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Old 11-01-2010, 03:48 PM   #21
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Default Testing Doors

This is with the assumption that you are just painting one side of the door.

On doors, you would need to test the

1. Door slab
2. Door trim (casing) on 1 spot.
3. Door jambs on 1 spot.

This is pretty much true whether the door has been repainted or refinished in the past or not.
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Old 11-01-2010, 04:22 PM   #22
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Default Testing Walls

If you're in a room with walls, you would have to test one spot of each wall. Walls connected together are not considered an integrated whole.

Crown, chair rail, baseboard, shelves and etc. are not considered an integrated whole of that wall.

On the exterior ... the same applies.

If the exterior wall has siding, you do not have to test each separate board. One test will be good enough on that wall.
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Old 11-01-2010, 10:59 PM   #23
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Default Testing Stairs & Windows

Got the word ...

Integrated whole can also be understood as testing combinations. In general, certified renovators would need to almost test the same components and testing combinations as a lead inspector. If you think about it, it wouldn't make much since that certified renovators can check a lot less than lead inspectors/assessors.

On stairs, the testing spots would be ...

1. the integrated whole is the risers and treads
2. balustrades (only 1 if painted same color)
3. stringers
4. rails,
5. newel post

and other components.

On windows, the testing spots would be ...

1. the integrated whole would be the stop and jambs.
2. Another integrated whole (IW) would be the casing (top and side casings together).
3. Another IW would be the sash (along with the mullions).
4. Trough
5. Sills or Stool
6. Window Head

So the original post is correct, except I need to take out the mullions. Will do so via edit tomorrow.
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Old 01-27-2011, 08:52 AM   #24
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I feel this is great info to understand to understand and realize the components that are associated with an Integrated Whole. However, it is how you use this information that can make you crazy or give you something to take away from it.

Think about it for a minute... If you had to check every component and one part of it has lead and another doesn't. Does this mean the preventative preparation is going to change at all? Doesn't this mean wasting tons of lead checkers? And Time? It may or may not. It truly depends on the project you are involved with.

Basically, the larger the project the more you should check the individual components at large, such as the fascia vs the siding. However, only concern your self with checking where you could potentially disturb the lead dust like in the case of loose and peeling paint for painters. Or removing a window for a window guy. Only worry about where the dust could be disturbed.

You see, these rules can be easily blown out of proportion. However, with a little bit of actualization visualization on a job by job, project by project, problem/solution basis, the stress can be lowered down to being in the damned hot suites and masks. lol.

Furthermore, We have been monitored a couple times now as a company. The first time we were not doing everything correctly and had to re-educate ourselves on the process in 2008. We paid a small fine, and now have mastered lead paint removal on the outside. After a recent surprise check on a job we did, they said we did an excellent, perfect job.

Quick tip: On the inside, learn to use heavy duty PVC tubing, duct tape, and 3 mil plastic to build yourself a custom booth for removing lead in isolated areas of the home.
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Old 01-27-2011, 09:02 AM   #25
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Quote:
Originally Posted by Dean CRCNA View Post
This is with the assumption that you are just painting one side of the door.

On doors, you would need to test the

1. Door slab
2. Door trim (casing) on 1 spot.
3. Door jambs on 1 spot.

This is pretty much true whether the door has been repainted or refinished in the past or not.
Now here is a statement that could make someone squirm in the pants holding back a lot of frustration.

This sounds crazy, but is only necessary if you potentially could disturb dust in this area. The other thing is, if the majority of a project has lead, just treat it as if all of it has lead if possible. Especially for homes from the 1978 and earlier and there is no recorded proof or clear sign of remolding.
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Old 01-27-2011, 10:06 AM   #26
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Just remember, if you touch that door with sand paper, you are disturbing lead dust regardless of how many layers down the lead is according to the EPA.
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Old 01-27-2011, 10:59 AM   #27
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The key term here to understand is the key phrase, "must test each and every component that will be affected." This is in a very high language for the average painter. LOL. Basically goes back to making it simple and taking a true evaluation of your job scope. Since we are all painters here this means to check everything that could absolutely cause dust. Which means for the most part loose and peeling paint.

Are there any other cases we should concern ourselves?
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Old 01-27-2011, 02:18 PM   #28
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Quote:
Originally Posted by Custom Brush Co. View Post
Think about it for a minute... If you had to check every component and one part of it has lead and another doesn't. Does this mean the preventative preparation is going to change at all? Doesn't this mean wasting tons of lead checkers? And Time? It may or may not. It truly depends on the project you are involved with.

Basically, the larger the project the more you should check the individual components at large, such as the fascia vs the siding. However, only concern your self with checking where you could potentially disturb the lead dust like in the case of loose and peeling paint for painters. Or removing a window for a window guy. Only worry about where the dust could be disturbed.

You see, these rules can be easily blown out of proportion. However, with a little bit of actualization visualization on a job by job, project by project, problem/solution basis, the stress can be lowered down to being in the damned hot suites and masks. lol.
1. If you inspect an exterior and find that lead based paint is only on some columns, you only have to do RRP on those columns ... not on the whole exterior. So the preventive measures can change.

2. No where in the rule, does it state you only test "where you could potentially disturb lead dust". You can't even see lead dust.

3. You don't have to wear hot suits and mask for the RRP.
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Old 01-30-2011, 06:00 PM   #29
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1. If you inspect an exterior and find that lead based paint is only on some columns, you only have to do RRP on those columns ... not on the whole exterior. So the preventive measures can change.

2. No where in the rule, does it state you only test "where you could potentially disturb lead dust". You can't even see lead dust.

3. You don't have to wear hot suits and mask for the RRP.
Now this is getting really confusing. I don't sand unless there is or was loose and peeling paint.

But I thought of a time when I might sand. If there is a high gloss oil paint (containing lead) paint to get my latex paint to stick. Then that can cause lead dust. The chances of this happening are so rare because what kind of oil paint that has lead in it would still have a gloss shine and wouldn't be alligatoring and cracking all over, fading... Only on the inside of a house is this possible on paint appplied to walls and doors and frames. This is also rare and the house would be in shambles most likely.

If I am not disturbing the surface (i.e., scraping, sanding, heat gunning) then I am probably only cleaning the surface with water and a cleaning agent and painting it.

So if all we are going to do is paint on a project we know has or potentially has lead, then what is the point of doing all those tests?

This is my point. Do you get it? I mean why else should we concern ourselves with it.

And show me where and when it's ok not to wear suits and a mask to remove the loose and peeling paint. We were not taught this, OSHA doesn't approve or the EPA as far as I was educated. What page or rule does it talk of this?


One last thing, I agree if on an exterior you test and only columns only have lead then thats all you have to do, but this goes against a rule of thumb they teach, that if you find it here and there and there are no detectable traces one place but there are on another that you need to hire a service (really expensive) to double check cause there still could be lead there. So this goes to my point know your project. If it is been remodeled since and new siding is on but not fascia. check the fascia and only do RRP rule to it. But if there is no proof of past restorations and one place has lead, most likely all of it will. Then you can check further if needed or treat the project as all having lead.
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Old 01-30-2011, 06:29 PM   #30
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In the EPA class the slide clearly says workers "should" wear PPE, it is not required.
Quote:
EPA would like to clarify the requirements for personal protective equipment. The Occupational Safety and Health Administration (OSHA) has requirements for personal protective equipment, EPA does not. For many years, EPA has recommended the use of personal protective equipment as a way to protect workers and to help ensure that leaded dust and debris does not leave renovation or abatement work sites. EPA recommends that renovators make use of the minimum respiratory protection recommended by the National Institute of Occupational Safety and Health (NIOSH) for environments where lead is present, but respiratory protection is not required by the EPA regulations. In addition, disposable clothing, if removed and disposed of before the workers leave the work site, can provide additional protection for workers' families by ensuring that no leaded dust or debris is carried home on worker clothing. However, EPA does not require this and allows renovators to use other methods to ensure that dust and debris does not leave the work area, including the HEPA vacuuming of clothing, tools, and other items before they leave the work area.



But everyone has been following OHSA Rules concerning LBP all along right?

The signs are another issue, if you use what RRP requires, it does not meet OHSA Rules.
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Old 01-30-2011, 06:29 PM   #31
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Quote:
Originally Posted by Custom Brush Co. View Post
Now this is getting really confusing. I don't sand unless there is or was loose and peeling paint.

But I thought of a time when I might sand. If there is a high gloss oil paint (containing lead) paint to get my latex paint to stick. Then that can cause lead dust. The chances of this happening are so rare because what kind of oil paint that has lead in it would still have a gloss shine and wouldn't be alligatoring and cracking all over, fading... Only on the inside of a house is this possible on paint appplied to walls and doors and frames. This is also rare and the house would be in shambles most likely.

If I am not disturbing the surface (i.e., scraping, sanding, heat gunning) then I am probably only cleaning the surface with water and a cleaning agent and painting it.

So if all we are going to do is paint on a project we know has or potentially has lead, then what is the point of doing all those tests?

This is my point. Do you get it? I mean why else should we concern ourselves with it.
You only need to follow RRP when you are going to disturb paint. If you are not going to disturb a painted/stained surface, you do not have to do RRP and likewise, there is no need to test.

In your example of lightly sanding trim before painting ... this would fall under RRP ... even if you greatly suspect it to be non-lead based paint. You have to have proof and the proof is lead testing.

I think we may be saying the same thing, just in a different way.

Quote:
And show me where and when it's ok not to wear suits and a mask to remove the loose and peeling paint. We were not taught this, OSHA doesn't approve or the EPA as far as I was educated. What page or rule does it talk of this?
As Chris said, the actual RRP rule does not say anything about wearing suits/mask. See the rule itself. So, if you don't ... you won't get into trouble from the EPA. OSHA is a different matter, but we are not talking about OSHA here.

Plus, wearing a N-100 mask is not going to cut it for OSHA any way.

Quote:
One last thing, I agree if on an exterior you test and only columns only have lead then thats all you have to do, but this goes against a rule of thumb they teach, that if you find it here and there and there are no detectable traces one place but there are on another that you need to hire a service (really expensive) to double check cause there still could be lead there. So this goes to my point know your project. If it is been remodeled since and new siding is on but not fascia. check the fascia and only do RRP rule to it. But if there is no proof of past restorations and one place has lead, most likely all of it will. Then you can check further if needed or treat the project as all having lead.
If you have proof of new siding, and you are going to disturb it ... you have to do RRP, unless it is tested. They don't want a "judgement" call being done. They want "proof" (which is testing).
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Old 01-30-2011, 06:43 PM   #32
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Just wanted to add a note on suits. While the RRP rule itself doesn't require it, it can help with keeping the dust in the containment area, if you take off the suit before leaving the containment area.

Not saying it is not a good idea, just saying that the rule itself doesn't say you have to.
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Old 07-07-2011, 05:59 AM   #33
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In Australia we have regulations to follow and we are training our apprentices in how to deal with lead paint hazard as a competency for their apprenticeship, however most of the painters here don't follow them.

I have worked on the philosophy that if you find lead in any areas that are being worked on you treat the whole job as a lead risk job.

When you test for lead you can test one area and find no or low lead content and then test 2 feet away and find high lead paint content. That's why I recommend people treat lead as lead no matter what the content comes back as.

I don't know what other countries regulations are, but you can see how we deal with lead paint here at
http://www.paintingbrisbane.com.au/m...t_removal.html

I hope this gives you an understanding of how we deal with lead paint down under and if anyone can give me any tips on how you deal with lead I would greatly appreciate it.
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Old 05-19-2012, 10:36 AM   #34
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Finally, some clarification on what to test ... from the EPA RRP FAQ ...


Question:

I’m a certified renovator using an EPA-recognized lead test kit to determine whether or not I have to follow the Renovation Repair and Painting (RRP) Rule work practices. What components must test negative for lead-based paint in order to qualify for the exclusion in 40 CFR 745.82(a)(2)?

Answer:

Generally, a certified renovator using an EPA-recognized test kit must test each building component to be disturbed. The only exception to this requirement is when the components make up an integrated whole. In such a case, one or more component(s) may represent a system of components, unless it is obvious to the renovator that the components have been repainted or refinished separately.

A staircase, for example, is made up of numerous repeating components which can be grouped together as integrated wholes for testing purposes. For these purposes, staircase components can be grouped into the following integrated wholes: (1) treads and risers, (2) balustrades, (3) newel posts, (4) railing caps, and (5) stringers. A single individual staircase component (e.g., a baluster) may represent the remaining staircase components of the same group (i.e., the rest of the balustrades on the staircase) unless it is obvious to the renovator that the components have been repainted or refinished separately. Therefore, where an entire staircase is to be disturbed, EPA believes it will be necessary to test five surfaces: one tread or riser, one balustrade, one newel post, one railing cap, and one exposed stringer. So long as it is not obvious that the components have been repainted or refinished separately, a negative test for lead-based paint on an individual staircase component in each of these groups would mean that a renovation on that particular staircase could be performed without regard to the RRP work practices.

EPA also believes it appropriate to apply the integrated whole concept to windows and doors. For testing purposes, window and door components can be grouped into the following integrated wholes: (1) the window or door assembly and (2) the window or door trim. Window assembly components include the sashes, stops, head, jambs, sill or stool, and trough; door assembly components include the door slab(s), jambs, head, sill and threshold. As a practical matter, it is likely that interior and exterior surfaces of window and door assemblies were repainted or refinished separately and should be tested separately. Therefore, where both the window/door assembly and trim will be disturbed (e.g., a full-frame window/door replacement), EPA believes that it will be necessary to test four surfaces: one interior window/door assembly component, one interior window/door trim, one exterior window/door assembly component, and one exterior window/door trim. However, if you only disturb paint on the interior or exterior of a window then you only need to test the assembly and trim on that side. If it is not obvious that the components have been repainted or refinished separately, a negative test for lead-based paint on a component in each of these groups would mean that a renovation on that particular window or door could be performed without regard to the RRP work practices.

NOTE: Each window, door and staircase to be disturbed must be separately tested, even if in the same room. Also, negative testing results must still be documented in accordance with the recordkeeping and reporting requirements of 745.86(b)(1)(ii) and (iii), and 745.86(a) and (c). See also FQ 23002-18220.
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Old 05-19-2012, 06:33 PM   #35
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Quote:
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Finally, some clarification on what to test ... from the EPA RRP FAQ ...


Question:

I’m a certified renovator using an EPA-recognized lead test kit to determine whether or not I have to follow the Renovation Repair and Painting (RRP) Rule work practices. What components must test negative for lead-based paint in order to qualify for the exclusion in 40 CFR 745.82(a)(2)?

Answer:

Generally, a certified renovator using an EPA-recognized test kit must test each building component to be disturbed. The only exception to this requirement is when the components make up an integrated whole. In such a case, one or more component(s) may represent a system of components, unless it is obvious to the renovator that the components have been repainted or refinished separately.

A staircase, for example, is made up of numerous repeating components which can be grouped together as integrated wholes for testing purposes. For these purposes, staircase components can be grouped into the following integrated wholes: (1) treads and risers, (2) balustrades, (3) newel posts, (4) railing caps, and (5) stringers. A single individual staircase component (e.g., a baluster) may represent the remaining staircase components of the same group (i.e., the rest of the balustrades on the staircase) unless it is obvious to the renovator that the components have been repainted or refinished separately. Therefore, where an entire staircase is to be disturbed, EPA believes it will be necessary to test five surfaces: one tread or riser, one balustrade, one newel post, one railing cap, and one exposed stringer. So long as it is not obvious that the components have been repainted or refinished separately, a negative test for lead-based paint on an individual staircase component in each of these groups would mean that a renovation on that particular staircase could be performed without regard to the RRP work practices.

EPA also believes it appropriate to apply the integrated whole concept to windows and doors. For testing purposes, window and door components can be grouped into the following integrated wholes: (1) the window or door assembly and (2) the window or door trim. Window assembly components include the sashes, stops, head, jambs, sill or stool, and trough; door assembly components include the door slab(s), jambs, head, sill and threshold. As a practical matter, it is likely that interior and exterior surfaces of window and door assemblies were repainted or refinished separately and should be tested separately. Therefore, where both the window/door assembly and trim will be disturbed (e.g., a full-frame window/door replacement), EPA believes that it will be necessary to test four surfaces: one interior window/door assembly component, one interior window/door trim, one exterior window/door assembly component, and one exterior window/door trim. However, if you only disturb paint on the interior or exterior of a window then you only need to test the assembly and trim on that side. If it is not obvious that the components have been repainted or refinished separately, a negative test for lead-based paint on a component in each of these groups would mean that a renovation on that particular window or door could be performed without regard to the RRP work practices.

NOTE: Each window, door and staircase to be disturbed must be separately tested, even if in the same room. Also, negative testing results must still be documented in accordance with the recordkeeping and reporting requirements of 745.86(b)(1)(ii) and (iii), and 745.86(a) and (c). See also FQ 23002-18220.
:cens ored:
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Old 05-19-2012, 11:02 PM   #36
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So

Cross all the x's and tick all the boxes, soon it will be a felony to fart in this country, As fellow tradesmen and women I respect you all. But the regulations in this country are turning it into something like the UN . A lot of power, but a fat lot of use! Here is my concern, 1978 does not mean Jack! Who came up with that year?

I went to bid on a house last week, 1942 built, a friend said we could not touch it! When he told me about this rule, I looked for how to get certified, apparently if I take a1 day course at a price of $249.00 I will be EPA compliant.

Unless I am convinced that this compliance will be monitored as well as it is being used to make money of contractors then to me it's another tick in the box money spinner for government , just like back in the UK when they regulated security.

Yep
I will do the course, follow the rules blah blah blah, God tells me I have to submit to our authorities, and I don't have the luxury or desire to contradict that, but let's not forget, we are the professionals here, so let no man take away the confidence needed to maintain your identity as tradesmen and not contractual sheep as gas happened all over the world!
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Old 05-20-2012, 03:40 PM   #37
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Sorry folks,
Just read that again, and realized I went off on a rant. Yes I'm sure Lead Paint is not nice if your breathing it in all the time !
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Old 05-23-2012, 08:46 AM   #38
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Yeah, Finn..time to join the club.

Get ready for HO's to stare like deer in the headlights when you mention RRP, most of them have never heard anything about it.

Be prepared to lose some work over it too. Most folks won't spend extra money so you can comply with rules they've never heard of...especially when the next painter they get an estimate from may not even bring it up, and come in 30% under your bid.
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Old 05-27-2012, 09:59 AM   #39
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I have still yet to see and electrician or plumber on any job that follows any RRP protocol.
I remember I was sitting in an RRP class with some of my employees (I was already certified RRP) and decided to stir the pot as the class was falling asleep.
I asked the instructor "What happens when the electrician comes in and notches the ceiling while I am working? It happens". The instructor really had no answer other than to report the electrician to EPA (yeah right, the H.O. would be thrilled). The class awoke and and started on a similoar questioning as this thread. The instructor started sweating.
My view is that it is a law with good intentions made by politicians looking for good P.R. but it is not written well and makes the painter the "Boogey Man" while most trades ignore. We just have to do our best to comply. Remeber if you are certified. you will be the first that the EPA will audit. They know who you are. They do not know the "Trunk Slammers" and "Gypsy" operations that will not and do not care about regulations.
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