As you may already know, complying with the EPA's Lead Safe Renovation, Repair, and Painting (RRP) Rule goes beyond just attending the Renovator Training and certifying your company. How you actually perform the work is the most important part of compliance. In this blog series, we'll look at what implementation of RRP lead-safe practices looks like on a job site, beginning with the equipment necessary to properly perform the work.
Without the right equipment, it is nearly impossible to comply with the regulations and standards established by the EPA's RRP Rule. In this breakdown, we will go step-by-step through a typical RRP project, and list for you the necessary materials and equipment needed to stay compliant with this rule. We will follow the Steps to Lead Safe Renovation, Repair and Painting guide found in Appendix 5 of your RRP training manual.
STEP 1 - Determine If the Job Involves Lead-Based Paint:
If a home or child-occupied facility was built before 1978, all surfaces affected by a renovation covered by the Renovation, Repair and Painting Rule must either be tested for lead-based paint or presumed to contain lead-based paint. Testing must include all affected surfaces coated with paint, shellac, varnish, stain, coating or even paint covered by wallpaper, if it will be disturbed during the renovation work. A report documenting the testing must describe the test used, the surfaces tested, and the results of the testing. Materials needed for this first step include:
- EPA-recognized test kits, such as LeadCheck swabs
- Utility knife
- Nitrile gloves
- Plastic bag for all waste created during the testing process
- Wet rag for clean-up
When you work on a job with lead-based paint, you must contain the work area to prevent the escape of dust and debris. The goal of proper setup of the work area is to keep dust in the work area and non-workers out. Materials and equipment needed for this step of an RRP Project include:
- Warning signs
- Barrier tape, rope or fencing
- Cones
- Heavy duty plastic sheeting
- Masking, duct, or painter's tape
- Stapler
- Utility knife or scissors
- Rigid framing material if using vertical containment
Without the right personal protective equipment, workers may ingest or inhale lead from the job and may risk bringing lead from the worksite home to their families. The right personal protective equipment and good personal hygiene will help combat lead exposure. Personal protective equipment includes:
- Disposable coveralls
- Painter's hat
- Disposable N-100 rated respirator (at least)
- Disposable shoe covers
- Eye protection
- Work gloves
As you work, your goal is to keep the dust down. Remember that as you scrape, drill, cut, open walls, etc., you are creating dust. You can keep dust down by using the right tools and following some simple practices that minimize and control the spread of dust. Remember - work wet, work safe, work clean! Equipment and materials used during this process include:
- Wet-dry sandpaper, sanding sponge
- Misting bottle or pump sprayer
- Heavy plastic sheeting
- Utility knife or scissors
- Masking tape, duct tape, or painters’ tape
- High Efficiency Particulate Air (HEPA) vacuum
- Heavy duty plastic bags
- Tack pads (large, sticky pads that help remove dust), paper towels, or disposable wipes
The work area should be left clean at the end of every day and must be cleaned thoroughly at the end of the job. The area must be completely free of dust and debris before it can be cleared by the Certified Renovator assigned to the project. Cleaning materials for an RRP Project include:
- Heavy-duty contractor bags
- HEPA vacuum with attachments and a powered beater bar
- Masking tape, duct tape, or painters tape
- Misting bottle or pump sprayer
- Disposable wet-cleaning wipes or hand towels
- General-purpose cleaner
- Mop and disposable mop heads
- Two buckets or one two-sided bucket with a wringer
- Shovel and rake
- Wet Mopping System
- Electrostatically charged dry cleaning cloths
Waste from renovation activities must be contained to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal. Collect and control all your waste. This includes dust, debris, paint chips, protective sheeting, HEPA filters, dirty water, cloths, mop heads, wipes, protective clothing, respirators, gloves, architectural components and other waste. Equipment and materials needed for this step include:
- Heavy-duty contractor bags
- HEPA vacuum to clean outside of waste bags
- Always check local requirements!
When your interior renovation work is complete, you have to do one of two clearance tests to ensure you cleaned up the job by the RRP standards - either a Cleaning Verification (CV) Procedure, or a Dust Clearance Examination performed by a Lead Inspector, Risk Assessor, or Dust Sampling Technician. As an EPA Certified Renovator, you are only allowed to perform a Cleaning Verification (CV) Procedure, in which you will check for dirt and dust by taking “swipes” of all windowsills, countertops and floors in the work area and checking them against your CV Card. The difference between this CV Procedure and a Dust Clearance Exam, is that for a Dust Clearance Exam, these “swipes” are sent to an accredited NLLAP laboratory. For exterior projects, when work areas have passed the visual inspection, the project is complete and the area may be turned over to the occupants. For conducting the Clearance Verification Procedure for interior projects, you will need:
- A flashlight
- CV card (provided in class)
- Wet, disposable cleaning clothes
- Cleaning materials if the renovation firm fails the Cleaning Verification Procedure