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Old 10-30-2010, 03:31 PM   #1
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Default Certified Renovator - What to test?

We've discussed much of the following, but wanted to put it down in writing. These are my thoughts ...




In talking with hundreds of Certified Renovators (CR), I’ve realized that they (CRs) aren’t testing near enough components.

The following information is written to help the CR know what to test. I’ve verified it (numerous times) with the folks at the EPA hotline, getting clarification from the EPA Q&A, reading the rule itself (slowly and in great detail) and with the EPA lead based paint enforcement division.

You are not going to like what I’ve discovered.

8 Hour Renovator Class

When most CRs went through the 8 hour course only a few minutes was dedicated to this subject. Your instructor was supposed to say 2 things.

1. Read the actual rule.
2. And read the actual rule again.

The actual rule says in 745.82(2); “Renovations in target housing or child-occupied facilities in which a certified renovator, using an EPA recognized test kit as defined in §745.83 and following the kit manufacturer's instructions, has tested each component affected by the renovation and determined that the components are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight”. “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”.

Breaking It Down

From above, we learn …

1. That each component needs to be tested.
2. Unless the components are a part of a larger component system (integrated whole), like stairs … a window or a door.

What is a component? The actual rule says; “Component or building component means specific design or structural elements or fixtures of a building or residential dwelling that are distinguished from each other by form, function, and location”. The definition continues giving examples.

So, to tell if it is a component, you must ask yourself these questions …

Does it have a specific design or structural elements?

Or fixtures of a building or residential dwelling that are distinguished from each other?

1. Does it have a different form?
2. Does it have a different function?
3. Does it have a different location?

What is a component system (integrated whole)? A component system is made up of a variety of components. Examples would be like a stair case, window or door.

A stair case is a component system made up of a variety of components (treads, risers, stringers, newel post(s), railing cap(s), balustrades and possibly other components).

A window is a component system made up of a variety of components (sill, sashes, jambs, mullions, stool, apron, heads, troughs and possibly other components).

Putting It All Together (Examples)

Example Number One, An Exterior Side.

Let’s say a home has 4 exterior sides to it. For now, we are only going to concern ourselves with one of those sides. As Certified Renovators, we would need to check the following components that will be disturbed ...

1. Frieze board
2. Drip Edge
3. Corner boards (each corner board, because they are separated by location)
4. Soffit
5. Fascia
6. Siding
7. Gable Vent
8. Rafter Tails
9. Gutter
10. Gutter Downspout
11. Trim
12. Molding
13. And any other individual components

You would also need to check the component systems, like a window. Let’s say there are 4 windows on that side of the house. Since each window is a separate component system, you must perform the following test on each and every window on that side of the house.

What to test on a window …

1. Sashes
2. Mullions
3. Casings
4. Jambs
5. Sill
6. Apron
7. Head
8. Trough
9. And any other components

Do you need to check each and every mullion? Not if the painting history is the same. If the mullions painting history is the same, you only need to check 1 mullion on that window. However, you would also need to check at least 1 mullion on the other 3 windows if the painting history is the same.

Example Number Two, An Interior Room

Let’s say this room has 4 walls, 2 doors and 2 windows. You would need to check the following individual components …

1. Each Wall
2. Crown Molding
3. Chair Rail
4. Wainscoting
5. Baseboard
6. Ceiling
7. Hardwood Floor
8. Quarter Round
9. And any other component.

You would also need to check each and every window as described under example number one. You would also need to check each door in several spots, since it too is considered a component system.

I Can See The Rage Building

Remarks I usually hear at this moment are “this is overkill”, “this is ridiculous” and some comments I can’t put into print. My response, “I agree with you”! However, from what my research shows me … it is the law.

Try to remember that as CRs, we only spent a few minutes learning how to use the LeadCheck swab. We weren’t taught in “what to test” ... just how to use the LeadCheck. For that type of instructions, you need to take a 24 hour Lead Inspector course and pass the test (and in many states, pass a second state test).
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Old 10-30-2010, 03:56 PM   #2
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So 1 tread can be used as part of the whole stair system but 1 part of a window can't be consider as a whole window???
This does not follow the logic of an intagrated system.
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Old 10-30-2010, 04:00 PM   #3
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I think you are missing the common sense factor. Each component can be considered as the whole if it apears to have been painted at the same time.
I'm going to consider that the entire window was painted at the same time just like you can assume the entire stair system was painted at the same time.
I will test Siding as 1,trim as 1,windows as 1 etc... I think I will be fine.
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Old 10-30-2010, 04:03 PM   #4
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Quote:
Originally Posted by aaron61 View Post
So 1 tread can be used as part of the whole stair system but 1 part of a window can't be consider as a whole window???
This does not follow the logic of an intagrated system.
If you are talking about common sense ... I agree. But the logic (at least to me) is there.

The 1 tread can not be used as part of the whole stair system. But 1 tread can be used as a representation of the other treads if the painting history is the same.

However, if you have 2 stair cases ... 1 tread on each stair case must be tested.

When I talked to the EPA, they actually made it worse. Example, they wanted on a window for the left jamb to be tested ... top jamb and the right jamb to be tested separately.
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Old 10-30-2010, 04:16 PM   #5
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Quote:
Originally Posted by aaron61 View Post
I think you are missing the common sense factor. Each component can be considered as the whole if it apears to have been painted at the same time.
I'm going to consider that the entire window was painted at the same time just like you can assume the entire stair system was painted at the same time.
I will test Siding as 1,trim as 1,windows as 1 etc... I think I will be fine.
If this is common sense, then it would also be common sense that all the exterior sides of the windows would be painted the same color and you would only need to check 1 window on the exterior. However, the EPA disagrees.

I've checked older homes to where the fascia is neutral ... the molding above the fascia is hot and the quarter round above the molding is neutral.

I've also found where one window sill is hot and another is neutral.

I've found where the frieze board on the porch is hot and the frieze board along the front is neutral.
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Old 10-30-2010, 05:13 PM   #6
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#2 of your OP states that:
“For instance, a stair tread MAY represent the whole stair system if the painting history of both is similar”. “If the painting histories are similar.
Therefore 1 part of a window MAY represent a whole window!
I would not assume all windows....there is a chance that Grampa painted a couple of windows 1 year and a couple the next....1 side of a house 1 year and another the next.Chaces are your going to hit a positive way before you test more than 5 or 6 component systems IMHO.

I also agree with anothers post that you can usually get a good feel just by looking at the home. I'm going to look harder at a home from before the 50's than a home of the 70's.
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Old 10-30-2010, 05:40 PM   #7
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Aaron,

I see where it can be confusing, so I edited it to just reflect the actual rule.
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Old 10-30-2010, 06:16 PM   #8
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It's really not confusing to me. I believe you had it correct before you edited! That was taken straight from the rule.1 component can represent the whole!

I would just always error on the side of caution.The folks from the EPA that I spoke with clarified enough for me to understand it. I think your taking it a bit far and I can see where you would want to.

But for me I'm going to use common sense.I will use Lead safe Practices on old homes regardless,but if someone has a home that was built lets say in the 60's,I'm going to test A window or 2,The siding & The Trim. If I feel comfortable I will move forward accordingly.
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Old 10-30-2010, 11:42 PM   #9
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I have seen enough older homes to understand that various elements of any one "system" could be newly replaced after 1978 while others could be dating back 75 - 100 years.

In the room in which I am sitting (my office) I can personally attest that some elements of just one window were new two years ago (header and stool), sashes were replaced after 1980, and the majority of the other elements 75+ years ago.

But knowledge of specific "systems" aside, I think we all agree that "EPA" and "logic" are not two words that have many similarities.

And from my experience, I would highly recommend that if you want to comply with the PPR rules, that you test and document each element or assume it is all lead.



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Old 10-31-2010, 12:09 AM   #10
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If I were to look at that window I bet I can tell which are the new parts as well. Test the old part!
If I'm not going to be sanding that said window then it doesn't matter.
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Old 10-31-2010, 12:18 AM   #11
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Quote:
Originally Posted by aaron61 View Post
If I were to look at that window I bet I can tell which are the new parts as well. Test the old part!
If I'm not going to be sanding that said window then it doesn't matter.
Absolutely, if you ain't gonna be disturbing no paint with sanding, then you ain't gonna need no tests.

But, how do you repaint without sanding ?

Maybe you gots diff'rent wood, weather, and paint in the Sunshine State, but 'round here, muntins, rails, stools, aprons, mullions etc need a good sanding to make the finish job look smooth an' pretty.



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Old 10-31-2010, 01:04 AM   #12
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Arch, even if you need to sand you can carry a bucket of water and a sanding sponge and sand, as long as the dust is wet you will be fine. Sometimes I think we forget about wet sanding.In that case you don't have to treat it as if you making dust in the room.
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Old 10-31-2010, 02:29 PM   #13
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My vote is with Arch. There is lead based paint on components that you would never know it is lead based paint. Of course other times, you may can tell.

Everyone must do what they think best.

There are those contractors who will try and follow the law and contractors who will do their own thing and use their own judgement.
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Old 10-31-2010, 03:33 PM   #14
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Quote:
Originally Posted by johnpaint View Post
Arch, even if you need to sand you can carry a bucket of water and a sanding sponge and sand, as long as the dust is wet you will be fine. Sometimes I think we forget about wet sanding.In that case you don't have to treat it as if you making dust in the room.
Wrong. Completely wrong. If you are sanding, wet sanding is one of the techniques that is part of RRP procedures. But, wet sanding in no way at all circumvents compliance at all. Now, using a bonding primer and skipping sanding all together, yes. That would work.
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Old 10-31-2010, 04:10 PM   #15
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Quote:
Originally Posted by aaron61 View Post
It's really not confusing to me. I believe you had it correct before you edited! That was taken straight from the rule.1 component can represent the whole!
Not that it matters, but the part edited, wasn't from the rule. The part left in is from the rule.

and also from the rule

Component or building component means specific design or structural elements or fixtures of a building or residential dwelling that are distinguished from each other by form, function, and location. These include, but are not limited to, interior components such as: Ceilings, crown molding, walls, chair rails, doors, door trim, floors, fireplaces, radiators and other heating units, shelves, shelf supports, stair treads, stair risers, stair stringers, newel posts, railing caps, balustrades, windows and trim (including sashes, window heads, jambs, sills or stools and troughs), built in cabinets, columns, beams, bathroom vanities, counter tops, and air conditioners; and exterior components such as: Painted roofing, chimneys, flashing, gutters and downspouts, ceilings, soffits, fascias, rake boards, cornerboards, bulkheads, doors and door trim, fences, floors, joists, lattice work, railings and railing caps, siding, handrails, stair risers and treads, stair stringers, columns, balustrades, windowsills or stools and troughs, casings, sashes and wells, and air conditioners.]
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Old 10-31-2010, 07:40 PM   #16
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Quote:
Originally Posted by DeanV View Post
Wrong. Completely wrong. If you are sanding, wet sanding is one of the techniques that is part of RRP procedures. But, wet sanding in no way at all circumvents compliance at all. Now, using a bonding primer and skipping sanding all together, yes. That would work.
Did I say it did? No, but you wish I did, right?
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Old 10-31-2010, 07:42 PM   #17
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If I were testing the house for lead and found it, I would not act as if it had no lead, but it is not that hard to work with compliance anyway with small areas that need wet sanding. What is you motive for all this anyway?
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Old 10-31-2010, 09:11 PM   #18
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Sorry if I misunderstood your post, but I thought you were saying wet sanding would make so you did not have to act as though you were creating dust in the room. You would still have to do full containment, full clean-up procedures, full everything.
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Old 10-31-2010, 09:16 PM   #19
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Sorry if I misunderstood your post, but I thought you were saying wet sanding would make so you did not have to act as though you were creating dust in the room. You would still have to do full containment, full clean-up procedures, full everything.
Well the less mess you make, the less work you have, the less clean up and so on.
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Old 11-01-2010, 04:07 PM   #20
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Default Epa q&a

Question

When testing a property for the presence of lead prior to beginning a renovation using an EPA-recognized
test kit, must I test every component affected by the renovation?

Answer

Yes. Because certified renovator training does not cover sampling protocols, certified renovators using EPA-recognized test kits to determine the applicability of the RRP Rule must test each and every component that will be affected in order to determine that the RRP Rule does not apply to a particular
renovation.

Question

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?


Answer

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.

Question

Is a lead-based paint inspection, performed by a certified inspector or risk assessor, that includes a
written determination that various building components are free of paint or other surface coatings
containing lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight
sufficient to determine compliance with requirements of the RRP rule?


Answer

The RRP Rule does not apply to target housing where a certified inspector or risk assessor has
determined that the components affected by the renovation are free of regulated lead-based paint or that
a property is free of lead-based paint for the purposes of the Lead Disclosure Rule.
The RRP Rule does not require certified inspectors or certified risk assessors to test each and every
component that will be affected by a renovation. Certified inspectors or risk assessors are free to conduct
representative sampling, so long as the components to be tested are chosen in accordance with
documented methodologies, such as the HUD Guidelines. However, because certified renovator training
does not cover sampling protocols, certified renovators using EPA-recognized test kits to determine the
applicability of the RRP Rule must test each and every component that will be affected in order to
determine that the RRP Rule does not apply to a particular renovation.
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