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EPA Question

 
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Old 12-05-2010, 07:44 PM   #1
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EPA Question


I've read a bunch of stuff on this, but am posting this here for advise (of course any advise given won't be taken as law). I'm going to blast paint off of a 30x12 interior brick wall (so it is larger than the 6' that is allowed). Before I blast I will use a test kit to test the paint. I'll even scrape some of the paint in case there are multiple layers.

Obviously if the test is negative I'll blast away.

If it comes back positive I was going to not proceed and get a hold of a certified person... but, I was doing some reading and it said the EPA rule applied to housing and child occupied facilities. This shop makes and sells custom corsets, drapes, etc. The building is around a 100 years old, but I have no idea when the brick would have been painted (it could have been 10 years ago or 90 years ago). No children are in this place on a regular basis. Does that mean I can blast if it tests positive?

I'm going to do the test either way for peace of mind, but what are my options if it is lead based.



The rule affects paid renovators who work in pre-1978 housing and child-occupied facilities, including:
  • Renovation contractors
  • Maintenance workers in multi-family housing
  • Painters and other specialty trades.
Under the rule, child-occupied facilities are defined as residential, public or commercial buildings where children under age six are present on a regular basis. The requirements apply to renovation, repair or painting activities. The rule generally does not apply to minor maintenance or repair activities where less than six square feet of lead-based paint is disturbed in a room or where less then 20 square feet of lead-based paint is disturbed on the exterior, but this does not include window replacement, demolition, or prohibited practices.
Previously, owner-occupants of homes built before 1978 could certify that no child six years of age or younger or pregnant woman was living in the home and "opt-out" of having their contractors follow lead-safe work practices in their homes. On April 23, 2010, to better prevent against lead paint poisoning, EPA issued a final rule to apply lead-safe work practices (PDF) (18 pp, 121K) to most pre-1978 homes, effectively closing the exemption. The rule eliminating the opt-out provision became effective July 6, 201
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Old 12-05-2010, 10:53 PM   #2
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Re: EPA Question


Hey john, You might try the EPA hotline number but I bet you can't get a straight answer.Emergency Response Hotline (800) 282-9378

I'm not sure if you can ever media blast lead without certain precautions. Tenting for containment proper mask a lead certified person on hand, I have eevn heard of the need to shower after the job. Kids or no kids I think blasting lead is risky if somehow there was a complaint, but it isn't like the guys hireing you are going to complain.

I did check and I found out that if you are not certified then you are not qualified to perform or read a test. Therefore, even if a test you do your self, say there were children involved, came out negative and it was a test which says aproved by the EPA, which it would have to, you could still be fined for working on a pre 78 child ocupied structure without a certifification that it was lead free. Who knmows if they would but I wouldn't want to test them. $30,000 a day is a little steep.

Let us know what they say. You might want to call from a pay phone, if those still exist.

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Old 12-06-2010, 12:15 PM   #3
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Re: EPA Question


I called the hot line and I liked the answer. They said that commercial properties are not included in the new EPA rules. The only commercial properties that would count are daycare's, child care facilities, and things of such nature. They did ask my state to confirm, so perhaps there are states that are stricter (probably California).

I'm still going to do a self test kit for my own mind and to inform the customer if it is positive, but I'm blasting it this week.

I did find out that you can't do your own tests (except in this case where I'm not required to test at all). For a home (pre 78) you would have to have a certified person do the testing first to confirm yes or no on lead.

And just to cover my own butt... I'm NOT certified and this was my interpretation of what I was told over the phone by the hot line. Don't take my word as law.
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Old 12-06-2010, 01:56 PM   #4
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Re: EPA Question


John, I just took the rrp class in November, so its fairly fresh in my mind. The way I understood it we should treat it like its lead even if we don't know or not. (before, during and cleanup) I also was told by the instructor that commercial buildings will have some of the same rules passed in just a few years. I'm just learning this all myself too.
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Old 12-07-2010, 08:21 AM   #5
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Re: EPA Question


I took the lead renovators class a few months back and what I found was that this is only the beginning and it's going to get tougher every year here on out.

When I asked the question about blasting the instructor told me that there's a big concern about open air blasting in residential areas and lead contamination on the ground surrounding the properties.

The course I took was facilitated by a training firm certified by the EPA in an urban area. There was a lot of discussions about lead, handling of lead paint and dust as well as how it impacts residential areas.

Just an FYI for anyone considering doing any auto restoration jobs or other backyard blasting jobs in a residential area or small rented garage next to a residential area... a lot of cars, trucks and commercial products prior to 1973 and even later used lead based paints.... you really need to be aware of that stuff, because these new lead laws impact anything with kids 6 and under.

I'm in New Jersey and it scares the Wee-Gees out of me every time I look at a job now. .
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Old 12-07-2010, 09:00 AM   #6
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Re: EPA Question


Johnny, Utah has adopted the RRP program, while commercial is exempt, I would still be cautious of blasting possible LBP. I would find a Certified Renovator to test for you, or even a Risk Assessor to test. While a CR can say say yes or no on the presence of LBP, a RA can determine the level, which may be under the requirement. OSHA would be a concern.

Here is the link to the Utah RRP program. I would call and talk to Bob Ford or Greg Mortenson, both of them are very helpful.

Nice to see a fellow Utahn on the forum!
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Old 12-07-2010, 10:51 AM   #7
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Re: EPA Question


Commercial might be exempt, but if it's next to a residential structure then it isn't.

This is a news story that happened over a year ago: http://www.paintsquare.com/news/arti...ackid=17243152

Every one I deal with on historic restoration projects in New Jersey and Eastern Pennsylvania bring the above story up in conversation as of late.

This has become a huge concern and I'm hearing it over and over on residential, commercial and especially in the public sector with all the Obama money that went into public school additions.

Cross your T's and dot your I's.

Last edited by MasterBlaster; 12-07-2010 at 10:54 AM.
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Old 12-07-2010, 02:34 PM   #8
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Re: EPA Question


I called and talked to Greg, Bob was out of town. I also read the article from the link. I'm going to use a self test kit. Greg said the one I got is very good. If it is negative for lead then I'll do the job. If it is + at all I don't think it is worth the headache or potential liability. Better to be safe than sorry. I'd hate to back out on the customer, but I think it would be warranted to do so. I hope it is lead free!

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Old 12-07-2010, 03:48 PM   #9
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Re: EPA Question


While RRP doesn't apply, there are other EPA rules that do, so you should probably do some more homework. Given that's it's not covered under RRP, you are free to test it for lead, whether or not you are certified. If there is LBP and you've got employees on this job, OSHA's "Lead in Construction" rules may also apply.
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Old 12-08-2010, 12:00 PM   #10
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Re: EPA Question


I show up today and before I unpack any equipment I get out my lead test kit. I get the small circle sample and stick it in the vial. It is allowed to be a medium brownish color. Results could be instant, but you should give the chemicals 10 minutes to ensure a complete result. The instant I drop the chemical into the vial it turns to a dark black! CRAP!! That was a good chunk of money I lost out on, not to mention I invested in some new tools (some ventilation blowers). Oh well, it is better than being fined a billion dollars.

I think I'm going to sign up and take the class. I think with what we do we should have a very solid understanding of all EPA rules. I know I could use a better understanding. If I did blast, seeing as how it was a contained room, where do you end up dumping the media? Wouldn't it now have a certain level of lead and need to be dumped at a special place? How expensive is that?

John
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Old 12-08-2010, 07:43 PM   #11
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Re: EPA Question


I think you made a smart choice. The repercussions could have been bad.
Contact Jeff Nelson at Summit- jnelson"at"summitutah.com
Here is a link to the Utah course, they did mine and my trainer had a long OHSA background, having a trainer with experience is much better!

I'd also get on the list for OHSA 10 hour training thru WCF. Both trainings can used for your continuing education requirements for your state license.

Good luck!
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Old 12-08-2010, 10:19 PM   #12
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Re: EPA Question


John, Good call. Get your training, and get certified than you will know what the EPA wants and you won't lose out on the next questionable job. Good luck.
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Old 12-09-2010, 07:20 PM   #13
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Re: EPA Question


John you could paint it with Enviro-Prep. Then it will no longer fail a tclp test or need special disposel.

I have not used the product but I spoke at length with them. You send them a sample and they tell you how many mills to spray.
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Old 12-09-2010, 07:31 PM   #14
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Re: EPA Question


Quote:
Originally Posted by kswoodbutcher View Post
John, Good call. Get your training, and get certified than you will know what the EPA wants and you won't lose out on the next questionable job. Good luck.
As I posted earlier, there's a lot more to "what the EPA wants" than what you learn in RRP class. The long-standing EPA regulation about lead in water from power-washing was a total shock to nearly everyone in my RRP class, for instance.
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Old 12-10-2010, 06:01 AM   #15
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Re: EPA Question


Has anyone tried to hire a CR or RA.? I assume they charge for the service plus their travel time and a tclp test at the begining, and if it was negative at the end of the job as well? I know I would need all of that up front, ecept for the second tclp test cost. I bet it's hard to get that out of a customer. sounds like about $400 and then also the second tclp test on the price to cover the second tclp test. I guess you clean up like normal but hold it in bags while another tclp test is done on a sample.
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Old 12-10-2010, 08:48 AM   #16
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Re: EPA Question


Not sure how this applies to blasting, but for painting:

Depends on the size and scope of the job. If you can have a CR come out and use less than a dozen swabs (that could be one room's worth) for $100 bucks and eliminate the need for RRP containment, it could cost less in the long run.

A larger job it would make sense to spend a few hundred and have a RA come out with an XRF, even if lead is detected, it may be under the required by RRP (but not OHSA, which has no minimum).

As far as "collecting a sample" you, or even a CR cannot do that. If you are doing an RRP job, you will have a CR that can do the cleaning verification at the end.
Or you can hire a third party, a Dust Sampling Technician (like me) who will come out and collect dust samples and have them tested.
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Old 12-11-2010, 09:01 AM   #17
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Re: EPA Question


Quote:
Originally Posted by MasterBlaster View Post
I took the lead renovators class a few months back and what I found was that this is only the beginning and it's going to get tougher every year here on out.

Just an FYI for anyone considering doing any auto restoration jobs or other backyard blasting jobs in a residential area or small rented garage next to a residential area... a lot of cars, trucks and commercial products prior to 1973 and even later used lead based paints.... you really need to be aware of that stuff, because these new lead laws impact anything with kids 6 and under.

I'm in New Jersey and it scares the Wee-Gees out of me every time I look at a job now. .
I spoke to the EPA and an instructor he said this only is for homes not auto's although my new portable blast room should take care of the dust even when blasting in a driveway. I just turn away blasting paint on homes I plan on taking the class so I'm with in the law to test the paint. I'm not even going to bother blasting lead paint even with the proper equipment. I blast mostly cars now.
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Old 12-11-2010, 10:39 PM   #18
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Re: EPA Question


Kell I'd love to see a pic of that tent set up. Have you tried it out yet?

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