It's a surprising statistic that lead paint was used in approximately 38 million homes prior to its banning in 1978. The EPA estimates that 24% of homes built between 1960 and 1978 contain lead paint, 69% of homes built between 1940-1960 and 87% of those built before 1940 contain lead paint. Lead paint is out there, and you need to know the RRP Rules and Regulations in order to maintain compliance with them.
If you are a contractor working on homes and childcare facilities built prior to 1978, you should be aware of the new EPA RRP Lead Safety regulations that place specific legal responsibilities on renovators, painters, plumbers, electricians and glaziers. Homeowners on the other hand are typically unaware of the rules until a lead certified renovator or a health related incident brings them to their attention.
When a repair or renovation will disturb more than six square feet of interior painted surfaces or 20 square feet of exterior painted surfaces, these rules apply to you. They are fairly straightforward, so make sure you get EPA Lead Certified prior to beginning any RRP regulated renovations, follow the RRP Rules, and get the lead out right.
Step One: Distributing The EPA Renovate Right Pamphlet
If you are working on a home or childcare facility built prior to 1978, Federal law requires that you provide the homeowners and residents with the EPA's Renovate Right Brochure. This pamphlet is available and downloadable from the EPA's website; it informs residents of the hazards of lead contamination, the basics of lead containment and provides recommendations for lead testing and the hiring of Lead Certified Renovation professionals.
Step Two: Before the Work Begins, Containing the Area
If you determine through an EPA-recognized Lead Testing Kit that your worksite contains lead, you will need to secure the regulated area prior to beginning any work activities. Remember that all companies involved in the renovation need to be an EPA Certified Firm and have an EPA Lead Certified Renovator on site during their renovation activities. EPA lead certification of one firm does not provide coverage for other firms subcontracting on the same project; each firm is responsible for its own activities and certifications.
Materials You Will Need
Heavy Plastic Sheeting
Blue Painter Tape and/or Stapler
Warning Signage which states: Warning Lead Poison Keep Out
Warning/Barrier Tape
Paperwork Holder
Indoors Renovations:
Remove all furniture and appliances possible prior to containment. Those items that cannot be removed should be encapsulated in heavy plastic or poly furniture covers.
Close and seal all HVAC vents leading into and out of the worksite
Turn off all HVAC systems during renovation whenever possible
Seal all doors, windows and openings with heavy plastic and tape or staples
Cover the floors with heavy plastic sheeting
Place warning signage at all entrances to the worksite.
Assign separate pathways and entrances to the home for residents and workers to enter and leave the site while working.
Outdoors Renovations:
Seal all windows and doorways around the worksite
Cover the ground and landscaping with heavy plastic
Remove children's playground equipment if possible, or cover with heavy plastic
Mark-off work area with warning barrier tape
Step Three: Gearing Up With Lead Safe Protective Gear
Protecting your workers while they are on the site and after the workday is over is another important consideration of the RRP Rules. Improperly contained lead dust on worker clothing and materials is easily removed to other areas of the residence under renovation, worker's vehicles and the firm's main office as well as worker's homes. There are several companies specializing in providing lead safe work gear. Here is a shopping list to help keep your employees and the areas surrounding the work space safe.
Materials you will need
Gloves (Latex)
Disposable antiskid shoe covers
Disposable Coveralls (Tyvec)
Painters Hats or Hoods
Protective Eye Wear: Dust Goggles or Foam Safety Glasses
N-100-rated disposable respirators
While working in the regulated area it is important to limit hand to mouth contact. That means no eating, drinking or smoking in the work area. Before eating or smoking, employees should wash their hands and faces to limit the possibility of ingesting lead dust. Once the workday is over employees must remove work clothing and wash-up before leaving the work site.
Step Four: Limiting the Amount of Lead Dust Generated
During the renovation process you will want to limit the amount of dust being generated on a daily basis. This makes daily clean-up and project finalization go much faster. When working on surfaces containing lead, mist them with water prior to sanding, scraping, cutting or drilling. On windows sills and other nonporous surfaces, you can use chemical strippers without methylene chloride to remove the contaminated paint without generating dust. When pulling apart components, score the joint with a utility knife and pry apart rather than pounding or breaking.
Wipe down the work space regularly with wet wipes and disposable Swiffer wetjet pads to reduce the dust buildup. Place all debris in a heavy duty trash bag daily. Trash bags should be sealed with duct tape and removed to a secure dumpster or storage facility. HEPA vacuum the area on a daily basis, and clean all tools before removing them from the worksite.
Equipment You will Need
Water Spray Bottle
Utility Knife
Dry/wet Sandpaper
Chemical strippers without Methylene Chloride
Power tools with dust muzzle attachments for HEPA vacuum cleaners
HEPA vacuum cleaner
Low-temperature heat gun
Dry Wipes, Wet Wipes and Swiffer Wipes
Heavy-duty plastic bags
Duct Tape to seal the trash bags
Caution: Certain procedures are prohibited by the RRP Rules in a lead safe work space. Use of power tools to sand, scrape, grind, plane or drill without a HEPA vacuum shroud attachment is strictly prohibited. Compressed air or sand blasters may not be used to remove lead from any of the surfaces. As with all renovation activities common sense should prevail - if inhaling lead dust is highly dangerous to your health, heating it to a vapor will be extremely hazardous to your health. Therefore, you may use a low-temperature heat gun, but heat guns used in excess of 1100 degrees are prohibited, as are open-flame burning torches.
Step Five: Cleaning up the Work Site
Once renovation is complete, the regulated area must be cleaned thoroughly and tested for lead dust. Begin by vacuuming all surfaces, including the walls and ceiling with a HEPA vacuum cleaner - start at the top and work down. Follow-up by wiping down surfaces with a general cleanser and a disposable mop or Swiffer pads. Use plenty of water and rinse the mop or dispose of cleaning pads regularly. For carpeted surfaces, the HEPA vacuum needs to be fitted with a beater bar.
Carefully remove the plastic sheeting containing the regulated area. Gently mist the dust side of the sheet, being careful not to shake loose dust and fold it dust side inward. Duct tape the sheeting shut and place all sheeting in heavy duty plastic garbage bags then seal with duct tape. Once the area has been cleaned, double-check for dust or lead paint chips. If you see signs of either, you will need to rewash the area.
Performing the cleaning verification or the "White Glove Test": You will need to verify that all windows sills, countertops and uncarpeted surfaces in the regulated area are adequately free from lead particles. This is done by wiping each surface with a damp disposable cleaning cloth and comparing the color of the cloth to an EPA issued cleaning verification card. If the color of the cloth matches or is lighter than the EPA cleaning verification card, the surface has been adequately cleaned, and you may move on the next surface. If the cloth does not match but is darker than the cleaning verification card, the surface should be recleaned and retested with a fresh damp cleaning cloth. If the surface fails a second time, wait one hour and clean with a dry disposable cloth. The surface will be deemed to be free of lead dust at that point and no further testing will be required.
Step 6: Maintaining Your Records for the EPA
Certain records will need to be completed within 30 days of project completion and maintained for a minimum of 3 years.
Test results from your original lead paint inspection including the type of testing kit used.
Copies of the training certificates of the remodelers and dust sampling technicians.
Training documentation of all workers on the project
A complete description on the containment materials employed on the project (plastic sheeting, drop cloths, signage etc...)
Documentation of the post cleaning test results performed in the cleaning verification.
Documentation of the waste disposal
Keep track of your records as the project progresses and this will make the record keeping process much simpler for you. This record keeping will also help improve accurate job costing and creating future estimates.
Taken step-by-step, the EPA Rules and guidelines amount to common sense when dealing with a substance that can have such detrimental effects on the health of workers, residents and children in particular. So get the lead out - but be sure you get the lead out right!
