New EPA Lead Paint Rules

[DanLuby]

Restoration & Remediation
The RRP Rule: A Significant Impact on the Restoration Industry
by Bob Eukovich
January 11, 2010


As a contractor, you should prepare for a new EPA regulation that becomes effective April 22. The Renovation, Repair and Painting (RRP) Rule addresses work performed in housing and child-occupied facilities built before 1978. If you disturb a surface area containing lead-based paint in a pre-1978 building, the EPA requires you become RRP certified and use specific work practices that prevent lead contamination.

Common construction, renovation and maintenance activities, such as grinding, sanding, drilling and cutting, can create hazardous levels of dust. Even small amounts can harm you, your employees and your customers.


Lead Poisoning

The federal government banned lead-based paint from housing in 1978. Up to that point, the more lead there was in a can of paint, the higher its quality and price. Lead makes paint easier to apply and quicker to dry while inhibiting rust, mold and mildew.

Today, we know lead is an extremely toxic metal that causes many health problems. Like asbestos, there is no safe level of lead exposure. Lead can enter the body through breathing or swallowing lead dust. It accumulates, eventually storing itself in organs, tissue and bones where it can cause irreversible damage.

Lead levels in blood thought to be safe 20 years ago are now considered dangerous. With such small amounts confirmed to cause health problems in millions of adults and children, the regulatory focus is now on routine renovation and maintenance activities that disturb surfaces covered in lead-based paint.


Certified Renovator Course

An individual can become RRP certified by successfully completing a one-day EPA-accredited course. The course teaches how to comply with the RRP Rule by making practical changes in the way work is done.

When working on a pre-1978 home or child-occupied facility, it is required that at least one RRP-certified renovator be on the job. Willfully violating the RRP Rule by employing prohibited work practices can result in fines up to $37,500.

It is a good idea to prepare for the RRP Rule and the possibility of enforcement by signing up for a certified renovator course. It will educate you and your staff how to work safely with lead by adopting simple practices and procedures.


Test the Paint

The RRP rule requires the contractor test each painted surface that will be disturbed during the job to determine if the paint contains lead. If the contractor resides outside of California, he will have to test the paint by using an EPA-approved test kit.

A California-based contractor must assume that any structure built before 1978 contains lead, so testing as specified by the EPA is not necessary. Contractors outside of California may also elect to skip the testing process and assume that surfaces contain lead-based paint.

This decision is understandable, since 66 percent of all homes and apartments built between 1940 and 1960 contain this dangerous material; 25 percent of homes and apartments built from 1960 to 1978 contain lead-based paint as well.


Advise Your Customers

Before beginning a job in a home, child-care facility or school built before 1978, certain EPA materials must be made available to the homeowner or building manager. The contractor is also responsible for explaining the steps that will be taken to protect the residents or building occupants from any exposure to lead dust.


Setting Up a Lead-Safe Work Site

Any contractor performing remediation work is familiar with the requirements for creating a lead-safe work area:
● The work area must be contained or separated from other parts of the building using heavy plastic sheeting.
● Objects that cannot be moved must be covered and sealed with poly as well.
● Entry doors and HVAC vents must be closed and sealed, and there are the warning signs to post, etc.
● Workers must have the appropriate personal protective equipment, i.e. clothing and respiratory protection.


Doing the Job

Common work practices in construction, renovation, restoration and demolition work create serious dust problems. Electric power tools such as drills, sanders, grinders, circular saws, reciprocating saws and scrapers all raise dust particles above OSHA’s Permissible Exposure Limit or “PEL” levels.

These power tools are prohibited for jobs covered by the RRP Rule.

To contain dust safely under RRP, you must use “ventilated” power tools connected to a HEPA vacuum. These specialized power tools are designed for dust control. They have shrouds that capture the dust when it’s at its most friable and transfers it under negative pressure to a HEPA vacuum.

New dust catching devices for drilling are beginning to appear on the market. There are plastic bubbles that stick on the surface and allow it to be drilled through it as it captures the dust.

A simple method for accomplishing the same result is to spray shaving cream on the wall and drill through it. The shaving cream will capture most of the dust and it’s easy to wipe away and dispose.

Electric power tools certainly create the most friable and dangerous dust. However, there are lead-safe practices that apply to non-electric or manual tools, which can also generate huge amounts of dust. For example, in demolition work, prying and pulling materials or components apart is a dustless alternative to pounding and hammering.

Other traditional work practices prohibited by the RRP Rule include planing, needle gunning, or blasting power tools, unless they are connected to a HEPA vacuum. Open flame burning, torching and heat gunning are also prohibited since it creates dangerous fumes and small lead particles that settle on surfaces and are difficult to pick up.


Clean-Up

With the exception of floors, the protocol for clean-up following a remediation job is identical for lead dust. The first step is to collect all the dust and debris in heavy mil plastic and seal it tight. Once the poly is removed, any objects and all non-floor surfaces should be cleaned with a HEPA vacuum or damp disposable wiping cloths.

Remember, lead is very toxic and it only takes a very small amount to poison you. Lead dust particles can remain on clothes, shoes hands and hair. HEPA vacuums should be used to clean work clothes and shoes before leaving the work area.

Do not bring lead-based paint dust home and expose your family to this poisonous material.

The last step is to clean the floor. Lead is a very dense, heavy metal so it tends to fall on the floor, and it is difficult to pick up. A floor that looks spotless may still contain lead dust, and normal cleaning methods are simply not sufficient to get the job done.

Sweeping is not effective and a standard vacuum may actually cause a more widespread exposure. Uncarpeted floors should be wet-mopped using a dual bucket system.

For cleaning carpeted floors, the RRP Rule is very specific. The only acceptable method is to use a HEPA vacuum connected to a powered brush roll.

Floor cleaning is critical because children play on floors where they can get the dangerous dust on their hands, toys and other objects they put in their mouths. Childhood lead poisoning is considered a major environmental health problem in the U.S. Children with unsafe levels of lead have damaged neural pathways in the brain causing learning and behavior disorders.

It is not by coincidence that approximately half of the children in special education today have higher-than-normal blood lead levels.


Cleaning Verification

After cleaning and a visual inspection, a certified renovator must perform a cleaning verification. The cleaning verification starts with a wipe down, using disposable cleaning cloths for every window and countertop.

Uncarpeted floors are wiped clean using a Swiffer mop. Each “used” wipe or Swiffer cleaning cloth must be compared visually to sample images printed on an EPA Post-Renovation Cleaning Verification Card.

A certified renovator can use the EPA Post-Renovation Cleaning Verification Card to determine whether dust, debris, or residues still exist after cleaning, and if a re-cleaning is required.


Waste Disposal

Waste disposal for materials containing lead is similar to remediation of materials containing mold. All waste and debris should be disposed in accordance with federal, state and local regulations.

Waste and debris should be placed in heavy mil plastic bags. Use a gooseneck seal and HEPA-vacuum the outside of the bag before it is removed from the work area. Examples of RRP waste include plastic sheeting; paint chips; drywall; wipes; mop heads; protective clothing; used respirators; gloves and architectural materials.

For more information on the RRP Rule and upcoming lead requirements, contact the National Lead Information Center at (800) 424-LEAD (5323) or visit EPA’s website at www.epa.gov/lead.


Bob Eukovich is Vice President of Sales & Marketing, Pullman-Holt & Pullman-Ermator LLC and EPA Certified Renovator. Email him at BEukovich@PullmanHoltCorp.com.


SOURCE: http://www.randrmagonline.com/Articles/Feature_Article/BNP_GUID_9-5-2006_A_10000000000000733146
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[Black Water]

Thanks for the info, that was extremly informative. We need to get the ball rolling and get all of our people in the class.

Thanks again!

[mca]

That is great information as we have the same laws for lead starting in Australia . Do you think this will add more expense to a mold remediation job. as we have found it hard to win the work down here against the guys using the Goldmorr mold remediation system as it requires no removal of any structure .
The insurance companies down here prefer this system and are bringing out new protocols totally based on this system , we heard it's coming out in Feb 2011 .
We are attending this course at the end of this month in San Diego as the courses are fully booked down here for this year.
We had a mold conference down here last month which was followed up with a IICRC mold course the major players in the industry did attend which concerned every one.
There is so much information on mold removal we find we have to move with what the major players want [ insurance companies]
I have been talking via email with some of the guy's attending this course over there and most do not do water or mold removal so it's hard to get an idea were the industry over there is going as we seem to be going in another direction over here in Australia, where we have always followed the USA.
Any thoughts from you guy's

[Water_damage]

WASHINGTON--(BUSINESS WIRE)--A coalition of housing industry groups joined the National Association of Home Builders (NAHB) today in announcing plans to file a lawsuit against the federal Environmental Protection Agency (EPA) for removing the “opt-out” provision from its Lead: Renovation, Repair and Painting rule.

“About 79 million homes are affected, even though EPA estimates that only 38 million homes contain lead-based paint. Removing the opt-out provision extends the rule to consumers who need no protection.”

The Lead: Renovation, Repair and Painting rule (LRRP) applies to homes constructed before 1978 when lead paint was banned. Its opt-out provision, which expired July 6, let consumers allow contractors to bypass extra preparation, clean-up and recordkeeping requirements in homes where there were no children under 6 or pregnant women, thus avoiding additional costs.

“Removing the opt-out provision more than doubles the number of homes subject to the regulation,” said NAHB Chairman Bob Jones, a home builder and developer in Bloomfield Hills, Mich. “About 79 million homes are affected, even though EPA estimates that only 38 million homes contain lead-based paint. Removing the opt-out provision extends the rule to consumers who need no protection.”

The Hearth, Patio & Barbecue Association, the National Lumber and Building Material Dealers Association and the Window and Door Manufacturers Association joined NAHB in filing the petition for review in the U.S. Court of Appeals for the D.C. Circuit.

The group will challenge EPA’s action on the grounds that the agency substantially amended its LRRP regulation without any new scientific data and before the regulation was even put into place on April 22, 2010.

“Even under the original rule, the opt-out provision was not available in homes where small children or pregnant women live,” Jones said. “That shows that this change provides no additional protection to the people who are most vulnerable to lead-based paint hazards.”

Remodelers’ and other contractors’ estimates of the additional costs associated with the lead-safe work practices average about $2,400, but vary according to the size and type of job. For example, a complete window replacement requires the contractor to install thick vinyl sheeting to surround the work area both inside the home and outdoors – with prep time and material costs adding an estimated $60 to $170 for each window.

“Consumers trying to use rebates and incentive programs to make their homes more energy efficient will likely find those savings eaten up by the costs of the rule’s requirements. Worse, these costs may drive many consumers – even those with small children - to seek uncertified remodelers and other contractors. Others will likely choose to do the work themselves – or not do it at all – to save money. That does nothing to protect the population this rule was designed to safeguard,” Jones said.
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PuroClean Home Rescue of Sacramento, specializes in water damage, fire, mold damage and other conditions resulting in property damage.