Asbestos & Lead

Steve Richards

I'm going to paint the trim on a (mid 50's built) asbestos-shingled house.

Is it just me, or does it seem silly to test for lead paint, on a house covered with asbestos?

Tom Struble

mama says silly is as silly does

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Tom

Steve Richards

heh

ok..if I do test it..then I'm silly?

I think so too!

I'm really tempted to just skip the lead testing on this one.

Tinstaafl

Asbestos and lead are covered by two completely different sets of rules. The presence of one has nothing to do with the presence or absence of the other.

But you're never actually required to test for lead, if you want to just go ahead and assume it's present. Which is probably what I'd do in this case.

hiteams

Been doing some studying on this subject. From what I've been reading, many certified renovators aren't testing near enough spots.

Example: If you are disturbing 10 windows (sand & paint or replacing) ... you would need to test around 6 components on each window. In other words, around 60 test if sand & painting. Around 120 test if replacing windows.

At $2.50 per test swab + the labor to do it ... it becomes pretty expensive quickly.

It may be cheaper to not test and just assume.

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Dean

Steve Richards

maybe so, hiteams..thanks


On this particular house...the (steel casement) window sash glazing and paint film are ok, no scraping or sanding, so
(far as I know) I wouldn't have need or reason to test them.

I was considering testing:
1 window sill on each side of the house, and the facia board -front and back.
Gutters and downspouts are factory finish
Soffit paint is all tight.

If it's JUST the (15 peeling) sills testing positive for lead, it'd be under the 20 sq ft anyhow.

Sooo... as long as the garage tests ok...

Maybe I'll be able to still have all 50 of my (already outdated) brochures, AND be able to "get rid of" some of these swabs!

hiteams

According to this http://toxics.custhelp.com/cgi-bin/t...i=&p_topview=1 it sounds like a factory finish needs to be tested, if it will be disturbed.

According to this http://toxics.custhelp.com/cgi-bin/t...i=&p_topview=1 and this http://toxics.custhelp.com/cgi-bin/t...i=&p_topview=1 each (all 15) window sill will need to be tested.

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Dean

Steve Richards

You are correct.

I'm heading over there in about an hour.

Thanks for the (timely) heads up!

(cut it a little close there, didn't ya?) heh

Steve Richards

Update...

I now have 49 (already outdated) brochures and 3 less swabs, than I had last night.

Steve Richards

update (as if anyone cares)...

1/2 done with the RRP stuff. On a little job like this, the scrape/sand would normally take me 1 day instead of 2.

So not as bad as I thought.

Used LOTS of plastic, took LOTS of pictures.

Dust-buddy shroud on my sander..I give a c+.

After doing this stuff so long, adding something new makes it ALMOST fun again.

(almost)

hiteams

Thanks for the update! Glad to hear about the dust shroud before being bought.

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Dean

Steve Richards

The shroud makes it hard to see what I'm doing, and its added weight (along with the vac hose's) is noticeable...even the next day. My guns are hurtin'!

I'm assuming that I need to fill out and give the owner of this property a 'lead test result form'..even though he didn't request the testing. Right?

(I tested hoping to NOT find lead, saving me time and him money)

hiteams

Legally, yes.

Hope the owner isn't mad.

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Dean

Steve Richards

I think he'd have been "madder" had I gone through the process(es) of "assuming", and then learned later there was no LBP...to have been concerned about in the first place.

Hard tellin'

But I'm sure he'll have preferred that I'd just stuck with "doing it like I used to" in any case.

I can only hope he don't just start looking around for someone that will.

FStephenMasek

Good news - that is not correct. If you examine Chapter 7 of the HUD Title X Guidelines, you will see that there is no need to think the mullions, for example, are different from teh rest of the sash. Simply test the inside frame assembly, the inside sahes, the outside frame assembly, and the outside sashes.

Some testing combinations have multiple parts. For example:

All of the parts of an interior window sash;

All of the parts of the window frame and trim (casings, stops, jambs, aprons, Etc.);

All of the parts of baseboard assembly (main board, quarter round, and so forth);

All of the parts of a door (stiles, rails, panels, mullions, panels, Etc.); and,

All of the parts of a door frame assembly (jambs, stops, transoms, casings, Etc.).


I have one funny story regarding lead paint and asbestos-cement shingles. We had a client tearing down a large section of an old military base with a report done by somebody else who forgot that an XRF machine can read through thin materials such as asbestos-cement shingles. They claimed the shingles were coated with lead paint, when they were actually reading the lead paint on the stucco below the shingles! If you have the shingles tested, be sure that the consultant you hire checks to see that they are not picking-up lead due to some older materials under the shingles.
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hiteams

Stephen,

Certified Renovators do lead test differently than Lead Inspectors/Assessors as shown in the FAQ on RRP ... http://toxics.custhelp.com/cgi-bin/t...i=&p_topview=1 and http://toxics.custhelp.com/cgi-bin/t...i=&p_topview=1.

Certified Renovators spent 30 seconds in hands on training in lead testing using a test swab. Chapter 7 is for lead inspectors/assessors, not Certified Renovators. In the RRP rule itself, it explains that Certified Renovators must test each component of an integrated whole (combination). Example: A CR does not have to check each and every mullion on a particular window ... but they must check at least one spot on the mullion.

On the next window, a mullion has to be checked again.

Once again, Lead Inspector/Assessors do it differently than Certified Renovators

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Dean

Steve Richards

Next job, new question.

Decorative exterior wooden shutters. The house was built in the 50s, but I really doubt the shutters are that old.
They should all have the same paint-history.

Just need to test one?
(of course I mean if I'm going to test at all)

hiteams

You need to test all of them, just like you needed to test all window sills on your previous job.

A certified renovator is not a lead inspector/assessor. A certified renovator has to check all (each and every one) components.

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Dean

Steve Richards

Well thanks for bumming me out again!

(actually, that's kinda what I thought..but I wanted to hear it from you)

As I cross the RRP bridge of compliance....thanks for holding my hand.

FStephenMasek

In many states (California is one), only an inspector/risk assessor can perform a lead inspection, so the whole swab discussion does not apply. Here is what is actually in the regulation:

? 745.82 Applicability.

(a) (2).... has tested each component.... 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.

Here is the question and answer you referenced:

Q: 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?

A: 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.

The only difference between what is written in the regulation and their answer and what is in Chapter 7 is that you would need to test each window. However, the mullions and so forth do make an "integrated whole," the sash, and the frame assembly is an "integrated whole," unless there is evidence to the contrary.

The earlier comment about the cost of just the swabs and time to use them adding-up quickly is certainly correct, and is a good reason to find a good consultant who can come in to perform the inspections. This is especially so on the larger jobs, or on groups of small job sites which can be visited one after another the same day.
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