EPA RRP Lead Renovator Containment Requirements

EPA RRP lead renovator containment requirements are not difficult. The work practice you choose will go a long way in determining what is required. We all know how important it is to contain leaded dust. The Environmental Protection Agency has defined containment as: a system of temporary barriers used to isolate a work area so that no dust or debris escapes while the renovation is being performed. So what does that mean for your jobs? We have tried to make it simple for you by breaking down 3 different scenarios. Interior containment on a hard surface floor, interior containment on a carpeted floor, and exterior containment.

Scenario 1: Interior containment on a hard surface floor

You have been tasked to repair a hole in the wall at your local university fraternity house. How the hole happened is uncertain, the size is a little bit over 8 square feet. The paint was tested 3 years ago during a renovation, and the records show that wall does contain lead based paint. The floor beneath the wall is hardwood, and the hole is in the living room of the residence. What are the containment requirements?

For interior containment the first thing you want to do is figure out how you will conduct the renovation and how much dust that procedure will generate. If you decide to use a wet method to conduct the renovation, the containment needed would be much different than if you worked dry. We will go on with the scenario assuming you used a wet method to conduct the renovation. This would drastically reduce the dust generated.

The first step in any interior renovation is to remove or cover items within the family room. If you are unable to remove an item it has to be covered with plastic and thoroughly cleaned at the end of the project. HEPA vacuum with a beater bar if the item is upholstered, or cleaned with a wet wipe if the surface is hard. Next you will want to look to the ceiling. What kind of surface is the ceiling? If it is a flat ceiling, that will be easy to clean and you could probably leave it uncovered. If the surface is porous or stamped you may want to cover it with plastic. Ceilings never have to be covered, but they have to be cleaned at the end of the job. Choose what will work best for the easiest cleanup at the end of the job.

Once you have figured out what to do with the ceiling, it is time to check for HVAC supply and return vents. We highly recommend that you turn off the HVAC system while conducting renovations with lead. By covering the vents you are taking the risk of damaging the system. An even bigger risk is the possibility of puncturing the plastic on a return vent. This would draw the leaded dust into the system and distribute it throughout the property. Close and cover all the vents with plastic and turn off the HVAC system.

After covering the vents it is time to make sure all the items are removed from the walls. Again, if the item can’t be moved then simply cover it with plastic and thoroughly clean it at the end of the job. At this point in your setup, it makes sense to go ahead and get your signs posted. Make sure your signs are in English and the language of the people who live at the property. Post them at the entrances to the property and outside the entrances leading into the work area.

Since your barrier doors will remain in place, go ahead and build those next. Before you do, get your supplies and materials needed to conduct the renovation into the room. Remember, every entrance leading into the work area needs to be covered with plastic, the door that you will use to enter and exit the room needs to be a barrier door with a flap. Once your doors are finished it is time to lay out the ground containment. We recommend that you use at least a 6 mil poly for ground containment. The minimum ground containment for a hard surface floor is 6 feet in each direction of the edges of the renovation being performed. While 6 feet in each direction is the minimum, ensure that you leave yourself enough room to store any garbage, tools, supplies, or materials you may need to finish the project. Also, the poly has to be sealed to the ground. We recommend that you install stepping stones down the middle of the plastic about every 2 feet. This will help remove the float effect that happens when you only seal the outside of the poly. Simply cut out a 2 inch by 6 inch square out of the plastic. Put down masking tape to protect the floor surface, then duct tape over the plastic hole until it is sealed.

The last thing to do before you begin working would be to check the windows. All of the windows need to be closed while the renovation is being performed. We recommend that if the window is within your containment area that you cover it with plastic. This will allow for easier cleaning at the end of the job.

Scenario 2: Interior containment on a carpeted floor

A local emergency service renovation firm has hired you to replace all of the plaster destroyed during a water release in a mansion built in 1923. Luckily, the water release happened on the first floor of the house and only one wall needs to be replaced. The owner would like drywall to be used to replace the plaster. The wall tested positive for lead based paint. The floor is carpeted and everything has been removed from the room. What are the containment requirements?

Protect the HVAC system, build your barrier door, cover the rest of the doors with plastic, and get your signs posted. Since the floor is carpeted you will need to cover the entire floor with 6 mil poly sheeting, or you can build a vertical containment. Since everything has been removed from the room, and you are conducting demolition. We would recommend just covering the entire floor with 6 mil poly sheeting. Since you aren’t going to build a vertical containment go ahead and cover all of the windows in the room with plastic sheeting. Covering the windows isn’t required but will make cleanup much easier at the end of the job.

Be sure to select the appropriate personal protective equipment and begin your project.

Scenario 3: Exterior Containment

You have been hired to repaint a barn that is covered in lead based paint. The barn isn’t attached to the customers house, but they would like a EPA Certified Firm to conduct the renovation in a lead safe manner. Your plan is to simply paint over the existing paint, and you won’t be disturbing more than 20 square feet during your work. What are the containment requirements?

Technically, since you won’t be disturbing more than 20 square feet the RRP rule doesn’t apply to this renovation. Although you wouldn’t be able to use the prohibited practices in the rule, you wouldn’t have to setup containment measures.  However, your customer understands how lethal lead can be, and doesn’t want to take any chances. They have read the renovate right pamphlet and understand the rules.

The first thing you need to do is remove any items outside of your work perimeter. If you can’t move it, cover with plastic and thoroughly clean it at the end of the job. After all items have been cleared from the work area go ahead and establish your perimeter. We recommend that you use green rope and wooden stakes to establish the perimeter, however any items from the yard can be used to set it up. Make sure your perimeter extends to 20 feet outside of the edge of your ground containment. Each approachable side needs a sign posted on the perimeter. Once you have your perimeter setup, go ahead and layout your ground containment. Use at least 6 mil poly sheeting and extend the plastic at least 10 feet in each direction from the edges of the renovation. We recommend that you use 2×4 sections to hold the poly sheeting in-place. After you have the plastic in place, ensure that all of the windows and doors are closed at least 20 feet in each direction. If you are going to use a door within the containment a barrier door should be built. If you won’t be using an exterior door within your containment you can simply put a piece a tape across the door and post a sign to it. If you don’t build the door, be sure to seal any cracks under or around the door with tape.

Make sure you check the neighboring properties to make sure there doors and windows are closed. Select the appropriate personal protective equipment and begin your project.

Containment requirements don’t have to be difficult. Take some time to research different work methods prior to starting the project. The less dust you create, the easier it will be to contain.

We offer the EPA RRP Lead Renovator Initial Certification Training course in over 20 states. We have a price match guarantee, satisfaction guarantee, and early bird pricing. Our trainers are passionate about lead safety, and will take the time to make sure you understand the rule and what you are required to do. To register for a course click here, dial 877-209-9648, or email [email protected].

To learn more about the EPA Renovate, Repair, and Painting Rule please check out some of our other articles below:

Educating Owners and Residents about Lead
EPA RRP Rule: Enforcement
EPA RRP Rule Exclusions
Visual Inspection Procedure

Containment Requirements

Containment Requirements

 

By: Scott Teepe Jr.