# Sticky  Certified Renovator - What to test?



## Dean CRCNA

_We've discussed much of the following, but wanted to put it down in writing. These are my thoughts ... _




In talking with hundreds of Certified Renovators (CR), I’ve realized that they (CRs) aren’t testing near enough components.

The following information is written to help the CR know what to test. I’ve verified it (numerous times) with the folks at the EPA hotline, getting clarification from the EPA Q&A, reading the rule itself (slowly and in great detail) and with the EPA lead based paint enforcement division.

You are not going to like what I’ve discovered.

*8 Hour Renovator Class*

When most CRs went through the 8 hour course only a few minutes was dedicated to this subject. Your instructor was supposed to say 2 things.

1.	Read the actual rule. 
2.	And read the actual rule again.

The actual rule says in 745.82(2); _“Renovations in target housing or child-occupied facilities in which a certified renovator, using an EPA recognized test kit as defined in §745.83 and following the kit manufacturer's instructions, has tested each component affected by the renovation and determined that the components are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight”. “If the components make up an integrated whole, such as the individual stair treads and risers of a single staircase, the renovator is required to test only one of the individual components, unless the individual components appear to have been repainted or refinished separately”_.

*Breaking It Down*

From above, we learn …

1.	That each component needs to be tested.
2.	Unless the components are a part of a larger component system (integrated whole), like stairs … a window or a door. 

What is a component? The actual rule says; _“Component or building component means specific design or structural elements or fixtures of a building or residential dwelling that are distinguished from each other by form, function, and location”_. The definition continues giving examples.

So, to tell if it is a component, you must ask yourself these questions …

Does it have a specific design or structural elements?

Or fixtures of a building or residential dwelling that are distinguished from each other?

1.	Does it have a different form?
2.	Does it have a different function?
3.	Does it have a different location?

What is a component system (integrated whole)? A component system is made up of a variety of components. Examples would be like a stair case, window or door.

A stair case is a component system made up of a variety of components (treads, risers, stringers, newel post(s), railing cap(s), balustrades and possibly other components).

A window is a component system made up of a variety of components (sill, sashes, jambs, mullions, stool, apron, heads, troughs and possibly other components).

*Putting It All Together (Examples)*

*Example Number One, An Exterior Side. * 

Let’s say a home has 4 exterior sides to it. For now, we are only going to concern ourselves with one of those sides. As Certified Renovators, we would need to check the following components that will be disturbed ...

1.	Frieze board
2.	Drip Edge
3.	Corner boards (each corner board, because they are separated by location)
4.	Soffit
5.	Fascia
6.	Siding
7.	Gable Vent
8.	Rafter Tails
9.	Gutter
10.	Gutter Downspout
11.	Trim
12.	Molding
13.	And any other individual components

You would also need to check the component systems, like a window. Let’s say there are 4 windows on that side of the house. Since each window is a separate component system, you must perform the following test on each and every window on that side of the house.

What to test on a window …

1.	Sashes
2.	Mullions
3.	Casings 
4.	Jambs
5.	Sill
6.	Apron
7.	Head
8.	Trough
9.	And any other components

Do you need to check each and every mullion? Not if the painting history is the same. If the mullions painting history is the same, you only need to check 1 mullion on that window. However, you would also need to check at least 1 mullion on the other 3 windows if the painting history is the same.

*Example Number Two, An Interior Room*

Let’s say this room has 4 walls, 2 doors and 2 windows. You would need to check the following individual components …

1.	Each Wall
2.	Crown Molding
3.	Chair Rail
4.	Wainscoting
5.	Baseboard
6.	Ceiling
7.	Hardwood Floor
8.	Quarter Round
9.	And any other component.

You would also need to check each and every window as described under example number one. You would also need to check each door in several spots, since it too is considered a component system.

*I Can See The Rage Building*

Remarks I usually hear at this moment are “this is overkill”, “this is ridiculous” and some comments I can’t put into print. My response, “I agree with you”! However, from what my research shows me … it is the law.

Try to remember that as CRs, we only spent a few minutes learning how to use the LeadCheck swab. We weren’t taught in “what to test” ... just how to use the LeadCheck. For that type of instructions, you need to take a 24 hour Lead Inspector course and pass the test (and in many states, pass a second state test).


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## aaron61

So 1 tread can be used as part of the whole stair system but 1 part of a window can't be consider as a whole window???
This does not follow the logic of an intagrated system.


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## aaron61

I think you are missing the common sense factor. Each component can be considered as the whole if it apears to have been painted at the same time.
I'm going to consider that the entire window was painted at the same time just like you can assume the entire stair system was painted at the same time.
I will test Siding as 1,trim as 1,windows as 1 etc... I think I will be fine.


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## Dean CRCNA

aaron61 said:


> So 1 tread can be used as part of the whole stair system but 1 part of a window can't be consider as a whole window???
> This does not follow the logic of an intagrated system.


If you are talking about common sense ... I agree. But the logic (at least to me) is there.

The 1 tread can not be used as part of the whole stair system. But 1 tread can be used as a representation of the other treads if the painting history is the same.

However, if you have 2 stair cases ... 1 tread on each stair case must be tested.

When I talked to the EPA, they actually made it worse. Example, they wanted on a window for the left jamb to be tested ... top jamb and the right jamb to be tested separately.


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## Dean CRCNA

aaron61 said:


> I think you are missing the common sense factor. Each component can be considered as the whole if it apears to have been painted at the same time.
> I'm going to consider that the entire window was painted at the same time just like you can assume the entire stair system was painted at the same time.
> I will test Siding as 1,trim as 1,windows as 1 etc... I think I will be fine.


If this is common sense, then it would also be common sense that all the exterior sides of the windows would be painted the same color and you would only need to check 1 window on the exterior. However, the EPA disagrees.

I've checked older homes to where the fascia is neutral ... the molding above the fascia is hot and the quarter round above the molding is neutral.

I've also found where one window sill is hot and another is neutral.

I've found where the frieze board on the porch is hot and the frieze board along the front is neutral.


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## aaron61

#2 of your OP states that: 
_“For instance, a stair tread MAY represent the whole stair system if the painting history of both is similar”. “If the painting histories are similar._
_Therefore 1 part of a window MAY represent a whole window!_
_I would not assume all windows....there is a chance that Grampa painted a couple of windows 1 year and a couple the next....1 side of a house 1 year and another the next.Chaces are your going to hit a positive way before you test more than 5 or 6 component systems IMHO. _

_I also agree with anothers post that you can usually get a good feel just by looking at the home. I'm going to look harder at a home from before the 50's than a home of the 70's._


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## Dean CRCNA

Aaron,

I see where it can be confusing, so I edited it to just reflect the actual rule.


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## aaron61

It's really not confusing to me. I believe you had it correct before you edited! That was taken straight from the rule.1 component can represent the whole!

I would just always error on the side of caution.The folks from the EPA that I spoke with clarified enough for me to understand it. I think your taking it a bit far and I can see where you would want to.

But for me I'm going to use common sense.I will use Lead safe Practices on old homes regardless,but if someone has a home that was built lets say in the 60's,I'm going to test A window or 2,The siding & The Trim. If I feel comfortable I will move forward accordingly.


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## daArch

I have seen enough older homes to understand that various elements of any one "system" could be newly replaced after 1978 while others could be dating back 75 - 100 years. 

In the room in which I am sitting (my office) I can personally attest that some elements of just one window were new two years ago (header and stool), sashes were replaced after 1980, and the majority of the other elements 75+ years ago. 

But knowledge of specific "systems" aside, I think we all agree that "EPA" and "logic" are not two words that have many similarities. 

And from my experience, I would highly recommend that if you want to comply with the PPR rules, that you test and document each element or assume it is all lead.


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## aaron61

If I were to look at that window I bet I can tell which are the new parts as well. Test the old part!
If I'm not going to be sanding that said window then it doesn't matter.


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## daArch

aaron61 said:


> If I were to look at that window I bet I can tell which are the new parts as well. Test the old part!
> If I'm not going to be sanding that said window then it doesn't matter.


Absolutely, if you ain't gonna be disturbing no paint with sanding, then you ain't gonna need no tests.

But, how do you repaint without sanding ? 

Maybe you gots diff'rent wood, weather, and paint in the Sunshine State, but 'round here, muntins, rails, stools, aprons, mullions etc need a good sanding to make the finish job look smooth an' pretty.


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## johnpaint

Arch, even if you need to sand you can carry a bucket of water and a sanding sponge and sand, as long as the dust is wet you will be fine. Sometimes I think we forget about wet sanding.In that case you don't have to treat it as if you making dust in the room.


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## Dean CRCNA

My vote is with Arch. There is lead based paint on components that you would never know it is lead based paint. Of course other times, you may can tell.

Everyone must do what they think best.

There are those contractors who will try and follow the law and contractors who will do their own thing and use their own judgement.


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## DeanV

johnpaint said:


> Arch, even if you need to sand you can carry a bucket of water and a sanding sponge and sand, as long as the dust is wet you will be fine. Sometimes I think we forget about wet sanding.In that case you don't have to treat it as if you making dust in the room.


Wrong. Completely wrong. If you are sanding, wet sanding is one of the techniques that is part of RRP procedures. But, wet sanding in no way at all circumvents compliance at all. Now, using a bonding primer and skipping sanding all together, yes. That would work.


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## Dean CRCNA

aaron61 said:


> It's really not confusing to me. I believe you had it correct before you edited! That was taken straight from the rule.1 component can represent the whole!


Not that it matters, but the part edited, wasn't from the rule. The part left in is from the rule.

and also from the rule

_Component or building component means specific design or structural elements or fixtures of a building or residential dwelling that are distinguished from each other by form, function, and location. These include, but are not limited to, interior components such as: Ceilings, crown molding, walls, chair rails, doors, door trim, floors, fireplaces, radiators and other heating units, shelves, shelf supports, stair treads, stair risers, stair stringers, newel posts, railing caps, balustrades, *windows and trim (including sashes, window heads, jambs, sills or stools and troughs)*, built in cabinets, columns, beams, bathroom vanities, counter tops, and air conditioners; and exterior components such as: Painted roofing, chimneys, flashing, gutters and downspouts, ceilings, soffits, fascias, rake boards, cornerboards, bulkheads, doors and door trim, fences, floors, joists, lattice work, railings and railing caps, siding, handrails, stair risers and treads, stair stringers, columns, balustrades, windowsills or stools and troughs, casings, sashes and wells, and air conditioners.]_


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## johnpaint

DeanV said:


> Wrong. Completely wrong. If you are sanding, wet sanding is one of the techniques that is part of RRP procedures. But, wet sanding in no way at all circumvents compliance at all. Now, using a bonding primer and skipping sanding all together, yes. That would work.


Did I say it did? No, but you wish I did, right?


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## johnpaint

If I were testing the house for lead and found it, I would not act as if it had no lead, but it is not that hard to work with compliance anyway with small areas that need wet sanding. What is you motive for all this anyway?


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## DeanV

Sorry if I misunderstood your post, but I thought you were saying wet sanding would make so you did not have to act as though you were creating dust in the room. You would still have to do full containment, full clean-up procedures, full everything.


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## johnpaint

DeanV said:


> Sorry if I misunderstood your post, but I thought you were saying wet sanding would make so you did not have to act as though you were creating dust in the room. You would still have to do full containment, full clean-up procedures, full everything.


Well the less mess you make, the less work you have, the less clean up and so on.


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## Dean CRCNA

*Epa q&a*

*Question*

_When testing a property for the presence of lead prior to beginning a renovation using an EPA-recognized
test kit, must I test every component affected by the renovation?
_
*Answer*

Yes. Because certified renovator training does not cover sampling protocols, certified renovators using EPA-recognized test kits to determine the applicability of the RRP Rule must test each and every component that will be affected in order to determine that the RRP Rule does not apply to a particular
renovation.

*Question*

_When a certified renovator uses an EPA-recognized test kit to determine the presence of lead, can the
results be grouped? For instance, may the certified renovator test just one window sill in a room if all will
be affected?_

*Answer*

No. The certified renovator must test each component affected by the renovation. If the components
make up an integrated whole, such as the individual stair treads and risers of a single staircase, the
renovator is required to test only one of the individual components, unless the individual components
appear to have been repainted or refinished separately. Multiple window sills are not integrated parts of a
whole. They are separate components and must be tested separately.

*Question*

_Is a lead-based paint inspection, performed by a certified inspector or risk assessor, that includes a
written determination that various building components are free of paint or other surface coatings
containing lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight
sufficient to determine compliance with requirements of the RRP rule?_

*Answer*

The RRP Rule does not apply to target housing where a certified inspector or risk assessor has
determined that the components affected by the renovation are free of regulated lead-based paint or that
a property is free of lead-based paint for the purposes of the Lead Disclosure Rule.
The RRP Rule does not require certified inspectors or certified risk assessors to test each and every
component that will be affected by a renovation. Certified inspectors or risk assessors are free to conduct
representative sampling, so long as the components to be tested are chosen in accordance with
documented methodologies, such as the HUD Guidelines. However, because certified renovator training
does not cover sampling protocols, certified renovators using EPA-recognized test kits to determine the
applicability of the RRP Rule must test each and every component that will be affected in order to
determine that the RRP Rule does not apply to a particular renovation.


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## Dean CRCNA

*Testing Doors*

This is with the assumption that you are just painting one side of the door.

On doors, you would need to test the 

1. Door slab
2. Door trim (casing) on 1 spot.
3. Door jambs on 1 spot.

This is pretty much true whether the door has been repainted or refinished in the past or not.


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## Dean CRCNA

*Testing Walls*

If you're in a room with walls, you would have to test one spot of each wall. Walls connected together are not considered an integrated whole.

Crown, chair rail, baseboard, shelves and etc. are not considered an integrated whole of that wall.

On the exterior ... the same applies.

If the exterior wall has siding, you do not have to test each separate board. One test will be good enough on that wall.


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## Dean CRCNA

*Testing Stairs & Windows*

Got the word ...

Integrated whole can also be understood as testing combinations. In general, certified renovators would need to almost test the same components and testing combinations as a lead inspector. If you think about it, it wouldn't make much since that certified renovators can check a lot less than lead inspectors/assessors. 

On stairs, the testing spots would be ...

1. the integrated whole is the risers and treads
2. balustrades (only 1 if painted same color)
3. stringers
4. rails, 
5. newel post 

and other components.

On windows, the testing spots would be ...

1. the integrated whole would be the stop and jambs.
2. Another integrated whole (IW) would be the casing (top and side casings together). 
3. Another IW would be the sash (along with the mullions). 
4. Trough 
5. Sills or Stool
6. Window Head

So the original post is correct, except I need to take out the mullions. Will do so via edit tomorrow.


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## Custom Brush Co.

I feel this is great info to understand to understand and realize the components that are associated with an Integrated Whole. However, it is how you use this information that can make you crazy or give you something to take away from it.

Think about it for a minute... If you had to check every component and one part of it has lead and another doesn't. Does this mean the preventative preparation is going to change at all? Doesn't this mean wasting tons of lead checkers? And Time? It may or may not. It truly depends on the project you are involved with.

Basically, the larger the project the more you should check the individual components at large, such as the fascia vs the siding. However, *only concern your self with checking where you could potentially disturb the lead dust* like in the case of loose and peeling paint for painters. Or removing a window for a window guy. Only worry about where the dust could be disturbed.

You see, these rules can be easily blown out of proportion. However, with a little bit of actualization visualization on a job by job, project by project, problem/solution basis, the stress can be lowered down to being in the damned hot suites and masks. lol.

Furthermore, We have been monitored a couple times now as a company. The first time we were not doing everything correctly and had to re-educate ourselves on the process in 2008. We paid a small fine, and now have mastered lead paint removal on the outside. After a recent surprise check on a job we did, they said we did an excellent, perfect job. 

Quick tip: On the inside, learn to use heavy duty PVC tubing, duct tape, and 3 mil plastic to build yourself a custom booth for removing lead in isolated areas of the home.


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## Custom Brush Co.

Dean CRCNA said:


> This is with the assumption that you are just painting one side of the door.
> 
> On doors, you would need to test the
> 
> 1. Door slab
> 2. Door trim (casing) on 1 spot.
> 3. Door jambs on 1 spot.
> 
> This is pretty much true whether the door has been repainted or refinished in the past or not.


Now here is a statement that could make someone squirm in the pants holding back a lot of frustration. 

This sounds crazy, *but is only necessary if you potentially could disturb dust in this area*. The other thing is, if the majority of a project has lead, just treat it as if all of it has lead if possible. Especially for homes from the 1978 and earlier and there is no recorded proof or clear sign of remolding.


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## DeanV

Just remember, if you touch that door with sand paper, you are disturbing lead dust regardless of how many layers down the lead is according to the EPA.


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## Custom Brush Co.

The key term here to understand is the key phrase, "must test each and every component that will be affected." This is in a very high language for the average painter. LOL. Basically goes back to making it simple and taking a true evaluation of your job scope. Since we are all painters here this means to check everything that could absolutely cause dust. Which means for the most part loose and peeling paint.

Are there any other cases we should concern ourselves?


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## Dean CRCNA

Custom Brush Co. said:


> Think about it for a minute... If you had to check every component and one part of it has lead and another doesn't. Does this mean the preventative preparation is going to change at all? Doesn't this mean wasting tons of lead checkers? And Time? It may or may not. It truly depends on the project you are involved with.
> 
> Basically, the larger the project the more you should check the individual components at large, such as the fascia vs the siding. However, *only concern your self with checking where you could potentially disturb the lead dust* like in the case of loose and peeling paint for painters. Or removing a window for a window guy. Only worry about where the dust could be disturbed.
> 
> You see, these rules can be easily blown out of proportion. However, with a little bit of actualization visualization on a job by job, project by project, problem/solution basis, the stress can be lowered down to being in the damned hot suites and masks. lol.


1. If you inspect an exterior and find that lead based paint is only on some columns, you only have to do RRP on those columns ... not on the whole exterior. So the preventive measures can change.

2. No where in the rule, does it state you only test "where you could potentially disturb lead dust". You can't even see lead dust.

3. You don't have to wear hot suits and mask for the RRP.


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## Custom Brush Co.

Dean CRCNA said:


> 1. If you inspect an exterior and find that lead based paint is only on some columns, you only have to do RRP on those columns ... not on the whole exterior. So the preventive measures can change.
> 
> 2. No where in the rule, does it state you only test "where you could potentially disturb lead dust". You can't even see lead dust.
> 
> 3. You don't have to wear hot suits and mask for the RRP.


Now this is getting really confusing. I don't sand unless there is or was loose and peeling paint.

But I thought of a time when I might sand. If there is a high gloss oil paint (containing lead) paint to get my latex paint to stick. Then that can cause lead dust. The chances of this happening are so rare because what kind of oil paint that has lead in it would still have a gloss shine and wouldn't be alligatoring and cracking all over, fading... Only on the inside of a house is this possible on paint appplied to walls and doors and frames. This is also rare and the house would be in shambles most likely.

If I am not disturbing the surface (i.e., scraping, sanding, heat gunning) then I am probably only cleaning the surface with water and a cleaning agent and painting it. 

So if all we are going to do is paint on a project we know has or potentially has lead, then what is the point of doing all those tests?

This is my point. Do you get it? I mean why else should we concern ourselves with it.

And show me where and when it's ok not to wear suits and a mask to remove the loose and peeling paint. We were not taught this, OSHA doesn't approve or the EPA as far as I was educated. What page or rule does it talk of this?


One last thing, I agree if on an exterior you test and only columns only have lead then thats all you have to do, but this goes against a rule of thumb they teach, that if you find it here and there and there are no detectable traces one place but there are on another that you need to hire a service (really expensive) to double check cause there still could be lead there. So this goes to my point know your project. If it is been remodeled since and new siding is on but not fascia. check the fascia and only do RRP rule to it. But if there is no proof of past restorations and one place has lead, most likely all of it will. Then you can check further if needed or treat the project as all having lead.


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## RCP

In the EPA class the slide clearly says workers "should" wear PPE, it is not required.


> EPA would like to clarify the requirements for personal protective equipment. The Occupational Safety and Health Administration (OSHA) has requirements for personal protective equipment, EPA does not. For many years, EPA has recommended the use of personal protective equipment as a way to protect workers and to help ensure that leaded dust and debris does not leave renovation or abatement work sites. EPA recommends that renovators make use of the minimum respiratory protection recommended by the National Institute of Occupational Safety and Health (NIOSH) for environments where lead is present, but respiratory protection is not required by the EPA regulations. In addition, disposable clothing, if removed and disposed of before the workers leave the work site, can provide additional protection for workers' families by ensuring that no leaded dust or debris is carried home on worker clothing. However, EPA does not require this and allows renovators to use other methods to ensure that dust and debris does not leave the work area, including the HEPA vacuuming of clothing, tools, and other items before they leave the work area.


http://toxics.supportportal.com/ics/support/default.asp?deptID=23019

But everyone has been following OHSA Rules concerning LBP all along right?

The signs are another issue, if you use what RRP requires, it does not meet OHSA Rules.


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## Dean CRCNA

Custom Brush Co. said:


> Now this is getting really confusing. I don't sand unless there is or was loose and peeling paint.
> 
> But I thought of a time when I might sand. If there is a high gloss oil paint (containing lead) paint to get my latex paint to stick. Then that can cause lead dust. The chances of this happening are so rare because what kind of oil paint that has lead in it would still have a gloss shine and wouldn't be alligatoring and cracking all over, fading... Only on the inside of a house is this possible on paint appplied to walls and doors and frames. This is also rare and the house would be in shambles most likely.
> 
> If I am not disturbing the surface (i.e., scraping, sanding, heat gunning) then I am probably only cleaning the surface with water and a cleaning agent and painting it.
> 
> So if all we are going to do is paint on a project we know has or potentially has lead, then what is the point of doing all those tests?
> 
> This is my point. Do you get it? I mean why else should we concern ourselves with it.


You only need to follow RRP when you are going to disturb paint. If you are not going to disturb a painted/stained surface, you do not have to do RRP and likewise, there is no need to test.

In your example of lightly sanding trim before painting ... this would fall under RRP ... even if you greatly suspect it to be non-lead based paint. You have to have proof and the proof is lead testing.

I think we may be saying the same thing, just in a different way.



> And show me where and when it's ok not to wear suits and a mask to remove the loose and peeling paint. We were not taught this, OSHA doesn't approve or the EPA as far as I was educated. What page or rule does it talk of this?


As Chris said, the actual RRP rule does not say anything about wearing suits/mask. See the rule itself. So, if you don't ... you won't get into trouble from the EPA. OSHA is a different matter, but we are not talking about OSHA here.

Plus, wearing a N-100 mask is not going to cut it for OSHA any way.



> One last thing, I agree if on an exterior you test and only columns only have lead then thats all you have to do, but this goes against a rule of thumb they teach, that if you find it here and there and there are no detectable traces one place but there are on another that you need to hire a service (really expensive) to double check cause there still could be lead there. So this goes to my point know your project. If it is been remodeled since and new siding is on but not fascia. check the fascia and only do RRP rule to it. But if there is no proof of past restorations and one place has lead, most likely all of it will. Then you can check further if needed or treat the project as all having lead.


If you have proof of new siding, and you are going to disturb it ... you have to do RRP, unless it is tested. They don't want a "judgement" call being done. They want "proof" (which is testing).


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## Dean CRCNA

Just wanted to add a note on suits. While the RRP rule itself doesn't require it, it can help with keeping the dust in the containment area, if you take off the suit before leaving the containment area.

Not saying it is not a good idea, just saying that the rule itself doesn't say you have to.


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## HomePaintersInfo

In Australia we have regulations to follow and we are training our apprentices in how to deal with lead paint hazard as a competency for their apprenticeship, however most of the painters here don't follow them. 

I have worked on the philosophy that if you find lead in any areas that are being worked on you treat the whole job as a lead risk job. 

When you test for lead you can test one area and find no or low lead content and then test 2 feet away and find high lead paint content. That's why I recommend people treat lead as lead no matter what the content comes back as. 

I don't know what other countries regulations are, but you can see how we deal with lead paint here at 
http://www.paintingbrisbane.com.au/main/page_lead_paint_removal.html

I hope this gives you an understanding of how we deal with lead paint down under and if anyone can give me any tips on how you deal with lead I would greatly appreciate it.


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## Dean CRCNA

Finally, some clarification on what to test ... _from the EPA RRP FAQ ..._


*Question:

I’m a certified renovator using an EPA-recognized lead test kit to determine whether or not I have to follow the Renovation Repair and Painting (RRP) Rule work practices. What components must test negative for lead-based paint in order to qualify for the exclusion in 40 CFR 745.82(a)(2)?
*
Answer:

Generally, a certified renovator using an EPA-recognized test kit must test each building component to be disturbed. The only exception to this requirement is when the components make up an integrated whole. In such a case, one or more component(s) may represent a system of components, unless it is obvious to the renovator that the components have been repainted or refinished separately. 

A staircase, for example, is made up of numerous repeating components which can be grouped together as integrated wholes for testing purposes. For these purposes, staircase components can be grouped into the following integrated wholes: (1) treads and risers, (2) balustrades, (3) newel posts, (4) railing caps, and (5) stringers. A single individual staircase component (e.g., a baluster) may represent the remaining staircase components of the same group (i.e., the rest of the balustrades on the staircase) unless it is obvious to the renovator that the components have been repainted or refinished separately. Therefore, where an entire staircase is to be disturbed, EPA believes it will be necessary to test five surfaces: one tread or riser, one balustrade, one newel post, one railing cap, and one exposed stringer. So long as it is not obvious that the components have been repainted or refinished separately, a negative test for lead-based paint on an individual staircase component in each of these groups would mean that a renovation on that particular staircase could be performed without regard to the RRP work practices. 

EPA also believes it appropriate to apply the integrated whole concept to windows and doors. For testing purposes, window and door components can be grouped into the following integrated wholes: (1) the window or door assembly and (2) the window or door trim. Window assembly components include the sashes, stops, head, jambs, sill or stool, and trough; door assembly components include the door slab(s), jambs, head, sill and threshold. As a practical matter, it is likely that interior and exterior surfaces of window and door assemblies were repainted or refinished separately and should be tested separately. Therefore, where both the window/door assembly and trim will be disturbed (e.g., a full-frame window/door replacement), EPA believes that it will be necessary to test four surfaces: one interior window/door assembly component, one interior window/door trim, one exterior window/door assembly component, and one exterior window/door trim. However, if you only disturb paint on the interior or exterior of a window then you only need to test the assembly and trim on that side. If it is not obvious that the components have been repainted or refinished separately, a negative test for lead-based paint on a component in each of these groups would mean that a renovation on that particular window or door could be performed without regard to the RRP work practices.

NOTE: Each window, door and staircase to be disturbed must be separately tested, even if in the same room. Also, negative testing results must still be documented in accordance with the recordkeeping and reporting requirements of 745.86(b)(1)(ii) and (iii), and 745.86(a) and (c). See also FQ 23002-18220.


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## epretot

Dean CRCNA said:


> Finally, some clarification on what to test ... _from the EPA RRP FAQ ..._
> 
> 
> *Question:
> 
> I’m a certified renovator using an EPA-recognized lead test kit to determine whether or not I have to follow the Renovation Repair and Painting (RRP) Rule work practices. What components must test negative for lead-based paint in order to qualify for the exclusion in 40 CFR 745.82(a)(2)?
> *
> Answer:
> 
> Generally, a certified renovator using an EPA-recognized test kit must test each building component to be disturbed. The only exception to this requirement is when the components make up an integrated whole. In such a case, one or more component(s) may represent a system of components, unless it is obvious to the renovator that the components have been repainted or refinished separately.
> 
> A staircase, for example, is made up of numerous repeating components which can be grouped together as integrated wholes for testing purposes. For these purposes, staircase components can be grouped into the following integrated wholes: (1) treads and risers, (2) balustrades, (3) newel posts, (4) railing caps, and (5) stringers. A single individual staircase component (e.g., a baluster) may represent the remaining staircase components of the same group (i.e., the rest of the balustrades on the staircase) unless it is obvious to the renovator that the components have been repainted or refinished separately. Therefore, where an entire staircase is to be disturbed, EPA believes it will be necessary to test five surfaces: one tread or riser, one balustrade, one newel post, one railing cap, and one exposed stringer. So long as it is not obvious that the components have been repainted or refinished separately, a negative test for lead-based paint on an individual staircase component in each of these groups would mean that a renovation on that particular staircase could be performed without regard to the RRP work practices.
> 
> EPA also believes it appropriate to apply the integrated whole concept to windows and doors. For testing purposes, window and door components can be grouped into the following integrated wholes: (1) the window or door assembly and (2) the window or door trim. Window assembly components include the sashes, stops, head, jambs, sill or stool, and trough; door assembly components include the door slab(s), jambs, head, sill and threshold. As a practical matter, it is likely that interior and exterior surfaces of window and door assemblies were repainted or refinished separately and should be tested separately. Therefore, where both the window/door assembly and trim will be disturbed (e.g., a full-frame window/door replacement), EPA believes that it will be necessary to test four surfaces: one interior window/door assembly component, one interior window/door trim, one exterior window/door assembly component, and one exterior window/door trim. However, if you only disturb paint on the interior or exterior of a window then you only need to test the assembly and trim on that side. If it is not obvious that the components have been repainted or refinished separately, a negative test for lead-based paint on a component in each of these groups would mean that a renovation on that particular window or door could be performed without regard to the RRP work practices.
> 
> NOTE: Each window, door and staircase to be disturbed must be separately tested, even if in the same room. Also, negative testing results must still be documented in accordance with the recordkeeping and reporting requirements of 745.86(b)(1)(ii) and (iii), and 745.86(a) and (c). See also FQ 23002-18220.


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## Finn

So 

Cross all the x's and tick all the boxes, soon it will be a felony to fart in this country, As fellow tradesmen and women I respect you all. But the regulations in this country are turning it into something like the UN . A lot of power, but a fat lot of use! Here is my concern, 1978 does not mean Jack! Who came up with that year? 

I went to bid on a house last week, 1942 built, a friend said we could not touch it! When he told me about this rule, I looked for how to get certified, apparently if I take a1 day course at a price of $249.00 I will be EPA compliant. 

Unless I am convinced that this compliance will be monitored as well as it is being used to make money of contractors then to me it's another tick in the box money spinner for government , just like back in the UK when they regulated security. 

Yep 
I will do the course, follow the rules blah blah blah, God tells me I have to submit to our authorities, and I don't have the luxury or desire to contradict that, but let's not forget, we are the professionals here, so let no man take away the confidence needed to maintain your identity as tradesmen and not contractual sheep as gas happened all over the world!


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## Finn

Sorry folks, 
Just read that again, and realized I went off on a rant. Yes I'm sure Lead Paint is not nice if your breathing it in all the time !


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## Steve Richards

Yeah, Finn..time to join the club.

Get ready for HO's to stare like deer in the headlights when you mention RRP, most of them have never heard anything about it.

Be prepared to lose some work over it too. Most folks won't spend extra money so you can comply with rules they've never heard of...especially when the next painter they get an estimate from may not even bring it up, and come in 30% under your bid.


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## Lee Decorating Corp.

I have still yet to see and electrician or plumber on any job that follows any RRP protocol.
I remember I was sitting in an RRP class with some of my employees (I was already certified RRP) and decided to stir the pot as the class was falling asleep.
I asked the instructor "What happens when the electrician comes in and notches the ceiling while I am working? It happens". The instructor really had no answer other than to report the electrician to EPA (yeah right, the H.O. would be thrilled). The class awoke and and started on a similoar questioning as this thread. The instructor started sweating.
My view is that it is a law with good intentions made by politicians looking for good P.R. but it is not written well and makes the painter the "Boogey Man" while most trades ignore. We just have to do our best to comply. Remeber if you are certified. you will be the first that the EPA will audit. They know who you are. They do not know the "Trunk Slammers" and "Gypsy" operations that will not and do not care about regulations.


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