The New Lead RRP Rule

John P. Lapotaire, CIEC

Lead paint clearance testing and abatement is becoming an increasingly important topic for remodelers as government requirements to control the hazard intensify. On April 22, 2010, federal law will require that contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, childcare facilities and schools built before 1978 must be certified and follow specific work practices to prevent lead contamination.

“The Lead RRP rule comes into effect anytime 6 sq. ft. of a painted surface will be disturbed inside or outside a home,” says Ada Duffy, CR, CLC, spokesperson for Milwaukee Lead/Asbestos Information Center, Inc. “When that criterion is met, it will be required that one person per crew be a certified renovator to handle the lead paint cleanup properly. In addition, that certified renovator has to work for a certified firm.”

Currently the one-day Lead Safe Work certification program is administered through the EPA. States will also be able to carry out the program as they apply for the state to do so. Beyond being certified, the responsibilities of certified remodelers include the following.

\* Training the entire crew on proper removal practices \* To be present and to facilitate the posting of appropriate signage \* Hand out the informational pamphlet no more that 60 days before the renovation work and obtain written acknowledgement that the occupant has received it \* To ensure that proper containment aids are being set up \* Make certain that lead safe work practices are implemented \* To be present on-site at all times during cleanup \* Perform the cleaning verification at the end of the process \* Keep accurate records of the entire process

If performing interior renovations, it is important to remove all objects from the work area. Any objects that can’t be removed should be appropriately covered with plastic. All duct openings in the work area should also be closed and covered. Plastic sheeting should be used to shield all doors, windows and floor surface including carpet. Precautions should also be taken to ensure all personnel, tools and other items are free of dust before leaving the work area.

When carrying out an exterior project, all doors and windows within 20 ft. of the renovation should be closed. Doors that will be used within the work zone while the job is being performed require plastic sheeting. To avoid contamination, plastic sheeting needs to cover the ground in the area being worked on and extend 10 ft. from the zone.

The main focus at the end of the job is to make sure that everything was cleaned up adequately. That means eliminating the dust that was possibly created. During cleanup all paint chips and debris must be collected, all protective sheeting should be removed, and a HEPA vacuum with a beater bar attachment is required for carpeted floors. Waste must be contained to prevent releases of dust and debris during and after the cleanup.

Additionally, for interior cleanup, all objects in the work area and within 2 ft. of the work area must be cleaned. For walls, cleaning should start at the ceiling working down using a HEPA vacuum or wiping with a damp cloth.

Remaining surfaces should be cleaned thoroughly with a HEPA vacuum or damp cloth as well. During the cleaning verification process, windowsills, the floor and countertops are all areas that will have to be inspected before the project can be reopened.

“Rather than looking at this as an inconvenience from more regulation, it’s actually going to result in the safety of workers and homeowners and perhaps a better sales tool for remodelers,” explains Duffy. “Homeowners may be more inclined to hire a qualified remodeler rather than someone who doesn’t work lead safe. This could result in more projects for remodelers who are certified as homeowners decide not to take on the task themselves.”

Until this rule goes into effect, the EPA recommends anyone performing renovation, repair and painting projects that could disturb lead-based paint in pre-1978 homes, childcare facilities and schools follow lead-safe work practices. The contractor should follow these three simple procedures: Contain the work area, minimize dust and clean up thoroughly.

For additional information on this new rule and all Lead Safe removal practices please visit these sites:

Information on the EPA Lead program: http://www.epa.gov/lead Information on the Lead Safe rule: http://www.epa.gov/lead/pubs/renovation.htm Application information on certifying a firm: http://www.epa/gov/lead/pubs/toolkits.htm To locate certified training firms: http://www.epa.gov/lead/pubs/trainingproviders.htm