EPA and HUD Prohibited Practices

Airborne Leaded Dust: Prohibited Practices

EPA RRP Rule Prohibited Practices

The EPA Renovation, Repair, and Painting Rule does not specifically address what measures must be taken to reduce the amount of dust generated on the job. Rather, the rule lists three Prohibited Practices that must not be used on the job.  A key to minimizing the spread of dust and paint chips is not to use certain traditional work practices known to create large amounts of dust and debris.

  1. Open-flame burning or torching of painted surfaces
  2. Heat gun above 1,100º F (degrees Fahrenheit).
    1. Open-flame burning or torching of paint and using a heat gun above 1,100º F create very fine leaded dust particulates (“fume”) that are dangerous for workers to breathe.
    2. The small leaded dust particles created by burning and heating also settle on surrounding surfaces and are very hard to clean up.
  3. The use of machines designed to remove paint or other surface coatings through high-speed operation are prohibited.  Any high speed machine must have shrouds or containment systems that are equipped with a HEPA vacuum attachment to collect dust and debris at the point of generation.  Machines must be operated so that no visible dust release of air occurs outside the shroud or containment system.
    1. Power sanding, power grinding, power planning, needle guns, abrasive blasting, and sandblasting create a large amount of dust that floats in the air and then settles on surfaces inside and outside of the work area.

HUD Lead-Safe Housing Rule Prohibitied Practices

In addition the EPA RRP Rules, HUD sets a higher standard for prohibited work practices.  HUD three additional rules that must be followed.

  1. Dry scraping or sanding is prohibited unless you are within one foot of an electrical outlet.
    1. Dry scraping and sanding often will create dust that will easily migrate past the minimum points of containment within the rule.  Because of that probability and the likelyhood that children will live in HUD properties dry scraping and sanding is prohibited.
  2. Using a heat gun.
    1. Heat guns are prohibited due to the dificulty of cleanup and potential for lead fumes during their use.
  3. Using a caustic based paint stripper in a poorly ventilated area.
    1. Paint strippers can remove oxygen from the air and also release cancer causing agents during their use. Closets, crawl spaces, and hallways all maybe poorly ventilated and an alternative paint removal process should be used.

We offer Lead Renovator Certification in 17 states and are approved to teach in several locations.  We offer bi-weekly classes in several cities.  Some of our favorites include:

Charleston, SC
Dallas, TX
Denver, CO
Nashville, TN
Orlando, FL
Pittsburgh, PA
Tampa, FL

Contact us anytime to register or for more information by emailing [email protected] or dialing 877-209-9648.

For more information on handling airborne leaded dust, we recommend these posts from our blog:

How Widespread is Lead-based Paint in Housing
How to Determine if Lead-based Paint is Present
Health Risks of Lead
EPA Firm Certification

Prohibited Practices

Prohibited Practices