Author Topic: RRP Clarification  (Read 1277 times)

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Offline mrFinpgh

  • Posts: 305
RRP Clarification
« on: May 17, 2019, 07:01 PM »
Met w/ a painter today about some work on an old house exterior.  Job is basically to remove flaking/alligatoring paint and prime/repaint.

They are EPA certified and brought this up proactively. 

I asked them about containment and they seemed to feel that it was not a big deal.  Dropcloths/plastic to contain scraping debris, shop vac w/ hepa filter, sanders with attached dust collection.

They also pointed out the 7 or more layers of latex over the probably lead paints (untested) and seemed to be thinking that this would be the primary surface they are disturbing and less so w/ the lead paints underneath.

I liked them and it's hard to get people out for a relatively small job.  At the same time, it doesn't seem like they are taking quite the level of caution that I usually take (wet everything, plastic everywhere, tyvek, masks..) when I deal w/ interior surfaces that have lead.

Am I incorrect in thinking that they are probably not strictly adhering to the letter of the law when it comes to RRP?  Are they correct in their observation that the paint they are disturbing is not the actual lead layer, but paint some layers removed from that?

Given the possibility of children in the future and neighbors so close, I'm always acutely sensitive to this, but want to make sure I'm not over-thinking it.

thanks,
Adam

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Offline JimH2

  • Posts: 808
Re: RRP Clarification
« Reply #1 on: May 17, 2019, 07:33 PM »
It's a small job and if there is no interest other than this company and they are offering a fair price go with them. I am sure if you look you will find a painting contractor who will blow the job out of proportion taking RRP to the extreme and come back with a ridiculously high quote. Then do you go with the reasonable quote or the crazy-high quote for an exterior paint job. If this were inside the house I'd be more concerned and if much more than scuff sanding I'd take the appropriate measures to minimize the risk.

If it makes you feel better call someone else out and have them perform a lead test. When considering any law or regulation reasonableness has to be considered and usually is not when legislation is passed or rules are made. Also, keep in mind that lead paint was used almost exclusively up until the 1978 because it was durable and held up to abuse. It was not until kids were left unsupervised eating window stools that it became a problem.

I know many extremists will respond (or consider responding) to this post. The question for them is whether or not they would honestly pay the difference between reasonable and extreme for a small outdoor job. I seriously doubt it.

Offline Pnw painter

  • Posts: 209
Re: RRP Clarification
« Reply #2 on: May 17, 2019, 07:48 PM »
Look up the RRP guidelines. Google RRP and I’m sure the Government has a website for homeowners that explains the process and everything you need to know. Once you have this info just make sure the contractor follows all the guidelines.

Just today I talked with another painter about a large project that has alligatoring paint and lead. He said that for the most part they either use a paintshaver hooked up to a vacuum (I think they use Festool vacs) to remove all the coatings or they scrap all the failing paint and encapsulate the lead using 2 coats of PeelBond primer.

We didn’t get into the specifics of on-site containment of lead chips and dust.




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Offline George Oliver

  • Posts: 36
Re: RRP Clarification
« Reply #3 on: May 17, 2019, 08:19 PM »
As far as I know from the certification classes I've taken the site protection rules aren't really performance based. In other words if you're disturbing more than the minimum number of square feet you have to do the full site protection to be in compliance.

That said, you could say there is a fair amount of theory and practice when it comes to lead mitigation.

Offline mrFinpgh

  • Posts: 305
Re: RRP Clarification
« Reply #4 on: May 17, 2019, 10:20 PM »
It's a small job and if there is no interest other than this company and they are offering a fair price go with them. I am sure if you look you will find a painting contractor who will blow the job out of proportion taking RRP to the extreme and come back with a ridiculously high quote. Then do you go with the reasonable quote or the crazy-high quote for an exterior paint job. If this were inside the house I'd be more concerned and if much more than scuff sanding I'd take the appropriate measures to minimize the risk.

If it makes you feel better call someone else out and have them perform a lead test. When considering any law or regulation reasonableness has to be considered and usually is not when legislation is passed or rules are made. Also, keep in mind that lead paint was used almost exclusively up until the 1978 because it was durable and held up to abuse. It was not until kids were left unsupervised eating window stools that it became a problem.

I know many extremists will respond (or consider responding) to this post. The question for them is whether or not they would honestly pay the difference between reasonable and extreme for a small outdoor job. I seriously doubt it.

I agree with you about reasonableness.  I always do try to consider the practical reasoning behind the laws and prescriptions.  For example, the obvious thing here is to remove any possibility of exposure to lead dust.  Thus, the prescribed behaviors like wet scraping/ wet sanding, hepa vacs, plastic everywhere, respirators, disposable clothing, etc.. all are intended to prevent 'contamination' of either the site or or the worker. 

For me, the issue is knowing where reasonable becomes a bad idea. For example, if sanding using a cordless sander attached to a dust bag, this would obviously not meet the hepa requirements.  Now there is lead dust being dispersed everywhere.   I hear that you can sand with a certified hepa attached vacuum now.  At the same time, are they sanding lead paint, or are they sanding paint that is sitting over lead paint?  When I sand a piece of plywood, I do everything I can _not_ to sand the substrate  [laughing] .  I've read that the rules are different and the logic around the lead/chemistry is kind of beyond me.

As a DIYer, my general inclination is to try and follow the rules and do the best I can.  So for things like lead, I typically do mask off the room, spray things down,  avoid dry scraping or dry sanding, and wear a respirator/disposable clothes. Is that extreme?  I don't know.  I don't have a HEPA air filtration unit running, and I don't post any signs...

Offline mrFinpgh

  • Posts: 305
Re: RRP Clarification
« Reply #5 on: May 17, 2019, 10:34 PM »
Look up the RRP guidelines. Google RRP and I’m sure the Government has a website for homeowners that explains the process and everything you need to know. Once you have this info just make sure the contractor follows all the guidelines.

Just today I talked with another painter about a large project that has alligatoring paint and lead. He said that for the most part they either use a paintshaver hooked up to a vacuum (I think they use Festool vacs) to remove all the coatings or they scrap all the failing paint and encapsulate the lead using 2 coats of PeelBond primer.

We didn’t get into the specifics of on-site containment of lead chips and dust.

Sent from my iPhone using Tapatalk

I've read them a few times.  I've spent a lot of time lurking on painttalk seeing how pros approach the issue and what the state of the art is. Amazing how divergent the attitudes among professionals seems to be. 

My understanding of the EPA rules is that any surface that has any lead paint on it is considered lead painted, no matter how many layers of paint sit on it.

As a painter, is it bad form if i ask for specifics about how they plan to address all these things? 


Offline mrFinpgh

  • Posts: 305
Re: RRP Clarification
« Reply #6 on: May 17, 2019, 10:36 PM »
As far as I know from the certification classes I've taken the site protection rules aren't really performance based. In other words if you're disturbing more than the minimum number of square feet you have to do the full site protection to be in compliance.

That said, you could say there is a fair amount of theory and practice when it comes to lead mitigation.

Yes, 20 sq ft of exterior or 6ft interior.

I think, in all, it's about 200sq ft of painted surfaces, so this rule would definitely apply.

Best,
Adam