# Finally taking on a lead job



## 6126

I could use some help here. I took the class over a year ago and was intimidated by the protocol, and decided I would stick with post '78 jobs. After turning down quite a few jobs over the last year I decided I would give this a shot. So now I am reading through the book I got from the class, plus another I ordered a few months ago, and doing research online. I know several of you are doing plenty of this work so any suggestions would be appreciated. The job is an exterior built in the 40s. Siding, windows, trim around windows and corner boards were replaced 10 or 15 years ago. Facia is original and positive for lead. Peeling is minimal on facia. Im curious if I can pressure wash siding if I stay away from facia? The detached garage is a different story. Its peeling and every component tests positive. The way I understand the rules, RRP will apply since its on the property of the dwelling. No pressure washing, put plastic down, and baricades and signs in place. Correct? I also looked at another job yesterday built in the 50s. Again, positive for lead. I was looking at a HEPA Vac yesterday in the paint store for $700 and I guess I have no choice but to pick one up. Anyway, my first question is the house. Im not sure if I can pressure wash it or not? As I mentioned, the facia is the only original part and paint is still holding up, been painted over several times and the lead is under the existing coatings.


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## aaron61

On the EPA's website they say you cannot pressure wash.Although it really doesn't make sense to me since it does rain on the house and like you said most of the lead is under the newer paint.


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## 6126

Thanks Aaron. I saw you in American Paint Contractor along with a few other PT members. Congrats. ') I was curious since only the facia contains lead and the paint isnt peeling. Have you had to wash any of these yet? From what I understand. even with hand washing I still need to contain the water. Might be a good idea to throw some Emulsa Bond in with the first coat along with mildewcide.


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## Dean CRCNA

gutters on the fascia?

It is fine to pressure wash non-lead based paint surfaces.


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## PressurePros

The issue with EPA laws is that they cannot think of every scenario and the interpretation is up to the enforcing officer. Looking like you are doing your best for containment can go a long way.


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## 6126

Dean CRCNA said:


> gutters on the fascia?
> 
> It is fine to pressure wash non-lead based paint surfaces.


Yes, a little bit of gutters


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## 6126

Only the facia contains lead. The rest was replaced a few years back


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## RCP

aaron61 said:


> On the EPA's website they say you cannot pressure wash.Although it really doesn't make sense to me since it does rain on the house and like you said most of the lead is under the newer paint.


Aaron, do you have a link to that?
Everything I have read says pressure washing is not considered renovation, but the discharge water is subject to state water laws. Kind of lame, I think.
What defines pressure washing? A certain psi? Does washing with a garden hose mean pressure washing? 



> 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 waste water) 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 waste water used during pressure washing. Check with your local water treatment authority for more information.


Source


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## RCP

Mike, look around for a vac, here is one for half the price. Check SW as well.
There are several links for supplies in a sticky in the lead section here.

In my state, which has also taken over RRP, they are very helpful, if you have a local office, call them and ask them to help you write a plan. 

Check and see if your state has a rule on pwing.


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## RCP

Oh, and congrats on taking the plunge, I think!


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## 6126

RCP said:


> Mike, look around for a vac, here is one for half the price. Check SW as well.
> There are several links for supplies in a sticky in the lead section here.
> 
> In my state, which has also taken over RRP, they are very helpful, if you have a local office, call them and ask them to help you write a plan.
> 
> Check and see if your state has a rule on pwing.


 Washington is very helpful too. I spoke to a guy there a coiple weeks ago and he said they were trying to come up with a solution for pressure washing.


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## aaron61

I am wrong. Here is what I found http://toxics.supportportal.com/ics/support/default.asp?deptID=23019

I find this a complete joke http://toxics.supportportal.com/ics/support/default.asp?deptID=23019 This basically states that the ho is not responsible for hiring a certified contractor so again making this a prime example of ensentavising a ho to NOT hire a certified contractor.Why pay the extra cost if you could care less about lead.Let the contractor carry all the burden.If they changed this one section then everything would and an ho would not think twice about hiring a firm that is not certified.


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## Different Strokes

Woodland I wish u good luck buddy. I agree with the above. They want to see you make an effort to comply. Too many contractors completely ignoring the rules to bother with a guy showing some concern. I will continue to turn down the work myself lol.


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## 6126

Thanks. We will see how I do on this one. I will be doing all the paperwork, and following the required procedures.


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## Dean CRCNA

Just as a personal exercise, I thought I would do a plan based upon your info.

I would get them to sign the signature receipt for renovate right.

I would make sure that I have copies of the renovate right signature page, lead test page, certified firm and certified renovator on site.

I would train workers that haven’t been trained before. I would do this as you are actually doing containment, so you are not wasting time. I would complete the worker training forms and keep a copy on site.

As far as EPA is concerned, you don’t have to wear PPE (mask, disposable suits, booties and etc.). Personally, I probably would wear a mask on the garage though. Just me. OSHA is a different story.

Also realize that you don’t have to put up barricades, yellow warning tape or whatever. Do so if you wish.

GARAGE

On the garage, I would make sure all doors and windows are closed. Would make plans not to go into garage, so I could avoid putting up plastic over entry/exit door.

Put out warning sign.

Put down plastic on ground 10 feet out surrounding garage. Tape plastic to the garage in a couple of spots.

Scrape or do whatever, to prep old paint.

Use two mop system with sponges to hand wash garage or you can use disposable wipes.

Collect paint chips and debris, put it into heavy duty plastic bag and seal. Put on truck, so you don’t have to worry about storage on property.

Mist plastic and fold inwardly. Put in heavy duty plastic bag and seal.

Do visual.

Remove warning signs.

Complete recordkeeping form. Give homeowners copies of all forms.

End RRP

MAIN HOUSE

Hopefully the disturbing of paint on fascia is less than 20 sq ft and RRP won’t be required.

Hand wash fascia and gutters with two mop system. Since you aren’t disturbing, no RRP.

Do the rest of the main house and garage like you normally would do.

End

Note1: Plastic moves around in wind and could kill grass, so take precautions.
Note2: Did this fast, so others should correct me.


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## 6126

Thanks so much Dean. Im going to see how this job goes and a couple more, then decide if I want to continue to do RRP. I am starting to see a possible good market here once I get familar with the routines. Not sure if Im surprised or not, but not a single one my competitors bidding against me on any of these older homes is mentioning Lead or RRP Rule to the client. I am the only one. Im thinking as enforcement gets better I could have a new area of work to add to what I already do. I added $1000 to cover the extra procedures which I hope is enough.. I have all the paperwork filled out and in the truck. When I am done I will keep it. They ask for 3 yrs, but I generally keep everything indefineatly. On the subject of plastic, I believe the ask for 7 mil? All the had at the paint store yesterday was 6. Allthough there is no grass around the garage I was also curious about the grass on future jobs since Im not in the habit of using plastic on grass. I generally use drops but also havent dealt with lead til now. Clear will kill grass faster right? White or black? On the house, the gutters have been replaced and tested neg. The facia is only peeling on one side. Its only for inches so if Im correct it would take 60 linear ft to make 20sq ft? Also yesterday, another painter mentioned 20sq ft per side? I was under the impression it was 20ft for the whole job. Anyway, I did wash the house yesterday and stayed away from all facia regardless of whether it was peeling or not. Im still on decided on the garage now for paint removal. I had considered Peel Away One since it has no Methaline Cloride (Im sure I spelt that wrong  ) But have never used it and its not cheap.


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## RCP

I thought it was 20 per side as well, just looked at code and it is total.
Here are some other points you might find helpful.


> (ii) Exterior renovations . The firm must:
> 
> (A) Close all doors and windows within 20 feet of the renovation. On multi-story buildings, 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.
> 
> (B) Ensure that doors within the work area that will be used while the job is being performed are 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.
> 
> (C) 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.
> 
> (D) In certain situations, the renovation firm must take extra precautions in containing the work area to ensure that dust and debris from the renovation does not contaminate other buildings or other areas of the property or migrate to adjacent properties.
> 
> (3) Prohibited and restricted practices. The work practices listed below shall be prohibited or restricted during a renovation as follows:
> 
> (i) Open-flame burning or torching of lead-based paint is prohibited.
> 
> (ii) The use of machines that remove lead-based paint through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, is prohibited unless such machines are used with HEPA exhaust control.
> 
> (iii) Operating a heat gun on lead-based paint is permitted only at temperatures below 1100 degrees Fahrenheit.
> 
> (4) Waste from renovations —(i) 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. If a chute is used to remove waste from the work area, it must be covered.
> 
> (ii) 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.
> 
> (iii) When the firm transports waste from renovation activities, the firm must contain the waste to prevent release of dust and debris.
> 
> (5) Cleaning the work area . After the renovation has been completed, the firm must clean the work area until no dust, debris or residue remains.


Source


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## NCPaint1

What about dry ice blasting instead of power washing or sanding? Would that comply with RRP. It seems that this would be the most efficient, and overall cheapest method to deal with lead....if it complies.

It seems that if this was compliant, it would be a great spin-off company, specializing in RRP prep. Not a cheap startup by any means, but lots of potential.


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## Dean CRCNA

Woodland,

The law doesn't specify thickness of plastic. They only talk about making sure no cuts in plastic, so go at least thick enough to not create holes.

Clear plastic burns grass faster than black or white, from what I've found out.


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## Dean CRCNA

NCPaint1 said:


> What about dry ice blasting instead of power washing or sanding? Would that comply with RRP. It seems that this would be the most efficient, and overall cheapest method to deal with lead....if it complies.
> 
> It seems that if this was compliant, it would be a great spin-off company, specializing in RRP prep. Not a cheap startup by any means, but lots of potential.


Thought about that too, but they see dry ice blasting the same as sand blasting.


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## NCPaint1

Dean CRCNA said:


> Thought about that too, but they see dry ice blasting the same as sand blasting.


Thats odd, because its not removing any material, there's no runoff, and gravity takes care of the rest :blink: Maybe they need an actual demonstration done :whistling2:


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## Paintuh4Life

Woodland said:


> Washington is very helpful too. I spoke to a guy there a coiple weeks ago and he said they were trying to come up with a solution for pressure washing.


Did they say flat out you can't pressure wash? Here is what Washington State Regulations say: "(ii) Uncontained hydro blasting or high-pressure washing of lead-based paint is prohibited"

My last job we put plastic down, (duct taping it to the foundation and hanging plastic from the gutters) applied Jomax with my pressure washer's downstream chemical injector, rinsed it with very low pressure, and captured all the water with buckets and big sponges.( about 15 gallons per side) and flushed it down the toilet, as per local regulations. Did I do something wrong here? I don't think I did. The process was contained and we did not use high pressure.


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