# What is the RRP?



## NEPS.US

*40 CFR PART 745 -*
*Lead; Renovation, Repair, and Painting Program final rule*


_*What Is the Lead-Based Paint Renovation, Repair andPainting Program (RRP)?*_



1. The Lead-Based Paint Renovation, Repair and Painting Program is a 
federal regulatory program affecting contractors,property managers, and 
others who disturb painted surfaces.

2. It applies to residential houses, apartments, and child-occupied 
facilities such as schools and day-care Centers built before 1978.

3. It includes pre-renovation education requirements as well as 
training, certification, and work practice requirements.

3.1. Pre-renovation education requirements are effective now:

3.1.1. Contractors, property managers, and others who perform renovations 
for compensation in residential houses, apartments, and child-occupied 
facilities built before 1978 are required to distribute a lead pamphlet 
before starting renovation work.

3.2. Training, certification, and work practice requirements become 
effective April 22, 2010:

3.2.1. Firms are required to be certified, their employees must be trained 
in use of lead-safe work practices, and lead-safe work practices that 
minimize occupants' exposure to lead hazards must be followed.

4. Renovation is broadly defined as any activity that disturbs painted 
surfaces and includes most repair, remodeling, and maintenance activities, 
including window replacement.

5. The program includes requirements implementing both Section 402(c) 
and 406(b) of the Toxic Substances Control Act (TSCA). 
(www.epa.gov/lead/pubs/titleten.html)

6. EPA's lead regulations can be found at 40 CFR Part 745, Subpart E.


_*What Happens if the Agency Discovers a Violation?( reprinted directly from *_
_*EPA literature!)*_



EPA uses a variety of methods to determine whether businesses are complying, 
including inspecting work sites, reviewing records and reports, and 
responding to citizen tips and complaints. Under TSCA, EPA (or a state, if 
this program has been delegated to it) may file an enforcement action 
against violators seeking penalties of up to $32,500 per violation, per day. 
The proposed penalty in a given case will depend on many factors, including 
the number, length, and severity of the violations, the economic benefit 
obtained by the violator, and its ability to pay. EPA has policies in place 
to ensure penalties are calculated fairly. These policies are available to 
the public. In addition, any company charged with a violation has the right 
to contest EPA's allegations and proposed penalty before an impartial judge 
or jury.




*What Are the Recordkeeping Requirements?*

1. All documents must be retained for three years following the 
completion of a renovation.

2. Records that must be retained include:

2.1. Reports certifying that lead-based paint is not present.

2.2. Records relating to the distribution of the lead pamphlet.

2.3. Any signed and dated statements received from owner-occupants 
documenting that the requirements do not apply (i.e., there is no child 
under age 6 or no pregnant woman who resides at the home, and it is not a 
child-occupied facility).

3. Documentation of compliance with the requirements of the Lead-Based 
Paint Renovation, Repair, and Painting Program (EPA has prepared a sample 
form that is available at www.epa.gov/lead/pubs/samplechecklist.pdf).


_*What Does the Program Require Me To Do?*_
_*Pre-renovation education requirements - Effective now.*_

1. In housing, you must:

1.1. Distribute EPA's lead pamphlet to the owner and occupants before 
renovation starts.

2. In a child-occupied facility, you must:

2.1. Distribute the lead pamphlet to the owner of the building or an 
adult representative of the child-occupied facility before the renovation 
starts.

3. For work in common areas of multi-family housing or child-occupied 
facilities, you must:

3.1. Distribute renovation notices to tenants or parents/guardians of the 
children attending the child-occupied facility. Or you must post 
informational signs about the renovation or repair job.

4. Informational signs must:

4.1. Be posted where they will be seen;

4.2. Describe the nature, locations, and dates of the renovation; and

4.3. Be accompanied by the lead pamphlet or by information on how parents 
and guardians can get a free copy (see page 31 for information on obtaining 
copies).

5. Obtain confirmation of receipt of the lead pamphlet (see page 23) 
from the owner, adult representative, or occupants (as applicable), or a 
certificate of mailing from the post office.

6. Retain records for three years.

. Note: Pre-renovation education requirements do not apply to emergency 
renovations.


Emergency renovations include interim controls performed in response to a 
resident chil
with an elevated blood-lead level.


_*Training, Certification, and Work Practice Requirements- Effective after *_
_*April 22, 2010*_.

1. Firms must be certified.

2. Renovators must be trained.

3. Lead-safe work practices must be followed. Examples of these 
practices include:

3.1. Work-area containment to prevent dust and debris from leaving the 
work area.

3.2. Prohibition of certain work practices like open-flame burning and 
the use of power tools without HEPA exhaust control.

3.3. Thorough clean up followed by a verification procedure to minimize 
exposure to lead-based paint hazards.

4. The training, certification, and work practice requirements do not 
apply where the firm obtained a signed statement from the owner that all of 
the following are met:

4.1. The renovation will occur in the owner's residence;

4.2. No child under age 6 resides there;

4.3. No woman who is pregnant resides there;

4.4. The housing is not a child-occupied facility; and

4.5. The owner acknowledges that the renovation firm will not be required 
to use the work practices contained in the rule.



*What Are the Responsibilities of a Certified Firm?*

_*Firms performing renovations must ensure that:*_


1. All individuals performing activities that disturb painted surfaces on 
behalf of the firm are either certified renovators or have been trained by a 
certified renovator.

2. A certified renovator is assigned to each renovation and performs all of 
the certified renovator responsibilities.

3. All renovations performed by the firm are performed in accordance with 
the work practice standards of the Lead-Based Paint Renovation, Repair, and 
Painting Program (see the flowchart on page 9 for details about the work 
practice standards).

4. Pre-renovation education requirements of the Lead-Based Paint Renovation, 
Repair, and Painting Program are performed.

5. The program's recordkeeping requirements are met.


*What Are the Responsibilities of a Certified Renovator?*

Certified renovators are responsible for ensuring overall compliance with 
the Lead-Based Paint Renovation, Repair, and Painting Program's requirements 
for lead-safe work practices at renovations they are assigned. A certified 
renovator (see the flowchart on page 9 for details about the work practice 
standards):


1. Must use a test kit acceptable to EPA, when requested by the party 
contracting for renovation services, to determine whether components to be 
affected by the renovation contain lead-based paint (EPA will announce which 
test kits are acceptable prior to April 2010. Please check our Web site at 
www.epa.gov/lead).

2. Must provide on-the-job training to workers on the work practices they 
will be using in performing their assigned tasks.

3. Must be physically present at the work site when warning signs are 
posted, while the work-area containment is being established, and while the work-area cleaning is 
performed.

4. Must regularly direct work being performed by other individuals to ensure 
that the work practices are being followed, including maintaining the 
integrity of the containment barriers and ensuring that dust or debris does 
not spread beyond the work area.

5. Must be available, either on-site or by telephone, at all times 
renovations are being conducted.

6. Must perform project cleaning verification.

7. Must have with them at the work site copies of their initial course 
completion certificate and their most recent refresher course completion 
certificate.

8. Must prepare required records.


----------



## aaron61

I'm lost with this????Please explain??? To my knowledge,#4, the "Opt out", is not an option after 4-22.


----------



## NEPS.US

aaron61 said:


> I'm lost with this????Please explain??? To my knowledge,#4, the "Opt out", is not an option after 4-22.


I copied that from a enviriomental company that is teaching the class for the PDCA and Benjamin Moore.


----------



## NEPS.US

EPA link

http://www.epa.gov/lead/pubs/renovation.htm


----------



## daArch

OK, to answer more appropriately 

From all the tidbits that have been posted here, it seems obvious to me that there are a lot of inconsistencies, changing laws, and different opinions. I think (and this is only my opinion) that we each need to educate ourselves and when we find something of an official nature, post it here like Chris did so that the more lazy of us  can benefit. 

I think that there will be much confusion amongst the trades, the teachers, and the enforcers. Let's hope the dust settles quickly and we will have a clear cut path that we can follow. The new laws will be onerous enough to follow. Having the existing confusion added to that is going to make it REALLY hard - and I think it will irritate a few people :whistling2:

My training course will be April 28th and I hope after that I will understand better this whole thing. 

Perhaps one sensible course of action IS to stay away from target housing until everyone is on the same page.


----------



## ewingpainting.net

Do know what agency would be enforcing it in your state?


----------



## Slingah

That opt out is not final as I have read it (everywhere).....looking to see what happens after the 22nd.
Maybe someone can post something by the EPA that says otherwise.


----------



## ewingpainting.net

My question about if epa rolling up on the job was serious. I would like to know if any one has experience dealing with the epa????


----------



## daArch

ewingpainting.net said:


> Do know what agency would be enforcing it in your state?


In Mass, from what I hear, the state will be taking over the program in the summer. I have not heard explicitly which agency will be enforcing. But the state does have Environmental Police. I do know that they are over burdened and under staffed at the moment. Perhaps this will be a way to boost their budget and staffing


----------



## NEPS.US

ewingpainting.net said:


> Have you ever had the EPA roll up on one of your jobs? If so. Did you sing praises to them?


I have called the EPA to come and inspect a job I was bidding to ask how to handle the situation legally. 

I've done the same with OSHA.


----------



## CApainter

ewingpainting.net said:


> Do know what agency would be enforcing it in your state?


ewing, it looks like there are several established agencies currently enforcing
cal/EPA laws. Do you know which one it is? Thanks

http://www.calepa.ca.gov/Enforcement/WhoEnforces.htm


----------



## ewingpainting.net

I have only dealt with AQMD, I don't work on asbesto projects. Cali we have been dealing with this for years. I know I don't touch it. I would want to know who enforces it if I were looking into it. Sometimes you can talk to them. 
.
NEPs, what agency came out when you called EPA?
OSHA has been on a few of my jobs as well as the EDD.


----------



## NEPS.US

ewingpainting.net said:


> I have only dealt with AQMD, I don't work on asbesto projects. Cali we have been dealing with this for years. I know I don't touch it. I would want to know who enforces it if I were looking into it. Sometimes you can talk to them.
> .
> NEPs, what agency came out when you called EPA?
> OSHA has been on a few of my jobs as well as the EDD.


 
They actually just forwarded me to the state BOH and a rep came out to look at the project. I just got some basic information that helped with my bid. I lost the bid.


----------



## vermontpainter

No matter how we feel about the regulations, we have to make choices. Everyone has different levels of interest in doing this type of work (disturbing lead), from: absolutely none, to when the situation is right, to "I'll take any work I can get." No matter what your interest level is, it would benefit you to do it legally, educate yourself and your crew about what that means, and educate the homeowner. From there, the (lead) chips can fall where they may. 

My belief is that there are 3 levels involved with RRP: contractor, epa enforcement, and homeowners choices. The best that the contractor and the epa can do is to educate homeowners to choose to do business with legal companies, and accept the reality that it costs more to do business legally. I was interviewed this morning by my local CBS news affiliate for a RRP story and said exactly that, among other things.


----------



## NEPS.US

I have found myself scrambling this week to get into a class ASAP because of several Gov't bids pending. I have my Firm application ready to go in the mail on monday and have my class set for the 14th. The gov't jobs I am bidding are "lead free" buildings but I am required to have my cert's. I am also finding that with the bids I have due from now until the end of April that there are still very few qualified contractors bidding. 

EPA and OSHA cert's will most likely be a requirement for most commercial, industrial and govt work in the days to come. This will be a good thing.


----------



## vermontpainter

daArch said:


> BTW, were the "other things" airable on family TV ????


Yes! I fall into the middle category. I only want to be legal to do lead disturbance work in the course of existing relationships I have with builders and homeowners. I'm not changing my business to do more or less of this type of work, just the same as before, only in compliance, because the laws (regardless of enforcement levels) have sharp teeth. 

As neps noted, it is a good thing if in any way at all it eliminates some of the non qualified painters from situations they have no business being in anyways.


----------



## RCP

Scott, post a link to the interview please!

Neps is right, there is a lot of misinformation out there, most comes from the trainers interpetations of the information on the EPA website.

To see the actual rule, which is kept updated, go here.

Be sure to check your state as well, some states are taking over the RRP and using the rule as a minimum, and adding!

You can also go 



 and here for some consumer info.


----------



## ewingpainting.net

I'm on the same page a you. To many contradicting post flying around. At the end your still responsible wether you know the law or not. So best get the facts right. And I wasn't aiming at you NEPs.


----------



## daArch

I think I've said the same.

We need to help keep each other EDUCATED. The laws are changing, so let's try to post the most up to date quotes (from "reliable" sources) that we can. 

RCP Chris has been real good about providing the links. Together we can get through this. 

Sheet, we'll prolly know more than the trainers, testers, and enforcers.


----------



## RCP

You guys are right, there is a lot of misinformation on the RRP Rule. 
It is our responsibility (like it or not) to become informed and responsible.

So I cleaned up the thread, maybe we could keep it limited to links and 
resources and start new threads on procedures and brainstorming.

We could move the state information and enforcement questions to a new thread, as wells as items like Scotts interview and media resources.

Thanks!


----------



## RCP

Sean at SLS has the best grasp of anyone else I have read.
Here is his blog.
http://blog.sls-construction.com/?tag=rrp-countdown-consequences


----------



## johnthepainter

EDIT: _As per your and 
gabe's wishes this was edited as it sounded disrespectful_


----------



## johnthepainter

yes i agree, my last post was tinted with sarcasm.

here is my concern>

why should anyone listen to other painters regarding rrp, and not their instructors?

i understand that when people relay information, things get fuzzy.

are the links you provide experts? instructors? (links other than epa)

this is where misinformation starts.


----------



## daArch

I believed the strategy here is to post links to known authoritative sources. 

The link to the SLS blog appears to be filled with authoritative quotes. We need to be careful when we post our own opinions and interpretations of the law. Now, since I have not taken the course, it would not be best if I posted "facts" about what is taught. 

You are correct that when people relate info, things get altered a bit - like the parlor game, "telephone"


----------



## RCP

John, one of the links I posted was the official updated rule, the EPA website is not updated.
The trainers use these instructions for the training, from the EPA site.

Most of the misinformation comes from the instructors, many who are Lead Abatement Instructors and they include Abatement and OHSA rules into the training.
They are following a script from the EPA that they often interpet differently. Many contractors I have spoken too report being told things that are different than the rule states, for instance, the wearing of tyvek suits and booties.

All I am saying, is read the rule itself and follow that.


----------



## Dean CRCNA

I personally would listen to what RCP (Chris) says. There are a small group of individuals (contractors) who have really dealt deep into understanding the ruling. RCP is one of them.

Who is an authoritative person? I have several cases where EPA contradicts EPA. I fully understand that a veteran of this new law is one who has only months of experience. This is because we've only been really hearing about this for only a few months.

The 8 hour training class will help. However, you will find that each trainer will teach different things. You will also find that the training book you will receive during class ... has things that the rule doesn't include.

In my mind, the authoritative voice would be (from greatest to least) ...

1. The rule itself

2. The EPA (even though they contradict each other).

3. Certain contractors that have really studied on this subject (like the blog and RCP).

4. Trainers

5. Certified Renovators

6. Non-Certified Renovators

Ultimately, it is the contractor's butt that is in the fire. The buck stops with us. I would rather trust a well studied contractor any day.

My 2 cents, which isn't worth much


----------



## NEPS.US

Your 2 cents is worth plenty. Thanks for coming back.:thumbsup:


----------



## ewingpainting.net

You could throw in a few more!


----------



## Dean CRCNA

Thanks Ewing & Neps

I do think links to authoritative sites is a good practice and I don't expect pros (like everyone here) to blindly follow someone. I agree with others (and their post) about making sure we separate fact from fiction ... and making sure it is facts (not fiction).

For us contractors, we are about to break into April ... with the date of compliance only a few weeks away. In my mind, it is time to begin looking at reality of "how do we make this work".

It is also a good time to find out ... "what we can do and what we can't do" (as far as the RRP). We got to find that balance between being legal + being profitable.

I'm surrounded by smart RRP folks (from the organization). From multiple trainers ... to construction lawyers (that know RRP) ... to environmental consultants ... to abatement companies ... to an enforcement agent.

It doesn't mean I'm smart though 

I'm more than willing to answer question about the rule and to provide the best links I can find to support the answers.

If I don't know the answer ... I will secretly email RCP to find what the correct answer is


----------



## Dean CRCNA

Slingah said:


> That opt out is not final as I have read it (everywhere).....looking to see what happens after the 22nd.
> Maybe someone can post something by the EPA that says otherwise.


You are correct. The Opt-Out is still in the updated rule found at http://ecfr.gpoaccess.gov/cgi/t/tex...gn=div5&view=text&node=40:30.0.1.1.13&idno=40

*However*

Sierra Club sued EPA to get the Opt-Out taken out. Because of a settlement to the suit (found here http://www.sierraclub.org/communities/lead/2009-08-24-epa-rrp-settlement.pdf) ... everyone knows that by April 22, 2010 ... the Opt-Out will disappear from the law.

_I know many of you knew about this, but just wanted to post some links to substantiate it._


----------



## Dean CRCNA

Some discussion about States.

Here is a good link to see what your state is doing http://www.healthyhomestraining.org/RRP/State.htm

_The organization the info comes from, basically holds hands with the EPA, so I personally believe the info to be good._


----------



## RCP

Thanks Dean.

Anyone check on the availability of the Test Kits?

I had asked SW to stock up as they had not planned on carrying them.
Hearing "on the net" that they are not available right now.


----------



## aaron61

RCP said:


> Thanks Dean.
> 
> Anyone check on the availability of the Test Kits?
> 
> I had asked SW to stock up as they had not planned on carrying them.
> Hearing "on the net" that they are not available right now.


Can't you just use the ones that HD carries??

That's what our trainer was using.


----------



## Dean CRCNA

aaron61 said:


> Can't you just use the ones that HD carries??
> 
> That's what our trainer was using.


Suppose to be the "Professional" LeadCheck. The professional comes with a test strip inside.

http://www.epa.gov/lead/pubs/kits.htm


----------



## RCP

There is some confusion there, I'd have to go back to the EPA site and Rule site to be sure. I think in the rule it calls it the Leadcheck Pro.
But that is the only company (for now) approved by the EPA.
They are accepting applications from Vendors to be approved until next month and there may be a change in September.


----------



## RCP

Thanks Dean, that is it, but the kit on the site does not say "Professional", do you have any info on that? 

Are the ones Aaron posted ok? Are they available?


----------



## johnthepainter

Dean CRCNA said:


> Suppose to be the "Professional" LeadCheck. The professional comes with a test strip inside.
> 
> http://www.epa.gov/lead/pubs/kits.htm


dean crnca, 

how am i supposed to believe anything you say?

im not trying to start anything or be disrespectful, but this is misinformation as far as i know. our instructor had 3 he had us use, and said they were approved.

this is what im talking about fellow pt members, whan you have people making stuff up.

they will tell you not to listen to YOUR instructor, but listen to these other fellas, and supply links to their blogs.

i would suggest reading this rule yourself, and quit taking advice from most of these so called experts.

rcp, this is not directed at you in any way. but i think you can see my point.


----------



## aaron61

So we have 22 days to comply & we can't readily purchase test kits WTF
This gets more rediculous every day1


----------



## RCP

high fibre said:


> dean crnca,
> 
> how am i supposed to believe anything you say?
> 
> im not trying to start anything or be disrespectful, but this is misinformation as far as i know. our instructor had 3 he had us use, and said they were approved.
> 
> this is what im talking about fellow pt members, whan you have people making stuff up.
> 
> they will tell you not to listen to YOUR instructor, but listen to these other fellas, and supply links to their blogs.
> 
> i would suggest reading this rule yourself, and quit taking advice from most of these so called experts.
> 
> rcp, this is not directed at you in any way. but i think you can see my point.


I see your point very clearly, that is why I keep asking these questions.
Dean provided a link to the information on the EPA site where it states the one kit approved.
It is not specified in the rule.
So your instructor said there were three that were approved. This is where the misinformation starts. It would be great if you could verify that for us.
I would rather find out now than when the EPA is questioning my work.


----------



## johnthepainter

me? verify??


----------



## Dean CRCNA

high fibre said:


> dean crnca,
> 
> how am i supposed to believe anything you say?
> 
> im not trying to start anything or be disrespectful, but this is misinformation as far as i know. our instructor had 3 he had us use, and said they were approved.
> 
> this is what im talking about fellow pt members, whan you have people making stuff up.
> 
> they will tell you not to listen to YOUR instructor, but listen to these other fellas, and supply links to their blogs.
> 
> i would suggest reading this rule yourself, and quit taking advice from most of these so called experts.
> 
> rcp, this is not directed at you in any way. but i think you can see my point.


No problem.

If your instructor says 3 are approved ... and EPA (per link) says only 2 are approved (and we can't buy Massachusetts), I have no problem with you following your instructor.

If the EPA (per link) says to purchase the Professional LeadCheck and you want to buy the household lead check from Homax ... feel free.

I personally will stick with what EPA says, so I don't get one of those $30,000+ fines.


----------



## Dean CRCNA

High fibre ...

Buy the way, my EPA training instructor was an architect  Gave me that warm fuzzy feeling


----------



## aaron61

Where do you get the "professional"


----------



## Dean CRCNA

aaron61 said:


> Where do you get the "professional"


from http://www.epa.gov/lead/pubs/kits.htm (link I gave before)

_EPA recognizes that, when used by a certified renovator, the *Professional* LeadCheck® lead test kit can reliably determine that regulated lead-based paint is not present on all surfaces, except plaster and drywall._

The link on the EPA website takes you to LeadCheck.com. However, LeadCheck.com (Hybrivet Systems) have closed off their website. I've talked to Bud Evan (Hybrivet Systems) previous to this and he was working his butt off trying to keep up with demand. Guess it finally overtook him.

The Professional LeadCheck show it is "recognized" by EPA. A test kit has to be "recognized" by EPA to use it.

When you do any lead test, you need to identify the test kit in the records. If EPA ever audits your records (even 3 years later) and it is showing the wrong kit :no:

_On a side note, I do remodeling. Just wanted to mention this in case you guys thought I was a suit or something._


----------



## aaron61

Dean CRCNA said:


> from http://www.epa.gov/lead/pubs/kits.htm (link I gave before)
> 
> _EPA recognizes that, when used by a certified renovator, the *Professional* LeadCheck® lead test kit can reliably determine that regulated lead-based paint is not present on all surfaces, except plaster and drywall._
> 
> The link on the EPA website takes you to LeadCheck.com. However, LeadCheck.com (Hybrivet Systems) have closed off their website. I've talked to Bud Evan (Hybrivet Systems) previous to this and he was working his butt off trying to keep up with demand. Guess it finally overtook him.
> 
> The Professional LeadCheck show it is "recognized" by EPA. A test kit has to be "recognized" by EPA to use it.
> 
> When you do any lead test, you need to identify the test kit in the records. If EPA ever audits your records (even 3 years later) and it is showing the wrong kit :no:
> 
> _On a side note, I do remodeling. Just wanted to mention this in case you guys thought I was a suit or something._


Would it matter if your check shows positive and you follow all the correct proceedure for lead?


----------



## aaron61

That's funny, the houshold ones are made by the same company but not acceptable??? The must not cost as much.


----------



## RCP

aaron61 said:


> Would it matter if your check shows positive and you follow all the correct proceedure for lead?


Some states that are taking over the rule (link in post 31) require a Lead Abatement Company to take over if tested positive for Lead. But, if you do not test, you can continue by using Lead Safe Practices.
Florida is not taking over, so you are ok.


----------



## mr.fixit

just another way of sticking their hands into our pockets. typical government make things so convoluted nobody understands what their supposed to do or know


----------



## donnaepaint

Its not pretty and is going to change the way we do business. Just attended the 8 hr class last week $190. EPA states it will only increase project costs by $35 (B.S.) Here in oregon, the construction contractors board will possibly be doing the enforcing via EPA approval. its based on 1978 or older homes. To me its just a revinue catch for the government. Get this, when i asked the instructor " why did it take 20 years to accomplish this" he in turn said "theyve been working on this new statue for 18 years. The oregon ccb is going to possibly require all contractors to be cert. in order to renew their licence which i feel is a crock. To me it feels like their choosing where and how I do business. In my area theres not very many homes w/ lbp due to being painted over in the past. After the class I felt like the EPA was trying to make us as contractors liable for an existing condition, opening the door for lawsuits. Oh and dont forget about our liability insurance going up due to being a certified renovator via ccb requirement. Ultimately, the customer will have to absorb the cost in which instance more "scabs" will be doing the work w/ no accountability.


----------



## aaron61

donnaepaint said:


> In my area theres not very many homes w/ lbp due to being painted over in the past.


I don't think this means anything...When we were certified they required use to make a V cut into the paint revealing the substrate.So be painted over isn't a factor. IMHO


----------



## johnthepainter

the illegals are going to thrive.

i recently began a project, and the extra steps are very difficult to perform in the real world.

painting is one thing, but remodelers are going to have a lot to deal with.

containment during a big project is pretty tricky. plastic on floors, tape, more plastic, and worrying the entire time that youll be sued if some escapes is freaky.

i dont care how much you plastic off a room, dust makes its way into every room in a renovation.

just doze these health hazards over. please.


----------



## donnaepaint

Aaron61 its different than it used to be by far. The documentation and certification is much more stringent per project.


----------

