# Official RRP Changes



## Dean CRCNA (Feb 4, 2010)

It seems, no clearance. Good news for the contractor.

http://www.epa.gov/lead/pubs/lrrpprepub.pdf


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## DeanV (Apr 18, 2007)

Vertical containment is clarified quite well it looks in the link. Time to start a scaffolding rental business. I cannot imagine the time to set up and tear down scaffolding as the weather requires on a large Victorian. I think only crews that are large enough to do all the lead paint disturbing in one day should try to tackle homes where the property line is close by. Unless your weather people are better than ours at predicting weather.

The vacuum section may help as well, but it is hard to say (a lot of pages to read in that link). It seems that a bissel household vac would meet specs as well as a fancy vacuum without EPA testing and certifying of vacs.


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## Dean CRCNA (Feb 4, 2010)

If you go to page 78 on the link, it gives the official wording that will probably be used.


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## Dean CRCNA (Feb 4, 2010)

DeanV said:


> Vertical containment is clarified quite well it looks in the link. Time to start a scaffolding rental business. I cannot imagine the time to set up and tear down scaffolding as the weather requires on a large Victorian. I think only crews that are large enough to do all the lead paint disturbing in one day should try to tackle homes where the property line is close by. Unless your weather people are better than ours at predicting weather.
> 
> The vacuum section may help as well, but it is hard to say (a lot of pages to read in that link). It seems that a bissel household vac would meet specs as well as a fancy vacuum without EPA testing and certifying of vacs.


The wording will read something like this ...

_If the renovation will affect surfaces within 10 feet of the property line, the 
renovation firm must erect vertical containment *or equivalent extra precautions* in containing the work area to ensure that dust and debris from the renovation does not contaminate adjacent buildings or migrate to adjacent properties. Vertical containment or equivalent extra precautions 
in containing the work area may also be necessary in other situations in order to prevent contamination of other buildings, other areas of the property, or adjacent buildings or properties. _

This seems that you could get 2 2x4s with a piece of plastic stuck between and then just lean them up against the gutters.

Long story short ... may not be a biggie.


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## Brandt Domas (Jun 29, 2009)

*Still wading through the 112 pages*

Good news though. Finally some good EPA RRP news. Amazing


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## Bender (Aug 10, 2008)

> Long story short ... may not be a biggie.


This could be a prophetic war cry for the entire lead mandate:whistling2:


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## eews (Apr 18, 2007)

The EPA is actually supporting the view that remodeling work is not the same as abatement, and that they see no evidence that the RRP rule as it stands is not sufficient to minimize creation of lead dust. Praise be! Apparently, the concerns of the regulated community were listened to, and respected. Now if they can re-instate the opt-out clause, RRP might make sense!


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## daArch (Mar 15, 2008)

Move to Mass. NO ONE is paying heed to RRP. 

I gotta start a photo gallery of the total disregard for the RRP rule I see all around.


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## chrisn (Jul 15, 2007)

I have to ask this ,Since I am starting my business back up, is anybody paying heed. Never mind, that question cannot be answered. What percentage of jobs have you run into that require you to apply RRP regulations? I will go to the stupid calass for the day and get official, but just wondering how much I am going to have to actually practice this.

Oh,sh!t, never mind, I cannot put this into words that anybody can respond too.


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## daArch (Mar 15, 2008)

Chris,

I really believe it's different in different parts of the country. I would advise that you go to the class so you can at least look at it from an educated point of view.

I have convinced myself that RRP does not apply when installing wallpaper because it does not DISTURB the required six s.f.

As far as painting, I literally have not seen ANY compliance in my travels around the Boston area. One of my painting buddies just applies paint over existing finsihes without any prep work - no disturbing the surface there (I seriously do not know how he stays in business). One of my other painting buddies does work that is obviously covered by RRP, but pays no heed, interior or exterior. 

I am sure in other parts of the country compliance is a lot better

And here's a couple of random jobs by others that I have seen while driving around. Sure there are only two, but this is highly representative:


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## Dean CRCNA (Feb 4, 2010)

chrisn said:


> I have to ask this ,Since I am starting my business back up, is anybody paying heed. Never mind, that question cannot be answered. What percentage of jobs have you run into that require you to apply RRP regulations? I will go to the stupid calass for the day and get official, but just wondering how much I am going to have to actually practice this.
> 
> Oh,sh!t, never mind, I cannot put this into words that anybody can respond too.


Good question.

Statistics are all over the place, but this may help.

Based on the whole US, a little less than 50% of homes were built in 1977 or older. This would mean for the average painter, 50% of the time, they would be working in a home built before 1978. 

*Interior Painting*

Now, many times in these pre-1978 homes, you may not be actually disturbing paint (or disturbing less than 6 sq ft) ... especially in interior painting. From my feel of the situation, the average painter would only be disturbing paint (not necessarily lead based paint) on the interior of a home built before 1978 around 15% to 10% of the time.

*Exterior Painting*

On exteriors, it is a totally different story. My feel is that around 100% of the time, you would be disturbing paint. This is mainly because of pressure washing. However, if you found a lead inspector that would be willing to only check the exterior … you would find that only 40% to 50% of these pre-built 1978 homes would have lead based paint. 

*Putting It All Together*

For the average painter in the US (based on all homes … any age), they would only have to worry about RRP on around 7% to 5% of interiors and 20% to 25% on exteriors.

If you used a lead inspector each time, you would probably find that for the average paint (based on all homes), they would need to do RRP on only 2% to 1% of interior jobs and 10% to 15% of exterior jobs.

*In Short*

In reality, RRP will only affect you on 15% of your jobs, unless you used a lead inspector, where it would only affect you on 5% to 7% of your jobs.

_Of course in reality this depends on where you live. In St. Louis, 80% of the time you would be working on a home built before 1978. In Dallas, it could be only 25% of the time. However, the above should give you the average, based on the US._


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## RCP (Apr 18, 2007)

Good stuff, Dean thanks for posting the above. I think that is something a lot of guys forget, not every pre 78 home is RRP, so when you see a pre 78 being worked on, that does not always mean RRP is not being followed, sometimes, but not always!

As far as Dust Clearance, I guess my plans to get rich doing clearance testing just went out the window!


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## chrisn (Jul 15, 2007)

Thanks Dean
This was just the sort of information I was looking for. I just could not put it into words very well.

and Bill, my wife said EXACTLY the same words as you

" I would advise that you go to the class so you can at least look at it from an educated point of view."

now that's kind of scary


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## daArch (Mar 15, 2008)

chrisn said:


> Thanks Dean
> This was just the sort of information I was looking for. I just could not put it into words very well.
> 
> and Bill, my wife said EXACTLY the same words as you
> ...


I am duly frightened


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## daArch (Mar 15, 2008)

Dean,

Although I like the numbers you put forth, I just gotta ask your sources for those numbers. I'm a natural born cynic (SURPRISE !) and I know it's a proved fact that if you throw out fabricated stats, 87% of your listeners will believe you, no questions asked.


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## Dean CRCNA (Feb 4, 2010)

daArch said:


> Dean,
> 
> Although I like the numbers you put forth, I just gotta ask your sources for those numbers.


OSHA, CDC, Census, Harvard. The "from my feel" is based on the number of painting contractors I do testing for. 

In the Boston area, you would have a lot higher rates than Dallas does. 

OSHA (Lead) basically feels that a painter would encounter interior LBP on 6 out of 100 working days and exterior LBP on 16 out of 100 working days. Once again, in Boston, the percentages would be higher. In Dallas, they would be lower.


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## daArch (Mar 15, 2008)

> In the Boston area, you would have a lot higher rates than Dallas does.


thanks for that, I was trying to figure a way to present that.


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