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EPA RRP Lead Paint Guidelines
What you need to do
Before the project starts, you have to hand out the new EPA lead paint brochure. Click HERE for "Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools." (You should have been doing this since December 2008.)
Your company must be certified by the EPA to work in homes with lead paint. It costs $300, and you can apply on the EPA's Web site. There is currently a 90-day wait to get approval back from the EPA.
At least one person with your firm has to take an EPA-approved eight-hour course in lead-safe renovation practices. Click HERE for a full list of providers.
For every project in a pre-1978 home, you need to follow the EPA's lead-safe work practices, which include posting warning signs for occupants and proper cleaning and isolation of the work area. Click HERE for the full EPA regulations provided by the US government.
You need to keep records for three years that show you followed the regulations, including proof of delivery of the "Renovate Right" pamphlet, documentation of work practices and proof of training and certification.
States are also allowed to take over administration of the program, as long as their requirements are at least as strict as the EPA's. So far, only Wisconsin has done so, but several other states are in the planning process.
OSHA Related Articles
Pending OSHA standards are mandating worker protection from harmful airborne particles created from drywall sanding and diamond tool grinding of concrete, masonry and stone materials. The dust from these materials is tied to lung cancer, silicosis and other serious maladies. In some areas right now, contractors are not allowed on the job without having a dust-containment system.
RRP Related Articles
- RRP Basics
- Renovation, Repair and Painting (RRP)
- Legal & Insurance Issues
- Remodeling Blogs about Lead Paint Rule
- Training documents & Forms
- Best Practices
EPA Lead Paint Regulations and Renovation Contractor Certification Requirements
Please note: While the EPA mandates the use of a HEPA vacuum, not all vacuums that use a "HEPA" filter meet government standards. Traditional shop vacuums retrofitted with a HEPA filter do not constitute a "certified" status, and fines as high as $32,000 are being reported for not complying with standards. The Dustless HEPA Vacuum uses a Certified HEPA filter and meets all government requirements, and are priced to be affordable for small contractors.
Cleaning Activities and Checking Your Work
Effective cleaning includes using specific techniques and following the proper order when cleaning. In this section, participants will learn:
- How to conduct an effective cleaning;
- The tools to always keep in your truck and at the work site;
- Effective techniques to clean up after both interior and exterior jobs;
- Safe disposal methods; and,
- How to check your work.
What is Effective Cleanup?
Just as you approach a job by planning the work to effectively contain dust and debris, you must approach cleaning by first having effective containment, then carefully following specific procedures to best clean the work area. The techniques outlined in this section should make your cleanup faster, more efficient, and more effective.
- Always conduct a visual check of the work area to make sure all work is complete.
- Proper waste disposal and checking your work are essential to the process of cleaning.
- The most effective cleaning will follow this sequence:
- Pick up all visible paint chips and debris.
- Clean and dispose of protective sheeting.
For interior renovations:
- Walls - slowly HEPA vacuum or wipe with a damp cloth, working from high to low.
- Other surfaces - thoroughly HEPA vacuum all surfaces including furniture and fixtures.? Wipe any remaining surfaces with a damp cloth.? The HEPA vacuum must have a beater bar for use on carpeting.
- Mop uncarpeted floors using the two-bucket mopping method.
- Visually inspect your work.
- Bag all waste in heavy-duty plastic bags, "gooseneck" seal, and dispose of them according to Federal, state and local regulations.
- Perform cleaning verification on windowsills, countertops and uncarpeted floors.
- Remove warning signs.
- Use a "gooseneck seal" -- a heavy duty plastic bag
- Pick up all visible debris and paint chips prepares a work area prior to the first HEPA vacuuming.
- Clean and dispose of protective sheeting. This step should come before HEPA vacuuming in order to collect any dust that may escape from the protective sheeting.
- HEPA vacuum the area from high to low. This first HEPA vacuuming will collect dust and debris not visible to the naked eye.
- Wet cleaning and mopping the area will further dislodge any lead-contaminated dust or debris not collected by the first HEPA vacuum. Wet cleaning also gets dust and debris that is "stuck" to surfaces.
- If necessary, a final pass with the HEPA vacuum or wet cleaning cloth will capture any remaining dust or debris left after the wet cleaning.
- The last step should be to check your work to make sure that visual check inspection can be passed, and all waste is bagged, sealed and disposed of in accordance with Federal, state and local laws.
A dust clearance examination may be required by Federal, state, tribal or local law, or it may be requested by the homeowner. If so, the clearance examination will replace the cleaning verification process. Clearance is required by HUD in many homes receiving Federal housing assistance.
Interior Cleaning Requirements
- Why should you pick up paint chips and other debris before picking up the protective sheeting? Why should you mist down and wet wipe the protective sheeting before picking it up? Answer to both questions: To prevent accidental spreading of lead-contaminated paint chips and dust off of the protective sheeting.
- After the first visual inspection of the work area, cleaning, folding and disposing of the protective sheeting is the next step. Clean your protective sheeting with a HEPA vacuum and wet wipe if necessary. Once cleaned, fold (dirty side in) and seal the sheeting and dispose with the rest of your waste. When you pick up and fold the protective sheeting (dirty side in), be careful not to spread any dust that may remain on the sheeting.
- This process is followed by HEPA vacuuming and wet mopping (discussed in the next slide) to clean up any dust that escaped the protective sheeting.
- Note that the sheeting covering the entry to the work area should stay in place until after the cleaning and removal of other sheeting.
- Workers must always clean at least 2 feet beyond the work area.
- Cleaning from high to low is more efficient and effective because any dust or debris dislodged will fall down to the floor. Just as one would clean steps working from the top down, cleaning a work area should proceed from high to low to "push" all dust not collected down to the floor, which should be cleaned last.
Visual Inspection Procedure
- Always conduct a visual check after cleaning is completed. If you find any dust or debris, make another pass with the HEPA vacuum and, if necessary, wet clean again. You should continue these steps until the site passes a visual check.
- After passing a visual check, you can perform the cleaning verification procedure or have a clearance examination performed to check your work. In some instances, other dust sampling may be required.
- Cleanup should always be performed as if a clearance examination is to be conducted after cleaning.
Dust Clearance Examination
- HUD requires a dust clearance examination after certain kinds of jobs in target housing receiving Federal housing assistance. Ask if the property receives Federal assistance. If so, ask if a clearance examination is required.
- In some states, a clearance examination conducted by a certified or trained person may be required by law. You should be aware of laws regarding clearance examinations and renovation work in your state and locality.
- In some instances, the owner may request that dust wipe samples be taken to locate lead hazards and to ensure cleaning has been effective. If you follow the cleaning techniques described earlier, you should pass be able to pass clearance testing.
- Emphasize that once you begin a clearance examination, if the clearance fails you must continue the cycle of re-cleaning, visual inspection, and dust wipe testing until the dust wipe results comply with the clearance standards governing the work.
Exterior Cleanup Requirements
- The main point of cleaning after an exterior renovation job is not to let dust spread beyond the work area. The focus is to be specifically on the areas accessible to children. This includes bare soil, play areas, exterior porches and exterior window sills.
- Always visually inspect beyond the work area. Collect and dispose of all paint chips, dust and debris found.
Exterior " Check the Effectiveness of Cleaning
- Discuss why a visual inspection for checking the cleaning is necessary.
- The visual inspection checks for visible dust and debris and includes all parts of the work area, areas not covered by the protective sheeting, and areas 2 feet outside the containment.
- Waste should be stored in a secure area to prevent children from getting into it and being exposed to leaded dust.
- Waste water produced during the job from mopping, wet cleaning, or misting should not be poured down the sink or tub (because it will contaminate the sink or tub), into the yard or down a storm drain.
- Before disposal, waste water may need to be filtered through a filter capable of filtering out particles 5 microns or larger, depending on state and local wastewater regulations.
- If local regulations allow, waste water may be poured down the toilet. If local regulations do not allow this, you may be required to contain and test the water, and contact a waste disposal company to assist you with disposal. Your local water authority can assist you with this decision.
- Always be aware of Federal, state and local regulations regarding waste water disposal.
- All waste should be handled carefully and sealed in heavy duty plastic bags.
- Do not overfill the bags. Renovation debris is heavy, and, if overfilled, will split the bags and could injure workers.
- Certified Firms must be aware of all components of the waste produced at the job site and of the proper method of disposal. Again, always be aware of Federal, state and local waste disposal regulations.
Disposal - Federal, State and Local Information
- Waste disposal is regulated under the Resource Conservation and Recovery Act (RCRA), and various associated state and local laws and regulations.
- Some waste generated from lead work may meet the definition of "hazardous waste" because it is toxic, corrosive, ignitable or explosive. Therefore, it is important for contractors to segregate waste into categories that are likely to be hazardous and non-hazardous. Examples of hazardous waste may include paint chips, vacuum debris, sludge or chemical waste from stripper, and HEPA filters.
- Generators of less than 220 pounds of waste per job site per month are exempt from Federal waste disposal regulations and most state regulations.
- Many states have more stringent regulations than Federal requirements. It is, therefore, important for contractors to understand their obligations under these laws and regulations.
- You should always be aware of how much waste you are generating per job site per month.
- EPA"s website has links to state information on solid and hazardous waste disposal at https://www.epa.gov/epawaste/wyl/stateprograms.htm.
- In a memorandum to RCRA Senior Policy Advisors and EPA Regions 1-10, dated July 31, 2000, EPA"s Office of Solid Waste stated that lead-based paint waste from households may be disposed of as household garbage subject to applicable state regulations. For more information, see Appendix 8 and the EPA website at www.epa.gov/lead/pubs/fslbp.htm. Although EPA considers lead-based paint waste commonly generated during residential renovation and painting to be household waste, some states have not yet adopted this interpretation. Until states do adopt EPA"s interpretation, they may continue to regulate lead-based paint waste as potentially hazardous if generated in large enough quantities.
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