Attention Owners of Historic Homes or Any Homes Built Before 1978!
You likely know about the lead hazard that may be in your home, but were you aware of the EPA’s Renovation, Repair and Painting
(RRP) Final Rule (40 CFR 745)? This rule REQUIRES that people that you hire to work in your pre-1978 home be a Certified Firm using Certified Renovators as of April 22, 2010. Certified Renovators will have completed an EPA-accredited renovator course to ensure that they know all of the rules and regulations necessary to make their work Lead Safe.
But what about the Do-It-Yourself homeowner? A homeowner is under no obligation to follow the RRP rule for work they do themselves, but still has the safety of themselves and their family to consider. With that in mind, here are some tips to help reduce the risk of exposure from repairs done in your home.
First off, to educate yourself about lead and what is to be expected of a contractor in your home, please read the EPA’s Lead-Safe Certified Guide to Renovate Right, found here: http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf
Before you start work it will be necessary to contain the area. Depending on the scope of your project, containment can range from plastic sheeting on the floor to creating a full enclosure. If possible, all objects and furniture should be removed from the room or covered well with plastic sheeting. Windows should be closed and covered with plastic sheeting. Similarly, all ducts and doors should be closed and sealed with plastic sheeting and tape. Turn off the AC so that it doesn’t cause dust to be moved around or sucked into the duct work.
For interior work, plastic sheeting should be laid on the floor six feet out in all directions from where the work is being performed. To limit the area that will need to be cleaned at the end of the project; you may wish to create a containment system using one of the several varieties of compression pole systems on the market. These systems use poles to attach plastic sheeting tight to the ceiling. You can place the poles to create a work space around your project area to reduce the cleanup area and prevent unnecessary contamination. The compression fit eliminates the need for taping plastic to the walls, and doesn’t leave marks or scrapes.
Entrance into the work area should be restricted to only those people doing the work. Place signs, barrier tape and/or cones to keep all non-workers, especially children, out of the work area. Keep pets out of the work area for their safety and to prevent them from tracking dust and debris throughout the home. To create a door into the work area cut and secure one layer of sheeting to the perimeter of the doorframe. Do not pull the sheeting taut. Rather, create a few folds to leave slack at the top and bottom of the door before taping or stapling. Cut a vertical slit in the middle of the sheeting leaving 6” uncut at the top and bottom. Reinforce with tape. Cut and secure a second, overlapping layer of sheeting to the top of the door.
Once you have established containment around the work area, now you need to think about protecting yourself. Protective gear necessary when working with lead includes:
Protective eye wear
Disposable Painter’s hat
Disposable N-100 rated respirator
Disposable latex/rubber gloves
Disposable shoe covers
These items should be worn at all times when inside the work area. At the end of the work period, vacuum off dust and remove disposable protective clothing covers. Do not use compressed air to blow dust off disposable protective clothing covers or clothing. DO NOT hug or come into contact with other people until you have taken off your work clothes and cleaned up. It is also important that you wash your hands and face when you take a break to eat, drink, or smoke.
Safe Work Practices
Materials for all jobs:
- 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 cleaner (a special vacuum cleaner that can remove very small particles from floors, window sills, and carpets and not return them to the air)
- Heavy duty plastic bags
- Tack pads (large, sticky pads that help remove dust), paper towels, or disposable wipes
Other tools that may be needed:
- Low-temperature heat gun (under 1,100 degrees Fahrenheit)
- Chemical strippers without methylene chloride
- Power tools with HEPA filter equipped vacuum attachments
What To Do
Use the right tools.
- Use wet sanders and misters to keep down the dust created during sanding, drilling and cutting.
- Use HEPA vacuum attachments on power sanders and grinders to contain the dust created by these tools.
- When a heat gun is needed to remove paint, use a temperature setting below 1,100 degrees Fahrenheit.
Use work practices that minimize dust.
- Mist areas before sanding, scraping, drilling and cutting to keep the dust down (except within 1 foot of live electrical outlets).
- Score paint with a utility knife before separating components.
- Pry and pull apart components instead of pounding and hammering.
- Keep components that are being disposed of in the work area until they are wrapped securely in heavy plastic sheeting or bagged in heavy duty plastic bags. Once wrapped or bagged, remove them from the work area and store them in a safe area away from residents.
Control the spread of dust.
- Keep the work area closed off from the rest of the home.
- Don’t track dust out of the work area: Stay in the contained work area and on the contained paths.
- Vacuum off suits when exiting the work area so the dust stays inside the work area.
- Every time you leave the plastic sheeting, remove your dispos¬able shoe covers, and wipe or vacuum your shoes, especially, the soles, before you step off the plastic sheeting. A large disposable tack pad on the floor can help to clean the soles of your shoes.
- Launder non-disposable protective clothing separately from family laundry.
Do Not Use Prohibited Practices.
The Renovation, Repair and Painting Rule prohibit the use of some dangerous work practices by contractors. These “Prohibited Practices” are:
- Open-flame burning or torching of lead-based paint.
- The use of machines that remove lead-based paint through high-speed operation such as sanding, grinding, power planing, abrasive blasting or sandblasting, unless such machines are used with a HEPA exhaust control.
- Operating a heat gun on lead-based paint at temperatures greater than 1,100 degrees Fahrenheit.
Keep it clean.
- Pick up as you go. Put trash in heavy-duty plastic bags.
- Vacuum the work area with a HEPA vacuum cleaner frequently during the day and at the end of the day.
- Clean tools at the end of the day.
- Wash up each time you take a break and before you go home.
- Dispose of or clean off your personal protective equipment.
- Continue to separate the work area from the rest of the home and remind residents to stay out of the area.
When the job is complete, renovators and do-it-yourself homeowners should:
- Remove plastic sheeting carefully, fold it with the dirty side in, tape it shut, and dispose of it.
- Make sure all trash and debris, including building components, are disposed of properly.
- Vacuum all surfaces, including walls, with a HEPA vacuum cleaner.
- Mist and scrub the work area with a general-purpose cleaner on a wet rag or mop, changing the rinse water often until dust and debris are removed.
- Vacuum all surfaces again once they are dry.
- Visually inspect your work. Look around the home, both inside and out. You should not be able to see any dust, paint chips or debris.
- Re-clean the area thoroughly if you find dust or debris.
What about the trash? Do I need to dispose of everything as hazardous waste?
- Because EPA considers most residential renovation and remodeling as “routine residential maintenance,” most waste generated during these activities is classified as solid, non-hazardous waste, and should be taken to a licensed solid waste landfill. This is not the case for work done in commercial, public or other nonresidential child-occupied facilities, where waste may be considered hazardous and require special disposal methods. See the following link for further information: www.epa.gov/lead/pubs/fslbp.htm.
- Water used for cleanup should be filtered and dumped in a toilet if local rules allow. If not, collect it in a drum and take it with you. Never dump this water down a sink or tub, down a storm drain, or on the ground. Always dispose of waste water in accordance with federal, state and local regulations.
- EPA’s Web site has state information on solid and hazardous waste disposal. See the following link for further information: http://www.epa.gov/epawaste/wyl/stateprograms.htm.
- Always check state and local requirements before disposing of waste. Some are more stringent than federal regulations.