption by EPA, based on the bogus and underestimated average additional cost of $35 per project, will result in $140 million in additional costs for projects “unnecessarily using the required work practices”.   What do you think about that?   What would consumers think about that?

Topics: Estimating Considerations, Tools and Supplies, Lead Test Kits and Testing, Effects of the RRP Rule, Amendments, Statistics

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

Posted by Shawn McCadden on Thu, Dec 16, 2010 @ 06:00 AM

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

On December 2nd I attended an RRP/OSHA Respiratory and Worker Protection Workshop put on by The Contractor Coaching Partnership and Safety Trainers.   The workshop was really helpful for me.  It helped me tie together some of my open questions and concerns regarding OSHA requirements and compliance as they relate to RRP related work activities for employees.

Respirators for RRP workWhile at the workshop I found one thing the main instructor Darcy Cook of Safety Trainers said to be very important for contractors to be aware of.   Under the OSHA Lead in Construction Standard, contractors must assume their employees will be exposed to lead above OSHA’s established action level requiring the use of respirators until they actually conduct air monitoring testing to prove otherwise.

This means that respirators must be worn while doing RRP work until the testing is done and a written respirator plan is put in place that details when a respirator is required and when it is not.   Engineering controls can be used to limit the creation and or spread of lead dust while work is performed.  The requirement to wear the respirator or not all depends on the kind of work being done as well as how the work is performed. 

For example; the sanding of painted surfaces.  If dry hand sanding is done, a respirator will definitely be required.   If wet sanding is done a respirator may not be required.  If the sanding is being done using a sander attached to a functioning HEPA Vac that captures all sanding dust, a respirator is probably not required.   The previous sentence is qualified with “may” and “probably not” on purpose.  The only way to know if a respirator is required or not is to monitor the air for lead dust while the work is actually being performed.

The chart below is from the EPA Certified Renovator Manual.  The chart shows exposure levels of airborne leaded dust for some common renovation activities.   OSHA’s permissible exposure limit (PEL) for workers is 50 Micrograms per centimeter squared (50 µg/m3).   If exposed over the PEL, workers must wear respirators.  All three activities in the chart exceed the PEL.

 

Airborne leaded dust, OSHA PEL   

Respirator fit testing and OSHA Respirator Fit Testing RequirementsSo, under OSHA requirements, before allowing them to do RRP related work or even enter a contained work area, employees must first be sent to a physician to be sure they are healthy enough to wear a respirator. Then they must be fit tested by a professional and provided with a properly fitted respirator that protects them from worst case lead exposure scenarios based on the kind of work they do. They must also be trained how to select, use, clean and store a respirator.   And, they must wear the respirator until the air monitoring testing is done to identify when a respirator is required and when it is not depending on how the work is performed and what engineering controls are being used.

Although these OSHA requirements are not new, the majority of residential contractors are not aware of them.  Unfortunately, ignorance of the requirements will not be an excuse if OSHA inspects one of your projects and or one of your employees is poisoned by lead.   Perhaps it would have been helpful if EPA had included the above information in the required eight hour certified renovator training when showing the chart above.

 

Click here for more information about Personal Protection Equipment (PPE) required for RRP work

Click here for more about what you need to know about Respirators when doing EPA RRP work

Click here for OSHA standards for cleaning a respirator

Topics: Worker Training, OSHA Considerations, Personal Protection, Compliance Options, Work Practices, Tools and Supplies, Health Effects of Lead, OSHA - EPA Challenges, Info for Trainers

Choosing Between EPA Approved Lead Test Kits

Posted by Shawn McCadden on Thu, Nov 11, 2010 @ 07:00 AM

Choosing Between EPA Approved Lead Test Kits

Now that they have more than one option, many renovators are now asking how to go about choosing a lead test kit.  Currently there are two commercially available Lead Test Kits approved by EPA for use on RRP regulated renovations. The recognized lead test kits are offered by Hybrivet Systems, Inc. and ESCA Tech, Inc.   

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

Lead Check test kit

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

D-Lead test kit

 

The D-Lead test kit was only recently recognized for RRP use.  The Lead Check Kit has been recognized since before the RRP rule came into effect on April 22, 2010.

RRP Instructor Shawn McCaddenGiven the choice, as Massachusetts and EPA authorized RRP instructor, I will definitely use the Lead Check Swabs in my training classes.  I offer some reasons for this choice below.  However keep in mind, if you do RRP renovations, you will likely be choosing which test lead test kit to use and why for different reasons than I would as an instructor.   I hope the information below helps you make a good decision when you select a lead test kit.  Please feel free to add any other comparisons or consideration for choosing a lead test kit by commenting at the end of this article.

Comparison of Lead Test Kits

  • In my opinion the Lead Check test kits are simpler to use.  The Lead Check kits give instant results with no waiting, where as the D-Lead Test Kit instructions say the test takes 3-13 minutes. 
  • The Lead Check kits can be used on the surface to tested, but the D-lead kit requires the collection of samples and placement of the samples into test solution bottles. 
  • Lead Check swabs contain everything you need inside the swabs.  You can just squeeze the kits with your fingers as instructed, shake the swab and you are ready to test.  The D-Lead kits require measuring and mixing chemicals to get ready for testing.
  • I believe the Lead Check kits are much safer, as they do not contain any toxic or harmful chemicals.  The D-Lead test kits contain sodium hydroxide and ammonium sulfide, both of which are considered irritants to the skin and eyes and should not be ingested.  Sodium sulfide smells like rotten eggs.  Ammonium sulfide is also flammable.
  •  The Lead Check Kits can be disposed of right after use, where the D-lead kit chemicals, because they are hazardous, must first be poured into a waste disposal bag.  The disposal bag is provided with the D-Lead kit and contains a waste absorbent to neutralize the harmful chemicals.
  • The D-Lead kits are approved for use on drywall and plaster.  The Lead Check Kit is not currently approved for use on drywall and plaster by EPA, but Hybrivet Systems, Inc. reports they should have that approval in the near future.
  • The D-Lead kit has a relatively short shelf life of 12 Months unopened, but 6 months once opened.  The Lead Check kits have an indefinite shelf life and therefore do not have an expiration date.
  • Lead Check is available in stores everywhere and on-line.   D-Lead is new to the market and therefore is not yet readily available for purchase in all markets.  Their web site says it is available at The Home Depot under the name of Klean-Strip.  The ESCA Tech, Inc. has a list of distributors where their product is available.
  • The 8 Swab Lead Check kits are available on-line for $24.95 (about $3.12/test).  When used as per the instructions, each swab can only be used once.  The 6-test D-Lead kit was available at the same on-line distributer for about $28.95 (About $4.83/test) and if used as per the instructions each test can only be used once.
Note: I had previously reported in this article that the individual Lead Check swabs could be used up to three times as long as the swab did not turn red.   Doing so would be in violation of the manufacturers instructions and would therefore not be in compliance with the RRP rule.  EPA states that users must follow the manufacturers instructions when using the test kits.  This makes sense because the EPA used the manufacturer's instructions as part of their standard process when evaluating the kits and ultimately recognizing them for RRP use.  It has also been pointed out to me that EPA does not "approve" test kits for RRP use, rather they "recognize" test kits for RRP use.  This article was updated on 12/15/10 to reflect the information in this note.

I hope you find this information helpful.  Whether you are an RRP instructor or a renovator doing RRP work, the best way to understand the differences between lead test kits would be to read the instruction manuals for both and decide for yourself.   For access to written and video instructions for both test kits see: EPA Approved Test Kit Instructions

Topics: RRP Questions, Tools and Supplies, Lead Test Kits and Testing

EPA Approved Lead Test Kit Instructions

Posted by Shawn McCadden on Tue, Nov 09, 2010 @ 07:00 AM

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. 

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

 

 

 

 

 

D-Lead Lead Test KitESCA 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.

Topics: EPA RRP for Dummies, RRP for Dummies, Tools and Supplies, Lead Test Kits and Testing

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

EPA Offers Clarification About Approved EPA RRP Lead Test Kits

Posted by Shawn McCadden on Thu, Jul 15, 2010 @ 01:53 PM

EPA Approved Lead Test Kits

Trainers and renovators have been expressing some confusion about the EPA approved lead test kits.  The confusion revolves around whether the current test kits can still be used and/or if and when they might be replaced.

 

7/15/10: The following is the most recent information and communication about EPA approved lead test kits sent from EPA Headquarters in DC to each of the EPA regions. 

 

EPA LogoEPA Communication to EPA Region Headquarters:

"I wanted to take this opportunity to clarify an RRP issue because I understand that there may be some mis-information that may have been given out to training providers.  I understand that training providers have been told they should not buy a lot of the currently available test kits because they will not be valid after September 1.  This is incorrect.  I would appreciate it if you would ask your staff to clarify this with the training providers in particular.

 Background on Test Kits

  • EPA has recognized two Phase 1 test kits (LeadCheck and State of Massachusetts kit) for use in determining if there is lead-based paint in target housing and child-occupied facilities.  These are currently being used by renovators and in renovator training classes.
  • These kits will continue to be recognized until EPA recognizes Phase 2 kits.  The Phase 1 kits do not automatically sunset on September 1 or any other date in the absence of approved Phase 2 kits.
  • EPA, under the Office of Research and Development’s (ORD) Envirnomental Testing Verification (ETV) process is currently evaluating 4 test kits for the Phase 2 criteria.  At this time we do not know if any of the kits will pass.

 We should have results in late July and will share that with you and post the preliminary results on the web."

Note: This information was shared with me by Joe Moriarty of LeadCheck.  LeadCheck® Swabs is the only EPA recognized rapid lead detection product available for RRP use by EPA Certified Renovators.

Topics: RRP Questions, Tools and Supplies, EPA RRP Rule Updates, Lead Test Kits and Testing