James Poggi Construction Newsletter

In the state or Oregon the Construction Contractors Board requires a special license for contractors to bid or work on pre-1978 residential structures. This special license is given after special training classes and is subject to renewal every two years. Make sure your General Contractor and the Subcontractors have this special license. This certifies that they have taken the extra steps needed to learn and hopefully work in line with EPA sanctioned requirements.

EPA’s Lead Renovation, Repair and Painting Rule (RRP Rule) requires that firms performing renovation, repair, and painting projects that disturb lead-based paint in homes, child care facilities and pre-schools built before 1978 have their firm certified by EPA (or an EPA authorized state). Firms must use certified renovators who are trained by EPA-approved training providers and follow lead-safe work practices.

The following is a basic overview of the Federal and State requirements and guidelines in place for Contractors to work on older structures in the State of Oregon. With all the projects actively taking place in Portland and the surrounding markets, a general understanding of law and procedures may help your project move forward a bit smoother.

STEP 1:  Determine if the job involves lead-based paint.

• How old is the home? If the home is built before 1978, it may have lead-based paint.
• Find out if homeowners have information on lead-based paint in their home.

STEP 2: Test the home with proper/certified lead based test kits approved by the EPA or take samples to local testing facility. 

• After results are determined, inform all persons involved: homeowners, non-certified workers, subcontractors etc.

STEP 3: Set Up Safely

Abatement Team for larger renovations.

You must protect workers and residents while working on a lead-based paint renovation project.  The RRP rule requires the work area be protected by plastic sheeting that extends the minimum of 6 feet in all directions from the location where paint will be disturbed. The rule further requires protective plastic sheeting to extend far enough from the location of disturbance so all dust or debris generated will remain in that isolated area.  Keep unauthorized persons and pets out of the work area by posting warning signs and setting up barriers.

Below is a list of materials we recommend using:

• Heavy Duty Plastic Sheeting
• Masking, duct, or painter’s tape
• Stapler
• Scissors/utility knife
• Signs
• Barriers/Cones/Fencing

For Outside Jobs:

Close all windows and doors 20 feet of the work area.  Cover the ground and plants with the heavy sheeting.  Avoid working in high-wind conditions .

STEP 4:  Protect Yourself

Workers should wear protective equipment to minimize inhaling and ingesting lead from the job. It also minimizes the risk of bringing lead from the worksite home to your family.

What to do:

• Protect your eyes
• Keep clothes clean
• Wear respiratory protection
• Post Warning Signs
• Wash up

Supplies:

• Protective eyewear
• Painter’s hat
• Disposable latex/rubber gloves
• Disposable shoe covers
• Disposable coveralls
• N-100 rated respirator

STEP 5: Minimize the Dust

While working your goal is to keep down the dust.

• Control the spread of dust by misting the area before sanding, scraping, cutting an drilling.
• Use only  power tools with Hepa attachments
• If a heat gun is needed to remove paint, do not use temperature above 1100.
•  Keep the work area closed off to the rest of the home. Stay in contained work areas and paths.
• Don’t track the dust out of the work area.
• Remove disposable shoe covers and coveralls when leaving

Here are a list of lead-base paint protective equipment:

• Heavy-Duty Plastic Bags
• Masking, Duct, Painter’s Tape
• Misting both or pump sprayer
• Disposable wet wipes or hand towels
• Hepa Vacuum

STEP 6: Work areas should be kept clean every day and the end of the job.  

• Clean up as you work.
• Vacuum areas and put trash in heavy duty plastic bags
• Wash your hands and face every time you leave work.

At then end of the day you should:

• Damp clean entire work area with a general cleaner, mop and wet rags.
• Vacuum after work area dries.
• Check area again for any signs of dust/debris. Repeat steps if needed.
• Wash well before going home
• Safely dispose of all hazardous materials

STEP 7: Control the Waste

Control waste on-site and when removing from site.  Dispose of contaminated water appropr

What needs to be contained:

• Waste from painted surfaces
• Protective Sheeting
• Dirty Water
• Cleaning Supplies
• Protective Gear
• Any other waste

How to bag the waste:  Bag and seal all waste before taking it out of work area.

• Place in plastic sheeting/heavy duty trash bags
• Gooseneck seal the bag
• Wrap large items in plastic sheeting and seal with tape
• Vacuum the outside of all bags
• Avoid using personal vehicle to transport the waste

Step 8: Verify Work Completion by Cleaning Verification Procedure or Clearance

EPA Post-Renovation CV Card

Cleaning verification procedure:

• Wipe all surfaces with a wet, disposable cleaning cloth
• Compare the wipe with CV card, if the cloth matches or is lighter than the CV card, the surface has passed and no more action is required
• If the 2nd wipe is not cleaner than the CV card, re-clean and wait 1 hour.
• Once all surfaces have passed the cleaning verification, you can turn in over to the occupants
• Cleaning Verification Cards are available from EPA by calling 1-800-424-LEAD (5323)

Clearance testing procedure:

• Conducted by certified lead-based pain inspectors, certified risk assessors, or certified dust sampling technicians.
• Clearance samples are taken from the work areas and then sent to a EPA-recognized dust-lead laboratory.
• Laboratory will report the amount of lead in the dust.

Dust at or above the following limits are considered hazardous:

• Floors: 40 micrograms per square ft
• Window sills:  250 micrograms pets square foot
• Window troughs 400 micrograms per square foot

Sources:

http://www.oregon.gov/oha/PH/HEALTHYENVIRONMENTS/HEALTHYNEIGHBORHOODS/LEADPOISONING/Pages/rrp.aspx

https://www.epa.gov/lead/renovation-repair-and-painting-program

https://www.epa.gov/lead/lead-test-kits

RRPTrainingProviders.aspx

We use  local laboratory services JSE LABS. They’re conveniently located in Milwaukie, Oregon.

Laboratory Services