KBB - November 2010 - (Page 12)
EPA offers clarity on the ner points of the RRP Rule
Editor’s note: Designer Mark Brady, of Mark Brady Kitchens, has been recounting his experience and frustrations with trying to comply with the Environmental Protection Agency’s Renovation, Repair, and Painting (RRP) Rule on K+BB’s blog, kbbcollective.com. The rule went into effect on April 22, 2010 and was designed to protect homeowners from lead contamination by requiring certi cation of all contractors performing renovation and painting jobs that disturb lead-based paint in homes built before 1978. K+BB asked Brady to submit some lingering questions regarding compliance, which were then forwarded to the EPA. Following are the EPA’s responses. The full Q&A appears at www.kbbonline.com/leading. Is it true that when a house is pre-1978, we can test for lead and skip the lead-safe procedures if none is found? If a home is found not to contain lead-based paint, it is not subject to the rule’s requirements. If lead-based paint is present, the requirements of the rule must be followed. To nd out more details about the speci c requirements of the rule, see the Agency’s Small Entity Compliance Guide to Renovate Right at http://epa.gov/lead/pubs/sbcomplianceguide.pdf. Plumbers, heating contractors, electricians and cabinet and counter installers have been telling me they don’t need to be certi ed, trained or rm registered because the Rule doesn’t apply to them. Is this true? It depends. If a contractor disturbs more than 6 sq. ft. of painted surfaces on the interior of a pre-1978 home or child-occupied facility (or more than 20 sq. ft. of painted surfaces on the exterior of a building), the rule’s requirements apply. Many thousands of plumbers, HVAC contractors, electricians, cabinet and counter installers, etc. have already become EPA-certi ed and taken training in lead-safe work practices from EPA-accredited private training providers. When I have set up a containment area, don’t mechanical contractors and the like need to be certi ed to do work in the containment area? Or do I just remove everything and send them in when it’s vacuumed and “clean enough” to remove the containment? The rule does not require that every worker at a job be a certi ed renovator. Certi ed renovators can conduct on-the-job training for other workers to ensure that the job is carried out in a lead-safe manner and that the work area is contained, the dust is minimized and the clean up is thorough. The rule does require that a certi ed renovator be present at certain key parts of the job, such as setting up the containment and at the cleaning veri cation stage.
Certi ed rms earn the right to use this logo in their business marketing materials.
When the lead-bearing components have been deposited in a dumpster, can bare studs and joists and sub- ooring with the bark still on them be vacuumed off and called “clean enough” to remove the “containment” and work normally? The rule requires that the certi ed renovator conduct a cleaning verication to ensure that a thorough cleanup takes place after the job is complete. The Small Entity Compliance Guide to Renovate Right outlines the steps required for cleaning veri cation. Once the studs, joists and sub- oor are vacuumed and the containment is down and work proceeds as “normal,” can the homeowner reenter the work area before it is “damp-cloth-cleanable”? There is no prohibition on the homeowner entering the work area; however, it is a good practice to keep the work area contained so that children, pets, etc., do not enter the area and dust is not inadvertently picked up from the work area and tracked to other parts of the house or building. In class, the procedure presented for certifying a space as being clean enough to re-occupy involved using wet Swiffers for every 10 sq. ft.— starting at the ceiling and going to and across the oor—and then administering the little window card test. How can vacuuming rough, bare studs, joists and sub- oors, etc., be considered clean enough to occupy and work regularly? The RRP rule requires cleaning veri cation, not clearance testing, after renovation jobs. Cleaning veri cation involves wiping oors, countertops, and windowsills with wet disposable cleaning cloths and comparing the cloths to a cleaning veri cation card distributed by EPA. If the cloths match or are lighter than the veri cation card, those surfaces have been adequately cleaned. When all surfaces pass cleaning veri cation, the work area is ready for re-occupancy. Clearance testing is a different process. EPA requires clearance testing after lead abatement projects. Clearance testing is performed by a certied inspector or risk assessor, who collects dust wipe samples from the oors and windows in the work area. These samples must be analyzed for lead content by a laboratory recognized under the National Lead Laboratory Accreditation Program (NLLAP). If the sample results are below the clearance standards, the area has passed clearance and is ready for reoccupancy.The clearance standards are 40 micrograms of lead per sq. ft. of oor area, 200 micrograms of lead per sq. ft. of windowsill area and 400 micrograms of lead per sq. ft. of window trough area. If any samples are above the clearance standards, the surfaces represented by that sample
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