Frequent Questions About Work Practice Standards Under the RRP Rule

Occupant Protection

When renovating the exterior of a high-rise building, does the requirement to close and seal doors and windows within 20 feet of the renovation include closing those openings two-plus floors above the floor where work is to be performed?

Not necessarily. When establishing containment for an exterior renovation on a multi-story building, you must close all doors and windows within 20 feet of the renovation on the same floor as the renovation, and close all doors and windows on all floors below that are the same horizontal distance from the renovation. In certain situations, the renovation firm must take extra precautions in containing the work are to ensure that dust and debris from the renovation does not contaminate other areas of the property. The conditions at your renovation site may be such that closing and sealing doors and windows on floors above the renovation is necessary to prevent these areas from being contaminated by dust and debris.

Question Number: 23002-23855

Containing the Work Area

What is the “work area?”

The “work area” is the area established by a certified renovator to contain the dust and debris generated from a renovation. In other words, the work area is defined by the containment measures established by the certified renovator. While a renovator has some discretion in setting up a sufficient amount of work area containment, the RRP Rule sets forth minimum requirements for both interior and exterior renovations.

For interior renovations, cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area six feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust, whichever is greater. Floor containment measures may stop at the edge of the vertical barrier when using a vertical containment system consisting of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls.

For exterior renovations, cover the ground with plastic sheeting or other disposable impermeable material extending 10 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to collect falling paint debris, whichever is greater, unless the property line prevents 10 feet of such ground covering. Ground containment measures may stop at the edge of the vertical barrier when using a vertical containment system. If the renovation will affect surfaces within 10 feet of the property line, the renovation firm must erect vertical containment or equivalent extra precautions in containing the work area to ensure that dust and debris from the renovation does not contaminate adjacent buildings or migrate to adjacent properties. Vertical containment or equivalent extra precautions in containing the work area may also be necessary in other situations in order to prevent contamination of other buildings, other areas of the property, or adjacent buildings or properties.

Question Number: 23002-32337

What is your recommendation if work has started and it begins to rain? What do we do with the water that is on the plastic in the containment area?

Before beginning the renovation, the firm must isolate the work area so that no dust or debris (including in the wastewater) leaves the work area while the renovation is being performed. In addition, the firm must maintain the integrity of the containment by ensuring that any plastic or other impermeable materials are not torn or displaced and taking any other steps necessary to ensure that no dust or debris, including water, leaves the work area while the renovation is being performed.

Some recommended options to prevent contaminated water from leaving the work site include:

Stop work and clean up the work site before rain begins. Proceed with interior work only.
Cover the area with a tarp to deflect the rainwater away from the work site.
Collect the water and dispose of it. Check with your local water treatment authority for local requirements for handling and disposing of wastewater.

Question Number: 23002-23220

What mil plastic is considered impermeable?

The regulation does not specify a particular thickness of plastic sheeting considered to be impermeable, but rather includes a performance standard. The performance standard requires firms to isolate the work area, prevent dust and debris from exiting and ensure plastic sheeting is not torn or displaced. Certain guidance materials recommend the use of six mil plastic sheeting, such as the U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint in Hazards in Housing. However, for the purpose of the RRP Rule, a contractor should choose one or more layers of plastic sheeting of sufficient thickness to prevent puncture based on the circumstances of the particular project.

Question Number: 23002-23297

Do I need to cover a closet door with plastic?

Yes, if the door is inside the work area. When containing the work area during an interior renovation, the firm must close windows and doors in the work area. Doors must be covered with plastic sheeting or other impermeable material.

Question Number: 23002-15162

What are the requirements for covering doorways used to access the work area?

Doors used as an entrance to the work area must be covered with plastic sheeting or other impermeable material in a manner that allows workers to pass through while confining dust and debris to the work area.

Question Number: 23002-21413

If a door is outside the work area but used by workers to enter and exit the room, does the door need to be covered with plastic?

If the work area is smaller than the entire room, and the door is not within the work area, you do not need to cover the door with plastic. However, all personnel, tools, and other items, including the exterior of containers of waste, must be free of dust and debris when leaving the work area.

Question Number: 23002-18246

Is interior containment required as well as exterior containment for an exterior window removal?

Yes. If removing windows from the exterior creates dust and debris on the interior as well as the exterior of the building, then the firm must follow the requirements in the RRP Rule for both interior and exterior containment. Before beginning the renovation, the firm must isolate the work area so that no dust or debris leaves the work area while the renovation is being performed. Window replacement typically disturbs paint on both the interior and exterior of a building.

Question Number: 23002-19009

When must scaffolding and vertical shrouding be used on an exterior renovation when other buildings are in close proximity to the work area?

The certified renovator or a worker under the direction of the certified renovator must contain the work area so that dust or debris does not leave the work area while the renovation is being performed. The certified renovator must be on site while the containment is established and is responsible for ensuring that dust or debris does not spread beyond the work area. The extent to which scaffolding and vertical shrouding are needed to meet this standard will depend on the conditions at the work site.

When performing exterior renovations, you must cover the ground with plastic sheeting or other disposable impermeable material extending 10 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to collect falling paint debris, whichever is greater, unless the property line prevents 10 feet of such ground covering. Ground containment measures may stop at the edge of the vertical barrier when using a vertical containment system. If the renovation will affect surfaces within 10 feet of the property line, the renovation firm must erect vertical containment or equivalent extra precautions in containing the work area to ensure that dust and debris from the renovation does not contaminate adjacent buildings or migrate to adjacent properties. Vertical containment or equivalent extra precautions in containing the work area may also be necessary in other situations in order to prevent contamination of other buildings, other areas of the property or adjacent buildings or properties.

Question Number: 23002-23847

If I paint without disturbing the surface of the existing paint, can I use a tarp instead of six mil plastic?

Yes. Projects that do not disturb a painted surface are not subject to the RRP Rule.

Question Number: 23002-18508

Plastic can be a slip hazard in some jobs, such as handling granite counter tops. This creates a more immediate safety concern than protecting the floor from dust. Can I just clean the floor at the end of the job?

No. For interior renovations, before beginning the renovation the renovation firm must cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust, whichever is greater.

You must comply with this requirement unless it is impossible to do so, for example, during portions of a renovation project that involve removing flooring, sanding a hardwood floor, or removing or installing carpeting. However, the RRP Rule allows you to place another, less slick, disposable surface (such as paper) on top of the plastic sheeting as long as the plastic sheeting remains intact. Remove and dispose of both surfaces at the completion of the job.

Even when plastic is used to cover the floor, you must also clean the floor at the end of the job. Thoroughly vacuum using a high-efficiency particulate air (HEPA) vacuum. The HEPA vacuum must be equipped with a beater bar when vacuuming carpets and rugs. Mop uncarpeted floors thoroughly, using a mopping method that keeps the wash water separate from the rinse water, such as the two-bucket mopping method or using a wet mopping system.

Question Number: 23002-19908

How can I use plastic sheeting in exterior renovations without creating a safety hazard? Moisture on the plastic from precipitation can cause plastic sheeting to become slippery.

Question Number: 23002-16472

During exterior power washing, instead of plastic, can landscaping fabric or a similar material be used to capture any paint chips or other debris, but permit the water to seep through?

No. Landscaping fabric is not an impermeable material.

Question Number: 23002-15754

When setting up the work area for a RRP project must the plastic be "sealed" to the floor on all four edges by tape or just "secured or held" to the floor by tape at several locations?

It depends on the specifics of the renovation job. The RRP Rule requires the renovation firm to cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area six feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust, whichever is greater. Floor containment measures may stop at the edge of the vertical barrier when using a vertical containment system consisting of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls. It is up to the certified renovator to determine how to cover the floor in such a way that dust and debris are captured by the containment and the site can be cleaned at the end of the job.

Question Number: 23002-18677

Does the RRP Rule require people working on a renovation to wear respirators, Tyvek(R) suits or other personal protective equipment (PPE)?

EPA would like to clarify the requirements for personal protective equipment. The Occupational Safety and Health Administration (OSHA) has requirements for personal protective equipment, EPA does not. For many years, EPA has recommended the use of personal protective equipment as a way to protect workers and to help ensure that leaded dust and debris does not leave renovation or abatement work sites.

EPA recommends that renovators make use of the minimum respiratory protection recommended by the National Institute of Occupational Safety and Health (NIOSH) for environments where lead is present, but respiratory protection is not required by the EPA regulations. In addition, disposable clothing, if removed and disposed of before the workers leave the work site, can provide additional protection for workers’ families by ensuring that no leaded dust or debris is carried home on worker clothing. However, EPA does not require this and allows renovators to use other methods to ensure that dust and debris does not leave the work area, including the HEPA vacuuming of clothing, tools, and other items before they leave the work area.

Question Number: 23002-15698

My firm is replacing windows on the second floor of a 90-year-old home. The windows are built into a bay that projects out from a steeply pitched slate roof. When setting up exterior containment for this job, does the RRP Rule require me to install plastic on the roof under the windows?

No. The RRP Rule does not require you to install plastic sheeting on the roof. You must cover the ground with plastic sheeting or other disposable impermeable material in accordance with the containment requirements at 40 CFR 745.85(a)(2).

Question Number: 23002-19757

When replacing an unpainted roof, sometimes sections of paint-covered lumber under the roof need to be removed as well. If my firm removed damaged lumber from only certain sections of the roof, does only this area need to be contained while we fix the lumber?

Yes. The renovation firm is responsible for containing the work area so that no dust or debris resulting from the disturbance of a painted surface leaves the work area while the renovation is being performed. Containment is not required for portions of the renovation outside this area that do not disturb painted components.

Question Number: 23002-23858

To avoid harming the homeowner’s grass and landscaping, may my firm fold up the plastic sheeting used for containment at night and re-use it the next day?

Yes, as long as your firm does so in a way that contains any dust and debris on the plastic. One way to accomplish this is to collect and remove the paint chips and debris from the plastic sheeting at the end of each day, mist the sheeting and fold it dirty side inward.

Question Number: 23002-20687

When I replace windows, I set up interior vertical containment barriers that extend from floor to ceiling and completely enclose the interior area in which I physically work. If these barriers are set up at a distance less than six feet from the perimeter of the work surface, must I still extend the containment on the floor beyond the vertical barrier to meet the six-foot requirement?

No, provided that the vertical containment system consists of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls (40 CFR § 745.85(a)(2)(i)(D)). This type of vertical containment acts as the functional equivalent of a wall for purposes of defining the work area. If the vertical containment meets these criteria the floor containment measures may stop at the edge of the vertical barrier.

Unlike permanent walls, however, vertical containment barriers are subject to all containment cleaning requirements including misting, inward folding, sealing, and proper disposal following the renovation. A firm must also thoroughly clean an additional two feet beyond the vertically-contained work area. Finally, during ingress or egress from the vertical enclosure, a firm must take precaution to ensure that dust and debris on personnel, tools, and other items do not escape the work area.

Question Number: 23002-23786

What, if any, additional requirements or liabilities exist if a homeowner independently removes the protective barriers and containment measures implemented by the firm during a renovation?

Before a firm begins a renovation, they are required to comply with all information distribution requirements under the RRP Rule and to post signs that clearly define the work area and warn occupants and other persons not involved in renovation activities to remain outside of the work area. A firm that fails to comply with these requirements is liable under the RRP Rule.

If, however, a firm does comply with these requirements and a homeowner or other person nevertheless removes the barriers, a firm must cease renovations until the necessary containment measures are re-established. A firm should also take additional steps to warn occupants or other persons of the dangers of entering the work area or removing barriers.

Question Number: 23002-23675

My firm removes and replaces windows from the exterior of a building or residence. To contain dust in the work area, we cover the entire interior surface of the window with impermeable plastic sheeting and affix the sheeting to the surrounding interior wall. This creates a pocket, accessible only from the exterior, from which the window is removed and replaced. All removal and replacement work is performed from the exterior, and we still apply the exterior containment measures as provided in the RRP Rule. Does the interior containment method described meet the requirements under the RRP Rule?

No. Although EPA encourages your firm to continue to use this method of supplemental containment, the minimum requirements of the RRP Rule must still be met. Specifically, the floor surface must be covered with taped down plastic sheeting or other impermeable material six feet the perimeter of the work surface, or a distance sufficient to contain the dust, whichever is greater. Alternatively, your firm can install vertical containment measures as described more fully in frequent question 23002-23786.

Question Number: 23002-19758

If I mist and HEPA vacuum the plastic sheeting used by my firm for interior containment, can I move and re-use plastic sheeting on the same day and job?

No. The RRP Rule does not contemplate a permissible method of moving and re-using plastic sheeting used for interior containment.

Question Number: 23002-18500

My firm replaces windows. Various obstacles make it difficult to set up the 10-foot exterior ground containment in a way that would enable our renovators to perform the work and still effectively contain dust. In these cases, we lay the ground containment, but also use vertical containment measures to completely enclose the area in which we work. Is this a permissible method of exterior containment? If the vertical containment is set up at a distance of less than 10 feet from the work surface, must we still extend the ground containment beyond the vertical barrier to meet the 10-foot requirement?

The work practices for exterior projects are based on a performance standard -- the work area must be contained so that dust or debris does not leave the work area while the renovation is being performed. EPA recognizes that proper use of exterior vertical containment measures may be a more effective method for containing the work area than use of the traditional ground containment alone, as outlined in the regulations.

With proper techniques, a firm may meet the performance standard by using vertical containment in conjunction with ground containment. Vertical containment means a vertical barrier consisting of plastic sheeting or other impermeable material over scaffolding or a rigid frame, or an equivalent system of containing the work area (40 CFR § 745.83). Properly constructed vertical containment, for example, might consist of a rigid box-like framework wrapped in impermeable plastic sheeting and anchored to the ground and home. When placed on top of ground containment, such containment should effectively limit the travel of dust and debris to the interior of the enclosure. Whatever construction techniques are used, the containment must completely isolate the work area and prevent any dust and debris from leaving the work area to satisfy the performance standard.

If exterior vertical containment is erected at a distance of less than 10 feet from the work surface, the ground containment need not necessarily extend the full 10 feet. Ground containment measures may stop at the edge of the vertical barrier when using a vertical containment system.

Question Number: 23002-32208

Under the RRP Rule, in exterior containment if a large tree or shrub is within the work area can the plastic be placed around the base and would the plant, however large, also need to be covered?

The RRP Rule does not specifically address containment of trees or shrubs, but if dust, debris or residue remains in the tree or shrub at the conclusion of the job, the site will not pass visual inspection. The work practices for exterior projects are based on a performance standard -- the certified renovator or a worker under the direction of the certified renovator must contain the work area so that dust or debris does not leave the work area while the renovation is being performed. In addition, at the end of the job, a certified renovator must perform a visual inspection to determine whether dust, debris or residue is still present on surfaces in and below the work area, including window sills and the ground. If dust, debris or residue is present, these conditions must be eliminated and another visual inspection must be performed.

Question Number: 23002-20753

The RRP Rule provisions require exterior containment. At what point is the wind too strong to allow work to continue?

The work practices for exterior projects are based on a performance standard -- the certified renovator or a worker under the direction of the certified renovator must contain the work area so that dust or debris does not leave the work area while the renovation is being performed. The certified renovator is responsible for determining when the wind is so strong that no form of containment is adequate to keep dust or debris from leaving the work site, and therefore work must stop until conditions improve such that containment can be maintained.

Question Number: 23002-20640

Prohibited & Restricted Practices

How do RRP requirements apply to pressure washing? What containment and other preparation are required?

Pressure washing is not a prohibited practice under the RRP Rule. Pressure washing is subject to the same containment requirements as other permissible work practices. Before beginning the renovation, the firm must isolate the work area so that no dust or debris (including in the wastewater) leaves the work area while the renovation is being performed. In addition, the firm must maintain the integrity of the containment by ensuring that any plastic or other impermeable materials are not torn or displaced and taking any other steps necessary to ensure that no dust or debris leaves the work area while the renovation is being performed. The firm must also ensure that containment is installed in such a manner that it does not interfere with occupant and worker egress in an emergency.

In addition, it is important to properly dispose of wastewater used during pressure washing. Check with your local water treatment authority for more information.

Question Number: 23002-17026

My firm drills a series of 1/2-inch diameter holes in sheet rock to dry it out where rooms have been flooded. Is drilling these holes a prohibited practice?

No. The requirement for HEPA exhaust control does not apply to the use of all power tools. Specifically, HEPA exhaust control is not required when using a power drill to drill holes in sheetrock. When using a power drill with a drill bit to cut through sheetrock, the speed associated with the contact between the bit and the paint is not of the same magnitude as the contact speed generated by the machines identified in the regulation. The RRP Rule prohibits the use of machines designed to remove paint or other surface coatings through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting or sandblasting, is prohibited on painted surfaces 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. These machines must be operated so that no visible dust or release of air occurs outside the shroud or containment system.

Question Number: 23002-19748

Waste from Renovations

Why are gloves, which are exposed to large amounts of lead dust, not required to be disposed of under the RRP Rule?

The RRP Rule requires the renovation firm to use precautions to ensure that all personnel, tools and other items are free of dust and debris before leaving the work area. Workers with contaminated clothing can take that contamination home to their own children, and taking contaminated equipment to another jobsite could potentially create a lead hazard at a new site. There are several ways of ensuring that gloves and other clothing are free of dust and debris before leaving the work area. For example, tacky mats may be put down immediately adjacent to the plastic sheeting covering the work area floor to remove dust and debris from the bottom of the workers' shoes as they leave the work area. If workers wear shoe covers, they may remove them as they leave the work area. Clothing and materials may be wet-wiped and/or HEPA-vacuumed before they are removed from the work area.

While the rule does not specifically address gloves, if they are contaminated with lead dust or debris that cannot be removed, EPA recommends that they not be removed from the work site during the job and that they be disposed of as part of final cleanup.

Question Number: 23002-24833

Under the RRP Rule, what type of container is adequate for on-site storage of debris? Must the container be covered and locked? Must it be placed behind a locked barrier?

At the conclusion of each workday and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to dust and debris. Using a covered container is one way to prevent release of dust and debris. Locking the container and placing it behind a locked barrier are good examples of ways to prevent access to the dust and debris.

Question Number: 23002-20763

Can non-certified workers transport debris off site under the RRP Rule if they have had documented on-the-job training in this activity by the certified renovator?

Yes. The RRP Rule requires the certified renovator to regularly direct the work being performed by other individuals to ensure that the work practices are being followed, including ensuring that dust or debris does not spread beyond the work site. The certified renovator is responsible for providing training to non-certified workers on the work practices they will be using in performing their assigned tasks, including transporting waste off site.

Question Number: 23002-14730

How should lead-containing wastes from RRP renovations be handled and disposed?

While at the work site, wastes must be collected at the conclusion of each work day and at the conclusion of the renovation and stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to dust and debris.

Similarly, while transporting the waste out of the work site for disposal or storage, waste must be contained to prevent releases of dust and debris.

Finally, contractors may dispose of lead-containing wastes from residential renovations in a municipal solid waste landfill (MSWLF) or a municipal solid waste combustor. Dumping and open burning of residential lead-based paint waste is not allowed.

Note: As a general matter, all debris, paint chips, dust, and sludges that exceed the toxicity characteristic regulatory limit of five mg/L lead in the waste leachate are considered “hazardous” and subject to more stringent RCRA hazardous waste management and disposal requirements. However, pursuant to 40 65 CFR 261.4(b)(1), household wastes (i.e., those derived from households) are excluded from the universe of RCRA hazardous wastes. In 2000, EPA issued a memorandum clarifying that the household hazardous waste exclusion applies to waste generated by either contractors or residents performing lead-based paint activities (abatement) or renovations in residences. Wastes from non-residential renovations may still be subject to RCRA hazardous waste requirements.

Question Number: 23002-33373

Under the RRP Rule, how should I dispose of contaminated water used in two-bucket mopping?

EPA recommends contacting your local water treatment authority and asking about local requirements for handling and disposing of wastewater.

Question Number: 23002-20756

Cleaning the Work Area

The RRP Rule requires HEPA vacuums to be used for cleaning up the dust created by renovations. What should I look for when purchasing a HEPA vacuum?

According to the definition in 40 CFR 745.83:

"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."

Therefore, renovation firms should look for a vacuum cleaner that was designed to be operated with a HEPA filter, rather than a shop vacuum that can be fitted with a HEPA filter in place of the original basic filter. A vacuum retrofitted with a HEPA filter is not necessarily properly sealed or designed so that all of the intake air goes through the HEPA filter. EPA also recommends that renovation firms ask the manufacturer or retailer whether the machine has been tested to ensure that it achieves the high efficiency required of a HEPA filter (capturing 99.97% of 0.3 micron particles).

Question Number: 23002-20634

Under the RRP Rule, do paint chips and debris need to be removed from protective sheeting prior to misting, removing, folding and sealing the sheeting even if such chips and debris can be effectively contained by the sheeting or the sealed container the sheeting is contained in for disposal?

Yes. After the renovation has been completed, the firm must clean the work area until no dust, debris, or residue remains. The first cleaning step required by the RRP Rule is to collect all paint chips and debris and, without dispersing any of it, seal this material in a heavy-duty bag. The purpose of this step is to prevent accidental spreading of lead-contaminated paint chips and dust off of the protective sheeting. Only when this step is completed may you remove the protective sheeting, following the directions specified in the rule.

Question Number: 23002-20761

If a renovator uses the required practices to remove containment and clean a work area, then performs successful cleaning verification, can the balance of the project then be done using uncertified workers and without reference to the work practices required by the RRP Rule?

Yes, as long as the balance of the project can be completed without disturbing a painted surface.

Question Number: 23002-18385

When waste from renovations has been removed from the work area and placed in on-site storage, may the waste be stored in a covered waste container or must it all be bagged for disposal?

Properly implemented, either option can meet the requirements of the RRP Rule. At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to dust and debris. Storing the waste in a covered waste container is one way to meet this requirement if the waste container prevents release of dust and debris. Containing the waste in closed trash bags can also prevent release of dust and debris. Locking the dumpster and placing it behind a locked barrier are good examples of ways to prevent access to the dust and debris.

Question Number: 23002-23884

Are components removed from the home to be cleaned up and reused subject to the waste handling requirements in the rule?

While components to be reused rather than disposed of are not considered waste for the purposes of the RRP Rule, it is likely that, even if they do not contain lead-based paint, they are contaminated with dust or debris from the project. The renovation firm must use precautions to ensure that these components are free from dust and debris before they are removed from the work area. EPA also recommends that these materials be stored on-site or transported off-site in a way that prevents access to dust and debris or release of dust and debris.

Question Number: 23002-13864

Who is responsible for controlling dust and debris from renovation waste once the waste container or truck used to transport the waste leaves the renovation site?

When a renovation firm transports waste from renovation activities, the firm must contain the waste to prevent release of dust and debris. The RRP Rule does not address the responsibilities of other entities. EPA recommends consulting with state and local waste disposal authorities to learn about any additional requirements.

Question Number: 23002-24718

For purposes of cleaning the work area following a renovation, is the interior floor of a garage considered interior or exterior space?

In general, the interior floor of a garage is considered an interior space for purposes of post-renovation cleanup. EPA recognizes the fact that it may occasionally be impossible for firms to meet all of the cleaning and verification requirements under the RRP Rule for garage floors such as those that are composed of dirt or gravel. In such a case, EPA recommends that a firm document and keep records of the specific circumstances surrounding the impossibility. A firm must also make their best effort to collect and remove all paint chips, dust, debris and residue. Furthermore, a firm must still comply with all feasible work practice standards and take precautions to ensure that the work area is properly contained.

Question Number: 23002-15872

My firm has signed a contract to replace the windows on a pre-1978 home. We have tested for the presence of lead-based paint and found the results to be positive. However, the homeowner has already scraped and repainted their house but did not follow lead-safe work practices. The result of their activity is paint chips scattered throughout the landscaping. How best should I proceed?

A firm working on a property that is already contaminated with paint chips, dust, debris and residue must proceed by containing the work area for the renovation and complying with all cleaning requirements under the RRP Rule for that work area. Paint chips, dust, debris and residue that fall within the work area must be eliminated. If paint chips, dust and debris exist beyond the work area, but were not a product of the firm's window replacement activities, EPA recommends that the firm document and keep record of the conditions.

Question Number: 23002-31780

Cleaning Verification

Under the RRP Rule, is composite sampling acceptable for post-renovation dust-lead testing in lieu of cleaning verification?

Yes. Under the RRP Rule, cleaning verification need not be performed if the contract between the renovation firm and the person contracting for the renovation or another federal, state, territorial, Tribal or local law or regulation requires:

The renovation firm to perform post-renovation dust-lead testing at the conclusion of a renovation covered by this subpart
The post-renovation dust-lead samples are required to be collected by a certified inspector, risk assessor or dust sampling technician
The renovation firm is required to re-clean the work area until the post-renovation dust-lead testing results are below the action levels in 40 CFR 745.227(e)(8) or any applicable state, territorial, tribal, or local standard

Post-renovation dust-lead testing must be performed following the procedures in 40 CFR 745.227(e)(8), which allow the use of composite sampling. Not all laboratories will analyze composite samples, so check with your laboratory before collecting them. Typically, interior clearance is achieved by means of dust wipe sampling by a certified inspector or risk assessor using single surface dust wipes. This is required on all HUD jobs.

Question Number: 23002-20755