# Lead Encapsulation



## CApainter

During a discussion on primers in another PT thread, the question of lead encapsulation came up. It was unclear what materials constituted an actual lead encapsulation that the EPA would recognize. After a little research, I discovered that the government agency HUD (Housing and Urban Development) has guidelines for lead encapsulation (Chapter 13, under Table of Contents) 

_"Residential paints, such as latex and alkyd-based paints and canvas-backed vinyl wallpaper, do not constitute encapsulant systems *unless they pass the patch test* (evaluating the encapsulant on a small area of the painted surface before the start of work) and meet the performance requirements of this 
chapter and any quantitative performance standards defined by ASTM or other local, State, or Federal agency. (See Section VI.A)"_

According to what I read in the guidelines, there are three classifications that include ASTM standards for liquid encapsulates, and a section on encasements. Basically, the guidelines _*do*_ recognize interior and exterior waterborne house paints (as a lead barrier), only if they can meet the HUD requirements. The requirements refer mainly to the structural assessment and preparation of the existing lead paint. For example:

-Has all the loose lead paint been removed?

-Can sanding be limited or or avoided altogether?

-Has a "Patch" been performed to determine if the paint of choice meets HUD requirements such as bonding, and the avoidance of harsh solvents that will degrade the existing lead painted surface?

Hopes this helps.


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## Epoxy Pro

Good to know. Now What about MA and RI who have their own lead rules for encapsulation? 
We have a few coming up this season. I am going to see what I can find and maybe add to this post.


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## DeanV

I believe to use encapsulating paint, you need abatement certification. RRP is not enough. In RRP class I know we were told regular paints are not encapsulants, but that does not mean the class was correct, especially if RRP is not sufficient to apply them anyway.


Above RRP really only involves limiting spread of lead dust, but does not imply anything about the existing lead paint, it makes sense that encapsulating and full abatement which are considered long term or permanent controls (I think that was the wording) fall under different training and classifications. 

As only RRP trained, I could not put paint over lead paint and call it encapsulated. Now, CApainter may have different training and be able to do so. 

To call something encapsulated implies a certain amount of long term protection from the lead. For an RRP painter to prep and paint over lead carries no such promise or guarantee.


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## CApainter

ASTM's web site offers encapsulating paint selection guidlines for what appears to be $42.00. I would have hoped this information would have been provided to the public for free. 

They're probably sponsored by BEHR! j/k


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## Epoxy Pro

DeanV said:


> I believe to use encapsulating paint, you need abatement certification. RRP is not enough. In RRP class I know we were told regular paints are not encapsulants, but that does not mean the class was correct, especially if RRP is not sufficient to apply them anyway.
> 
> 
> Above RRP really only involves limiting spread of lead dust, but does not imply anything about the existing lead paint, it makes sense that encapsulating and full abatement which are considered long term or permanent controls (I think that was the wording) fall under different training and classifications.
> 
> As only RRP trained, I could not put paint over lead paint and call it encapsulated. Now, CApainter may have different training and be able to do so.
> 
> To call something encapsulated implies a certain amount of long term protection from the lead. For an RRP painter to prep and paint over lead carries no such promise or guarantee.


This is one reason we use oil based primer over lead. I honestly wouldn't trust a latex to encapsulate lead, I know there is what's it called stop Lead or lead stop. I usually contact our local inspector and if he says a latex product will work and is with in the MA laws I may try it.


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## CApainter

cdpainting said:


> This is one reason we use oil based primer over lead. I honestly wouldn't trust a latex to encapsulate lead, I know there is what's it called stop Lead or lead stop. I usually contact our local inspector and if he says a latex product will work and is with in the MA laws I may try it.


According to the HUD guidelines, anything that may deteriorate the existing lead paint (like an organic solvent vehicle in alkyd paint for instance) may not be compliant. Strong solvents may cause lead leaching into the encapsulating coating.


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## CApainter

Chapter 11 "Interim controls" has excellent information concerning primers. Oil base was mentioned for its good adhesion because of the softening affect it has on existing coatings, but also mentions the solvent hazards. However, the solvent hazards were not in reference to lead leaching. I believe that was mentioned in Chapter 13.


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## CApainter

DeanV said:


> I believe to use encapsulating paint, you need abatement certification. RRP is not enough. In RRP class I know we were told regular paints are not encapsulants, but that does not mean the class was correct, especially if RRP is not sufficient to apply them anyway.
> 
> 
> Above RRP really only involves limiting spread of lead dust, but does not imply anything about the existing lead paint, it makes sense that encapsulating and full abatement which are considered long term or permanent controls (I think that was the wording) fall under different training and classifications.
> 
> As only RRP trained, I could not put paint over lead paint and call it encapsulated. Now, CApainter may have different training and be able to do so.
> 
> To call something encapsulated implies a certain amount of long term protection from the lead. For an RRP painter to prep and paint over lead carries no such promise or guarantee.


I don't have any special lead training other then what my employer provides me in terms of exposure and handling of lead. From what I read in the HUD guidelines, basic encapsulating paints like waterborne latex, does not require much beyond a low level skill worker if properly trained. Chapter 13 page 13-13:

_1. Skill Level 
Different levels of skill are required for application of the various classes of encapsulants. Generally, liquid non-reinforced coatings require the lowest skill level. Coatings having two components (requiring rapid, efficient application), or those incorporating a mat, require more experience and skill. Use of adhesively bonded materials, such as tile and flexible wall 
coverings, also require an intermediate skill level for application (HUD, 1990b). Overall, skills required for encapsulation are lower than those for enclosure and replacement. Nevertheless, specific knowledge and skills are critical for success in the application of any encapsulant. _

I believe that the guidelines currently in place for RRP certified painting contractors, basically resembles the HUD interim controls, and encapsulation, laid out in Chapters 11 and 13.

I think the term abatement, implies an entirely different approach that may in fact require higher levels of skills and possible certification.


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## DeanV

We were told for RRP I (being RRP certified) can train my own employees.

For the stuff you are talking, each employee must be trained as well, not just through the company. There was some additional level of training like that. I think it might also involve who has to be onsite. With RRP, a certified person must be involved with clearance and containment. But, can be gone at other times. I am not sure if the same applies to HUD and abatement. 

For HUD stuff, RRP is not sufficient. Some even question whether RRP is sufficient if the mortgage is through HUD.


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## RH

Interested to see what WB interior paint would pass the test. If it's prepped right I can encapsulate lead with ProMar200 eggshell? :thumbup:


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## Epoxy Pro

Looking at the dates of some of these write ups laws have changed. This is why I always call our lead inspector and do a walk thru with him before we start. We will do the same again and if he says Lead Stop is ok or othe latex primers in MA we will use it. I don't remember which oil primers he approved this past summer I have to go dig my notes out (I think it was Fresh Coat or First Coat). If the inspector says I can use a certain product I have to believe him and not some thing that was written 4 years ago. Especially since he will be the one stopping by and fining us if we re using the wrong product.


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## Epoxy Pro

DeanV said:


> We were told for RRP I (being RRP certified) can train my own employees.
> 
> For the stuff you are talking, each employee must be trained as well, not just through the company. There was some additional level of training like that. I think it might also involve who has to be onsite. With RRP, a certified person must be involved with clearance and containment. But, can be gone at other times. I am not sure if the same applies to HUD and abatement.
> 
> For HUD stuff, RRP is not sufficient. Some even question whether RRP is sufficient if the mortgage is through HUD.


This is another part of the law they need to update and be clearer on for us to understand fully. I was told to document any employees we train, I have my RRP license and as long as I'm on site during removal and disposal I just need to fill out the paper work and have the employee sign off saying I taught him the correct way according to local RRP laws. Same goes with a certified employee.


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## CApainter

cdpainting said:


> Looking at the dates of some of these write ups laws have changed. This is why I always call our lead inspector and do a walk thru with him before we start. We will do the same again and if he says Lead Stop is ok or othe latex primers in MA we will use it. I don't remember which oil primers he approved this past summer I have to go dig my notes out (I think it was Fresh Coat or First Coat). If the inspector says I can use a certain product I have to believe him and not some thing that was written 4 years ago. Especially since he will be the one stopping by and fining us if we re using the wrong product.


I would hope that HUD updates their site regularly given all the government employee resources at their disposal. Then again, it is the government (i.e. ACA). But its a great point to have a close RRP contact to update or answer any lead related concerns. We work with a Workplace Health and Safety/Hygiene department that doesn't always have the immediate answers we need. I trust that the EPA (RRP), OSHA, and HUD sites are fairly up to date.


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## RCP

CApainter said:


> I trust that the EPA (RRP), OSHA, and HUD sites are fairly up to date.


I wouldn't! This is the one that is updated.


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## CApainter

RCP said:


> I wouldn't! This is the one that is updated.


Does that mean you're exempt if a violation of compliance isn't officially posted?


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## Epoxy Pro

CApainter said:


> I would hope that HUD updates their site regularly given all the government employee resources at their disposal. Then again, it is the government (i.e. ACA). But its a great point to have a close RRP contact to update or answer any lead related concerns. We work with a Workplace Health and Safety/Hygiene department that doesn't always have the immediate answers we need. I trust that the EPA (RRP), OSHA, and HUD sites are fairly up to date.


The links you provided are dated 2010 at the bottom of the pages.
They need to post the new updates with the refined laws so we are not all confused by it. I know most of us here want to follow the law and it's hard if they do not post them.


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## RCP

CApainter said:


> Does that mean you're exempt if a violation of compliance isn't officially posted?


LOL, doubtful, but if it isn't posted, is it a rule?


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## CApainter

cdpainting said:


> The links you provided are dated 2010 at the bottom of the pages.
> They need to post the new updates with the refined laws so we are not all confused by it. I know most of us here want to follow the law and it's hard if they do not post them.


I agree. It's the responsibility of the government agencies to keep their sites updated. However, It's unlikely that any thing beyond minor tweaks to existing requirements will be added. The discussion in this thread addresses the question of encapsulation and what that constitutes. Unless someone can provide further evidence that regular latex interior paint _*can't *_act as a barrier over existing lead paint , I do not believe there are any RRP restrictions that prevent lead certified painters from performing this application.


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## Epoxy Pro

I know alot of you don't have a local inspector yet or they are just not around your area. We are lucky to have one who will come by the job to talk with us.
As for being exempt from rule changes that's doubtful. We are responsible for finding out the rule changes which again is difficult.


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## csv

I was under the impression that all loose paint must be removed, quality primer, two coats of latex paint, equals acceptable encapsulation. At least that's the way I read the guidelines for HUD financed homes.


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## Epoxy Pro

csv said:


> I was under the impression that all loose paint must be removed, quality primer, two coats of latex paint, equals acceptable encapsulation. At least that's the way I read the guidelines for HUD financed homes.


If you look t the dates on the HUD it's dated 2010, rules have changed as each state figures out how they want to deal with it.


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## Brian C

This is an old lead paint removal on a timber home. I used the paint shaver with my Festool dust extraction vacuum. We covered all the ground with drop sheets to capture any loose flakes. I then run over the boards with 60 grit then 100 grit sandpaper on my Festool sander with dust extraction hose connected.


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## Epoxy Pro

Looks good. We have a few to do this summer like this. Shave it down. Our Festool vacuum motor is crapping out on us. We just got it in August. I have to send it out and hope they get it back before the spring.


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## Brian C

Festool have a 2 year warranty. I would be getting it fixed promptly. My Festool vacuum is still going strong after 10 years. I use the disposable paper dust bags for this type of work.


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## Dean CRCNA

Dean V got it right.

There are many lead laws. For this conversation, I'll name 4 ...

1. HUD LSHR over $5,000 (Abatement and Interim) project cost, which takes additional training and certification other than RRP training and certification.

2. EPA Lead Abatement, which takes additional training and certification other than RRP training and certification.

3. HUD LSHR less than $5000 project cost, which RRP training can do.

4. EPA RRP renovations, repair and home improvement, which RRP Training can do.

Difference between Abatement and RRP is "intent". If the intent is to remove or encapsulate to get rid of lead paint or protection (encapsulation) from lead based paint ... it is abatement. If you are doing renovations, repair and home improvement ... it is RRP, even though you may remove lead based paint in the process. 

If a client ask you to remove or encapsulate lead based paint (intent) ... you can't do it with just RRP training.


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## Oden

I've never been certified or had any classes. I do encapsulate from time to time. My directions are always to not scrape or sand anything. as soon as you start knocking off the loose ur into a different ball game I guess. (I'll knock off some loose though if it's something that needs to look nice--windows I did a lot of come to mind) it's a easey weed really-when ur encapsulating exhisting in a old building-the G.C. Can't pick apart ur prep. There isn't any.


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## DeanV

Oden said:


> I've never been certified or had any classes. I do encapsulate from time to time. My directions are always to not scrape or sand anything. as soon as you start knocking off the loose ur into a different ball game I guess. (I'll knock off some loose though if it's something that needs to look nice--windows I did a lot of come to mind) it's a easey weed really-when ur encapsulating exhisting in a old building-the G.C. Can't pick apart ur prep. There isn't any.


It does not sound like your boss is operating legally at all in this area, Oden.


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## Jmayspaint

Oden said:


> I've never been certified or had any classes. I do encapsulate from time to time. My directions are always to not scrape or sand anything. as soon as you start knocking off the loose ur into a different ball game I guess. (I'll knock off some loose though if it's something that needs to look nice--windows I did a lot of come to mind) it's a easey weed really-when ur encapsulating exhisting in a old building-the G.C. Can't pick apart ur prep. There isn't any.



Never even any in house training? As an employee you don't necessarily have to be RRP certified, but you should get some training from someone who is.


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## Oden

I have even tested though. some jobs. Prior to and after. Never had anything show up really at all which contributes to my veiws on the whole lead paranoia. I think it is a crock. I think you really have to go out of ur way to get lead poisoned.


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## Gough

Oden said:


> I have even tested though. some jobs. Prior to and after. Never had anything show up really at all which contributes to my veiws on the whole lead paranoia. I think it is a crock. I think you really have to go out of ur way to get lead poisoned.


In 30+ years we've never repainted a house that didn't have lead paint. We could come close to predicting the actual levels by knowing the age of the house. I think the highest level we've found was 600,000 ppm or 60% lead. That doesn't mean that 60% of the paint was lead-based paint, that means 60% of the paint was lead! We're in the intermountain West, an area with younger housing stock that's not known for high incidence of LBP.


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## CApainter

Dean CRCNA said:


> Dean V got it right.
> 
> There are many lead laws. For this conversation, I'll name 4 ...
> 
> 1. HUD LSHR over $5,000 (Abatement and Interim) project cost, which takes additional training and certification other than RRP training and certification.
> 
> 2. EPA Lead Abatement, which takes additional training and certification other than RRP training and certification.
> 
> 3. HUD LSHR less than $5000 project cost, which RRP training can do.
> 
> 4. EPA RRP renovations, repair and home improvement, which RRP Training can do.
> 
> Difference between Abatement and RRP is "intent". If the intent is to remove or encapsulate to get rid of lead paint or protection (encapsulation) from lead based paint ... it is abatement. If you are doing renovations, repair and home improvement ... it is RRP, even though you may remove lead based paint in the process.
> 
> If a client ask you to remove or encapsulate lead based paint (intent) ... you can't do it with just RRP training.


What if the intent is to completely paint an interior or exterior of a house as part of an over all renovation? By virtue of coating the walls with paint, aren't you performing encapsulation per HUD's description of acceptable products and procedures? A quality latex paint over a liquid sanded surface is an example of what's acceptable.

It's more of an issue with semantics and the intended use of the word "encapsulation". EPA, HUD, and RRP need to make it more clear to painting contractors. Until then, I believe you can argue that a regular repaint can be considered a form of encapsulation based on HUD's Guidelines. Lumping abatement and encapsulation in the same category implies a more extreme approach to managing lead. Even HUD describes one who applies encapsulating paint as a low skilled worker that doesn't require much more training then any other painter.


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## Dean CRCNA

CApainter said:


> What if the intent is to completely paint an interior or exterior of a house as part of an over all renovation? ......


Abatement, including encapsulation, is understood as a permanent solution to eliminate lead based paint hazards. It has to last at a minimum of 20 years.

For most painters here, they will probably not be called on to perform abatement or encapsulation, since the person in charge would know to find an abatement company. However, you could be called upon to do paint stabilization, since you are RRP certified. 

You're right that normal painting could be understood as encapsulation, but not as far as HUD and EPA is concerned however.


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## CApainter

Dean CRCNA said:


> Abatement, including encapsulation, is understood as a permanent solution to eliminate lead based paint hazards. It has to last at a minimum of 20 years.
> 
> For most painters here, they will probably not be called on to perform abatement or encapsulation, since the person in charge would know to find an abatement company. However, you could be called upon to do paint stabilization, since you are RRP certified.
> 
> You're right that normal painting could be understood as encapsulation, but not as far as HUD and EPA is concerned however.


The following items captured from HUD's Lead Guidelines, Chapter 11: Interim Controls, suggests RRP Certified Renovators can in fact perform a form of encapsulation as indicated in item 4. 

1.)(Note that, if renovation or rehabilitation is the intention of the work, some or all of the component replacement may not be abatement, but may be conducted as an interim control.

2.)Interim control measures are fully effective only as long as they are carefully monitored, maintained, and, in some cases, professionally reevaluated. If interim contr ls are properly maintained, they can be effective indefinitely.

3.)(Abatement measures are either literally permanent, in the case of component removal, or are considered by Title X as being permanent because they last for at least 20 years, in the case of enclosure or encapsulation. These latter measures are “permanent” if they are maintained by establishing and implementing an ongoing lead-safe maintenance plan for at least 20 years, and, in the case of encapsulants, the products have a 20-year or longer warranty subject to the implemen­tation of the maintenance plan.

4*.)Enclosure or encapsulation without such an expected longevity and maintenance plan may be conducted as interim control measures.)*

My point all along is that painting interior walls with the intent of preventing exposure from a lead containing surface, may not be abatement, but as an interim control, can be considered a form of acceptable encapsulation albeit, not a permenent fix.


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## vermontpainter

CA

Since this discussion is taking place on painttalk, you would be remiss not to consider the following critical questions:

Will your company pay cash up front or use a charge acct to purchase the materials to be used for interim encapsulation?

Will your painters be wearing whites during said procedure?

When painting walls, will you roll first and then cut? 

What is your favorite kind of brush for interim encapsulation work?

Will the paint used for said interim encapsulation be BM, SW or Bare?

Will you use 18" rollers to expedite the interim encapsulation, or do you find them to be too fatiguing?

What type of footwear shall be in play during the interim encapsulation?

What is the going rate for this type of work?

Will the workers performing the work be subcontractors or payrolled employees?

What types of insurances are required for this type of work?

What safety measures will be in place during the interim encapsulation?


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## Gough

vermontpainter said:


> CA
> 
> Since this discussion is taking place on painttalk, you would be remiss not to consider the following critical questions:
> 
> Will your company pay cash up front or use a charge acct to purchase the materials to be used for interim encapsulation?
> 
> Will your painters be wearing whites during said procedure?
> 
> When painting walls, will you roll first and then cut?
> 
> What is your favorite kind of brush for interim encapsulation work?
> 
> Will the paint used for said interim encapsulation be BM, SW or Bare?
> 
> Will you use 18" rollers to expedite the interim encapsulation, or do you find them to be too fatiguing?
> 
> What type of footwear shall be in play during the interim encapsulation?
> 
> What is the going rate for this type of work?
> 
> Will the workers performing the work be subcontractors or payrolled employees?
> 
> What types of insurances are required for this type of work?
> 
> What safety measures will be in place during the interim encapsulation?


Hardly a comprehensive list. For example, you said nothing at all about the music being played during the course of the work, either content or mode of delivery (MP3, streaming, or vintage vinyl).


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## CApainter

I'm just another Andy Dufresne, chipping away at the RRP rules and regulations. Concealed under the provocative pose of PT, in my attempt at escape.


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## vermontpainter

CApainter said:


> I'm just another Andy Dufresne, chipping away at the RRP rules and regulations. Concealed under the provocative pose of PT, in my attempt at escape.


And I am Willie Loman.


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## Dean CRCNA

CApainter said:


> The following items captured from HUD's Lead Guidelines, Chapter 11: Interim Controls, suggests RRP Certified Renovators can in fact perform a form of encapsulation as indicated in item 4.
> 
> 4*.)Enclosure or encapsulation without such an expected longevity and maintenance plan may be conducted as interim control measures.)*
> 
> My point all along is that painting interior walls with the intent of preventing exposure from a lead containing surface, may not be abatement, but as an interim control, can be considered a form of acceptable encapsulation albeit, not a permenent fix.


Do what you want. However, you should understand the whole HUD Lead Safe Housing Rule and when interim controls apply. Interim controls only apply on certain projects. Painting the walls of a house is paint stabilization and does not use HUD Guideline Chapter 11.


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