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.

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

Making RRP Easier - New Understandings About RRP Work Practices

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

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

In 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)

I 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

It 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. 

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

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

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. There 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. It 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

Guest Blog: Weighing In On The RRP Opt Out

Guest Blogger: Peter Lawton had his first lead safe training in 1997 while operating his design/build remodeling firm designPLUS in the greater Boston area. Today he is the founder and senior principle trainer for LeadSMART Training Solutions which trains contractors in areas of lead remodeling and OSHA safety standards. His classes are held throughout New England as well as occasionally on the west coast as well.  Peter can be reached at peter@leadsmarttraining.com or visit his training schedule at www.leadsmarttraining.com .

Opt Out..... Weighing In

Both sides of this issue have valid points to consider. Before we make rash decisions have we looked at the entire picture? We can do better than our politicians, but we must think before we act.

Isn't it a bit odd that months before an election some politician comes out of the woodwork and puts forth this bill? Where was this senator a year ago? How much research and thought went into addressing the bigger picture? Are we being used again as pawns by tapping our emotions and not our intelligence for votes? Do you really feel this is all that stands between you and having enough work?

Here are a few questions/comments I believe this bill ignores:

• Whether the Opt Out comes back or not, what about the employees of the firms who intend on using this option? Did anyone ask those who are actually doing the work how they feel about their health risks? Will they have a voice without retaliation?
• Is OSHA going to come up with a "you must protect your workers’ health UNLESS the customer gave you permission to work unprotected" clause? My bet is OSHA will stand firm on 1926.62 (Lead in Construction). In fact, if you have employees, EPA is irrelevant with whatever they decide to do.
• How about extending the OPT OUT to state that the homeowner releases his or her civil right to sue the contractor should anything go wrong?
• For those of you who think this is all BS, how about signing a waiver that says my tax dollars won’t be used to pay for related health care for you, your family, your workers or your clients who might get sick due to the work you perform?
• If any of you perform HUD work, do you really feel they will buckle from their standards?

Anything that can improve our economy is worth looking at. I am not sure this is the answer everyone has been looking for – can’t we come up with a better solution than Bill #S 2148?

I believe this law can create marketing and positioning opportunities to those who see it this way and in the process, keeps everyone safe  – and for those who see it differently, it’s obviously a never ending source of complaints which has divided our industry at a time when we need each others’ back more than ever.

Stay Healthy,

Peter Lawton, President, LeadSMART Training Solutions

Information, Resources and Instructions About Working Lead-Safe

The 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.

Links 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

Guest Blog: RRP Demolition and Asbestos Removal Share Similar Risks and Work Practices

Guest Blogger: Rachel Gilner is an Outreach Coordinator for Asbestos.com.  She specializes in asbestos awareness, education, and safety issues within the online community.  You can follow the organization on Facebook and Twitter for the latest asbestos and mesothelioma updates.

RRP Demolition and Asbestos Removal Share Similar Risks and Work Practices  

In 2008 the EPA began forcing contractors to abide by the RRP Rule regarding lead and its health hazard.  As noted in the rule, certification is required when working with homes built prior to 1978, which is also the same time period asbestos was commonly used in building homes.  Like lead, asbestos is an extreme health risk for contractors and homeowners.  Since asbestos removal is not required by law it often goes unnoticed by contractors.  Asbestos is the leading cause of mesothelioma, a rare cancer in the lining of the lungs.

If There’s Lead, There’s Probably Asbestos

The EPA created the RRP Rule because lead is found in many products in homes.  Asbestos was also used frequently in homes in similar products such as paint, floor tiles, roofing tiles, and water pipes.  It is safe to assume that where lead is present, asbestos is also near.   Asbestos is only a serious health hazard when it is disturbed, which means during renovations the fibers may be set airborne and inhaled by workers. 

Best Practices for Asbestos are Similar to Lead

According to the RRP Rule workers are required to remain up-to-date on training and lead-safe work practices.  Although the only current laws regarding asbestos removal are for abatement companies and not contractors, safe handling is still important all around. Here are some good rules of thumb:

1. Assume asbestos is present if you are working with an older home if it has not been tested by the owners
2. Post warning signs around the area containing asbestos
3. Wear a HEPA certified protective face mask to avoid inhaling asbestos dust fibers
4. Wet down asbestos particles you may see to avoid them from becoming airborne
5. Change your clothes before returning home and keep work clothes away from family members

Protecting Your Workers

Although asbestos is not included in the RRP Rule, companies should still be concerned about the health and well-being of their workers.  Workers are protected under OSHA, and have the right to a safe workplace.  The law requires employers to provide their employees with safe working conditions.  It would be in the best interest of employers to be aware of lead or asbestos on the premises.  If a proper test has not been performed you should always assume lead or asbestos is present until it is proven otherwise

For additional information on Asbestos visit Asbestos.com.  If you think you may have been exposed to asbestos and would like to speak with someone directly our advocates can be reached directly at 800-815-7924.

Refresher: Exemptions to RRP Work Practices

It’s probably been a while since you took your RRP Certified Renovator Training Class.  This is the first of several blog posts that will be added to RRPedia in the next few months or so to help renovators keep important details about the RRP rule top of mind when selling, estimating or performing RRP renovations.

The RRP Rule's required work practices may be waived under the following conditions:

• The home or child occupied facility was built after 1978.
• The property is used as housing for the elderly or persons with disabilities, unless any child who is less than 6 years of age resides or is expected to reside in such housing
• The property is a zero-bedroom dwelling, such as studio apartments or dormitories.
• The renovations are performed by the home owner(s) themselves
• The renovations are performed without compensation (Examples might include friends, brother-in-law, or volunteers)
• The repairs are minor, with interior work disturbing less than six square feet of painted surfaces per room or exteriors disturbing less than 20 square feet of painted surfaces on the entire envelope.
• The work practices do not apply if the entire house or specifically affected components, as described within a scope of work for the project, test lead free by a Certified Risk Assessor, Lead Inspector or Certified Renovator
• In the case that renovations are for emergency or interim control purposes, the work practices do not apply.  However, in these situations, the cleaning practices and cleaning verification are still required.

I did a RRP videos series for Remodeling magazine shortly after the RRP Rule went into effect.  In video #6 titled; Exemptions to RRP Work Practices, I offer examples of when, where and why the RRP rule and work practices are not required under the rule. The video stresses that even if the work practices are not required under the RRP rule, your business will still be liable if lead poisoning and or contamination results from the way work is performed.  

Also, in the video contractor insurance expert Tom Messier of Mason and Mason Insurance stresses the importance of verifying proper and adequate insurance coverage to protect your business, available coverage options as well as related costs for coverage.

The following information is from the NARI Government Affairs Committee’s newsletter of June 23, 2011 titled “NARI on the Hill”.  

NARI Work Group Findings on LRRP

From March through June 2011, a dedicated work group of NARI members regularly convened for the purpose of documenting challenges in the application of EPA's Lead Renovation, Repair and Painting Rule (LRRP Rule).  NARI's purpose is to convey to the EPA what is working and what is not working in implementation and to make recommendations.  The work group identified the following prioritized concerns with recommendations:

Concern #1

The rule application is presented as a "one size fits all" and fails to provide guidance on the varying conditions often found on job sites.

Recommendation #1

The EPA should revise the rule to define the desired outcomes and provide a tool box of options to address varying conditions.

Concern #2

The cost of compliance is driving homeowners to either DIY or hire an uncertified renovator thus defeating the purpose and intent of the rule.  Also, the rule does not address the contractor's responsibility when the work of disturbing lead paint has been undertaken and completed by the homeowner or an uncertified contractor. 

Recommendation #2

The EPA needs to educate the general public about the rule, clarify the contractor's responsibility under this scenario, and assess the impact of homeowner-initiated projects on childhood lead poisoning.

Concern #3

The EPA lacks an effective method of providing updates and information on the rule.  The website housing over 600 FAQs is not a feasible communications tool.

Recommendation #3

EPA and states with oversight should provide a regular newsletter with necessary updates.  The website should be overhauled addressing the topical information needs of the user.

Concern #4

The rule is not clear on the training and certification requirements for subcontractors used by the certified renovator.

Recommendation #4

The EPA should clarify the responsibilities of subcontractors and define a "certified renovator of record" as a single point of contact throughout the project. 

Concern #5

The model training program is not consistent with the current rule.  Curriculum and materials do not reflect amendments.

Recommendation #5

The EPA must exercise responsibility in properly maintaining training curriculum and material content.

 Why we convened a Work Group: to inform various entities in Washington about the issues with regard to this regulation.  Since regulatory reform is a hot topic in Washington right now, the time is right to share these findings and garner more support. When trying to bring an issue to light in Washington, officials want current data to review, so the Work Group convened for a current, detailed analysis and NARI is sharing recommendations of the Work Group in Washington.

A copy of the complete report is available by request by e-mailing: gac@nari.org.

A Fast, Clean and Safe Way to Remove Lead Paint

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.

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.

Another 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.

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