# presumed lead, now what?



## lilpaintchic

I just took the RRP course and was told that sometimes it's best to presume vs. test. 1932 2 story victorian style house, exterior, peeling everywhere. Presumed lead. Trying to be in compliance but how the heck am I supposed to work on this?!? I need a lift to get up and over some of the areas and old growth foliage. Not trying to restore it, just lipstick and it goes up for sale. Trying to provide a mid range job on it..remove failing paint, no sanding, prime and paint.
The problem: containment of water runoff while pressure washing. Is there an inexpensive way of doing this? What do you guys use? And how do you convince your crews to wear the gear when it's 87 degrees and climbing and still get any work done? How much extra (roughly) should these protective measures cost on average?

Does anyone have any pics that would be helpful?


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## Gough

lilpaintchic said:


> I just took the RRP course and was told that sometimes it's best to presume vs. test. 1932 2 story victorian style house, exterior, peeling everywhere. Presumed lead. Trying to be in compliance but how the heck am I supposed to work on this?!? I need a lift to get up and over some of the areas and old growth foliage. Not trying to restore it, just lipstick and it goes up for sale. Trying to provide a mid range job on it..remove failing paint, no sanding, prime and paint.
> The problem: containment of water runoff while pressure washing. Is there an inexpensive way of doing this? What do you guys use? And how do you convince your crews to wear the gear when it's 87 degrees and climbing and still get any work done? How much extra (roughly) should these protective measures cost on average?
> 
> Does anyone have any pics that would be helpful?


What gear is that? RRP has no requirements for personal protection. 

From what I've been able to find, EPA seems to have left the was water issue up to the states. It was a big deal a number of years ago, but the last time I tried to find information online, it always led me back to local regulators.


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## DeanV

Epa: must be contained and dumped down a toilet. No storm drains or into ground. I 

Local waste water: toilet ok if lead ppm below some threshold. 








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## lilpaintchic

Tyvek suit, gloves taped up, respirator...yada yada yada..I think I got it worked out...visquine pool and straw waddles.

So are you suggesting that we don't have to wear the PPE while scraping? It's not required for washing (that I know of) but for dry disruption it is, right? I'm still new to this horse dookie EPA crap...


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## Gough

lilpaintchic said:


> Tyvek suit, gloves taped up, respirator...yada yada yada..I think I got it worked out...visquine pool and straw waddles.
> 
> So are you suggesting that we don't have to wear the PPE while scraping? It's not required for washing (that I know of) but for dry disruption it is, right? I'm still new to this horse dookie EPA crap...


EPA doesn't require tyvek suit, gloves, respirators...none of that.

If you've got employees, you should take a look at OSHA. Depending on the amount of lead they're exposed to, your employees might need some level of PPE. That determination is made after initial air monitoring.

Respirators are a whole other kettle of fish....


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## journeymanPainter

When I did some lead prep(wasn't a full removal ) a few years ago we had respirators, tyvex suits, and gloves at all times.


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## Gough

journeymanPainter said:


> When I did some lead prep(wasn't a full removal ) a few years ago we had respirators, tyvex suits, and gloves at all times.


JP, here in the states, there are two different governing bodies (at least) when it comes to dealing with lead paint. Personal protective equipment for employees falls under the purview of OSHA. They have rules for working around lead paint in general, and another set of rules for respirators. The level of PPE required is based on on-site air monitoring. The air monitoring results from of our jobs have shown that PPE hasn't been required.

The much-maligned RRP rule is administered by the EPA (in most states). That rule is concerned about lead contamination of job sites during the regulated activities. It is silent about PPE.


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## lilpaintchic

So, to be clear, we don't need the tyvek and respirators on an exterior if we're not changing the air quality (sanding) on the job site? We'll be putting up containment walls off the sides of the house (out about 6 ft and straight down and ground cover 10ft out) and containing water runoff. There will be a hand washing station and gloves are required...not much (if any)dust though...with exception to sanding over some bondo in a few spots, but that's just Bondo not the existing finish...


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## journeymanPainter

Gough said:


> JP, here in the states, there are two different governing bodies (at least) when it comes to dealing with lead paint. Personal protective equipment for employees falls under the purview of OSHA. They have rules for working around lead paint in general, and another set of rules for respirators. The level of PPE required is based on on-site air monitoring. The air monitoring results from of our jobs have shown that PPE hasn't been required.
> 
> The much-maligned RRP rule is administered by the EPA (in most states). That rule is concerned about lead contamination of job sites during the regulated activities. It is silent about PPE.


I know, just letting the OP know what I had to do. Was it helpful? Maybe, was it safer than no ppe? definitely


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## lilpaintchic

It was helpful jp, I want my guys (and myself) to be in compliance and safe. It just seems like in some cases, it's more risky to be bubble wrapped (tyvek, resp, etc.) And working on a 32 than the risk of lead exposure...so if it's not required,and it's safe, I don't want the added distraction and discomfort.


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## lilpaintchic

And ty dean, I wasn't aware that we can dump it in the toilet...we're going to soak up the water with straw waddles and cut em up and bag em with the rest of the trash...thanks guys for responding to this post...I'm not on here much but when I am I always get good ideas from others who are actually doing this stuff in the field...I appreciate you sharing your experiences.


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## Gough

journeymanPainter said:


> I know, just letting the OP know what I had to do. Was it helpful? Maybe, was it safer than no ppe? definitely


Not to be argumentative, but...not necessarily, although it may have been in your case. Depending on the worksite conditions and engineering practices (what steps you take to control exposure), suiting up the crew in Tyvek and respirators can certainly be more dangerous than having them go without.


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## journeymanPainter

Gough said:


> journeymanPainter said:
> 
> 
> 
> I know, just letting the OP know what I had to do. Was it helpful? Maybe, was it safer than no ppe? definitely
> 
> 
> 
> Not to be argumentative, but...not necessarily, although it may have been in your case. Depending on the worksite conditions and engineering practices (what steps you take to control exposure), suiting up the crew in Tyvek and respirators can certainly be more dangerous than having them go without.
Click to expand...

Oh, very true....especially on an exterior in the summer. 

They definitely need to do some serious research into better procedures into removal of lead paint/products from a building.


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## Gough

lilpaintchic said:


> So, to be clear, we don't need the tyvek and respirators on an exterior if we're not changing the air quality (sanding) on the job site? We'll be putting up containment walls off the sides of the house (out about 6 ft and straight down and ground cover 10ft out) and containing water runoff. There will be a hand washing station and gloves are required...not much (if any)dust though...with exception to sanding over some bondo in a few spots, but that's just Bondo not the existing finish...


It's not just a simple matter or sanding or no sanding, scraping can stir up enough dust to cause problems as well. The air monitoring is done on some of the employees and it can clear you from having to use some or all of the PPE. 

Here are some links that should be helpful. Just a heads up, they do make RRP look like a walk in the park.

Lead in Construction:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10641

This covers air monitoring, medical (blood testing), record-keeping, and a host of other topics. 

Respirator use:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=12716,


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## lilpaintchic

JP, who is "they"? I assume you're referring to the governing bodies? If so I AGREE!! The methods that appear to be the "norm" are ridiculous and down right dangerous in exterior applications. "They" want my ladder on top of the visquine that I'm getting wet with a pressure washer from 32 feet above. Might work great if you're in an office at your desk writing procedures and protocol, but on the side of a house with slippery hands because they don't make gloves small enough and the tyvek suits are wayyy too big (i'm 5 ft 1 and female, thus the smaller hands)...now add a respirator and did i mention the whole dang thing needs to be enclosed with plastic and its 8 am and 87 degree already...."THEY" are gonna kill me!!!


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## LA Painter

The only true containment to cover the entire house. :thumbsup:


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## lilpaintchic

Good idea LA! go through all of that only to sit on your couch with your contaminated clothes, including gloves, and drink beer. Why didn't I think of that?! Thanks for sharing...thanks for the house pics...what is that membrane called?


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## Gough

LA Painter said:


> The only true containment to cover the entire house. :thumbsup:


LA, I know your post was partly tongue in cheek, but we've actually used that first approach. For some major whole-house stripping (not abatement), we've waited until the off season and wrapped our scaffolding in Visqueen.

That does at least double duty. It takes care of vertical containment and it lets us do the work when the weather is cooler. It also lets us do some labor-intensive jobs in the off season, which can help even out the schedule.


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## MikeCalifornia

Work is work, but IMHO I think it sucks to just do a quick scrape prime and paint to sell a house like the one you describe, and trust me I am not blaming you. I don't know your area, but a house like a 30's victorian should get the full treatment. Sellers and agents are doing no service to the new buyer who will ultimately have to pay more money down the road to repair what is not getting done today. As a buyer I would always be weary to the "recently painted" claim. 

I have a client who purchased a home one year ago, it had just gotten a quick spray to make it look good. One year later and it is peeling from the cheap paint used, *cough* *cough* HD. The painter tried to hide the crappy fascia by skim coating with spackle, at least 1/16" to 1/8" and it is falling off the old wood. This is one of my peaves with realtors.


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## slinger58

LA Painter said:


> The only true containment to cover the entire house. :thumbsup:


I miss old Walt and Jesse.


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## lilpaintchic

I feel ya Mike. I work for a construction Co. Though...we want him to spend the $on the remodel on his new place and give the new place the full deal inside and out.


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## LA Painter

slinger58 said:


> I miss old Walt and Jesse.



Me tooooooo!


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## lilpaintchic

so the straw wattles are a MESS!! what do you guys use to contain/soak up the water runoff?


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## AV Painting

You don't have to contain water runoff


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## Gough

AV Painting said:


> You don't have to contain water runoff


We first read about EPA requiring us to contain and filter wash water containing lead paint residue years ago. Since then, they seem to have left the enforcement to local jurisdictions. Some do, some done.


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## DeanV

AV Painting said:


> You don't have to contain water runoff



I called the epa to ask. They said to contain. Maybe they changed their mind but the epa and class said to. 


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