Recently the EPA published changes to the RRP (Renovation Remodeling and Painting) rule.
These changes are posted on the Federal Register: RRP Rule changes
The proposed rule published on May 6, 2010. EPA has decided not to
promulgate dust wipe testing and clearance requirements as proposed.
However,
EPA is promulgating several other revisions to the RRP rule,
including a provision allowing a certified renovator to collect a paint chip sample and send it to a recognized laboratory for analysis in lieu of using a lead test kit, minor changes to the training program accreditation application process, standards for e-learning in accredited training programs, minimum enforcement provisions for authorized state and tribal renovation programs, and minor revisions to the training and certification requirements for renovators. EPA is also promulgating clarifications to the requirements for vertical containment on exterior renovation projects, the prohibited or restricted work practice provisions, and the requirements for high-efficiency particulate air (HEPA) vacuums.
From the update:
Renovator trainees must receive hands-on training in using
test kits, renovation methods that minimize creation of dust and
lead-based paint hazards, containment and cleanup methods, and
cleaning verification.
See our DVD for training your crew in LSWP (lead safe work practices)
Vertical Containment:
Vertical containment. EPA's 2010 proposal included more specific
language on vertical containment requirements for exterior projects.
As proposed, the rule would specifically state that vertical containment
is required for exterior renovation projects that are covered by the
rule and that affect painted surfaces within 10 feet of the property
line. In such cases, vertical containment is necessary to ensure that
adjacent buildings or properties are not contaminated by leaded dust or
debris generated by the renovation.
HEPA exhaust control
power tools used to remove painted surfaces are prohibited
unless such machines have shrouds or containment systems and are
equipped with a HEPA vacuum attachment to collect dust and debris
at the point of generation. Machines must be operated so that no
visible dust or release of air occurs outside the shroud or containment
system.''
HEPA Vacuums
EPA has decided to promulgate the requirement that HEPA vacuums be operated
in accordance with manufacturer's instructions,
more...
HEPA vacuum means a vacuum cleaner which has been designed with a
high-efficiency particulate air (HEPA) filter as the last filtration
stage. A HEPA filter is a filter that is capable of capturing
particulates of 0.3 microns with 99.97% efficiency. The vacuum cleaner
must be designed so that all the air drawn into the machine is expelled
through the HEPA filter with none of the air leaking past it. HEPA
vacuums must be operated and maintained in accordance with the
manufacturer's instructions.
Paint Chip Sampling from Appendix 13.2 of the 1995 Hud Guidelines
Dust sampling must always be done before paint chip sampling in
order to minimize the prospect of cross-sample contamination.
Paint chip sampling is a destructive method that may release a
small quantity of lead dust. Although paint chip samples are to
be collected from inconspicuous areas, the occupant must always
be notified that paint chip sampling may be necessary.
Method One: Plastic Sheeting Underneath Sampling Area
A clean sheet of plastic measuring four feet by four feet should
be placed under the area to be sampled to capture any paint chips
that are not captured by the collection device or creased piece
of paper. Any visible paint chips falling to the plastic should be included
in the sample. Dispose of the plastic after each sample is collected by
placing the sheeting in a trash bag. Do not throw away the plastic at
the dwelling. Wet wipes may be used to clean the area.
It is my opinion paint chip sampling will be a PITA for the average renovation contractor and the Lead Check and D-Lead sampling options will be the first choice to determine the presence or absence of LBP
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