Changes from the 2010 revision are effective now. Changes from the 2011 revision will be effective as of October 5, 2011.
No “opt-out” provision (2010 revision)
The opt-out provision (which allowed a renovation firm to “opt out” of the some of the RRP requirements where the firm obtained a certification from the owner-occupant of a residence that no child under age 6 or pregnant woman resides in the home and the home is not a child-occupied facility) has been removed and is no longer in effect.
Required information for owners and occupants (2010 revision)
Renovation firms must provide a copy of records demonstrating compliance with the training and work practice requirements of the RRP rile to the owner and occupant of the housing, and operator of the child-occupied facility, in a short, easily-read checklist or other form. A sample checklist for these items can be found at http://epa.gov/lead/pubs/samplechecklist.pdf, but firms may develop their own forms or checklists as long as all of the required information is included.
Paint chip sample collection and related records (for purposes of determining whether components are free of lead-based paint (as defined by statute)) (2011 revision)
Starting on October 5, 2011, certified renovators may collect paint chip samples from components to be affected by a renovation as an alternative to using EPA-recognized test kits to test the paint, as previously allowed. If paint chip samples are taken, they must be sent to a laboratory recognized by NLLAP for analysis, prior to the effective date of the rule, EPA will be making information available to certified renovators on how to take paint chip samples.
If paint chip samples are collected, those records (description of the components that were tested including their locations, name and address of the NLLAP-recognized entity performing the analysis, and results for each sample) must be prepared by a certified renovator and maintained for three years, as already required for other records.
Vertical containment (2011 revision)
Vertical containment means a vertical barrier consisting of plastic sheeting or other impermeable material over scaffolding or a rigid frame, or an equivalent system of containing the work area. Vertical containment is required for some exterior renovations but it may be used on any renovation.
Renovation firms may erect vertical containment for interior renovations. This allows renovation firms to erect vertical containment closer to the renovation activity than the minimum floor containment distance specified in the RRP rule, to give renovation firms more flexibility in designing effective containment strategies for particular work sites.
Interior floor containment measures may stop at the edge of the vertical barrier when using a vertical containment system consisting of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls.
If the renovation will affect surfaces within 10 feet of the property line, the renovation firm must erect vertical containment or equivalent extra precautions in containing the work area to ensure that dust and debris from the renovation does not contaminate adjacent buildings or migrate to adjacent properties. Vertical containment or equivalent extra precautions in containing the work area may also be necessary in other situations in order to prevent contamination of other buildings, other areas of the property, or adjacent buildings or properties.
In addition, renovation firms may erect vertical containment for other exterior renovations. This allows renovation firms to erect vertical containment closer to the renovation activity than the minimum ground containment distance specified in the RRP rule, to give renovation firms more flexibility in designing effective containment strategies for particular work sites.
Exterior ground containment measures may stop at the edge of the vertical barrier when using a vertical containment system.
HEPA vacuums (2011 revision)
HEPA vacuum cleaners must be designed so that all the air drawn into the machine is expelled through the HEPA filter with none of the air leaking past it. HEPA vacuums must be operated and maintained in accordance with manufacturer’s instructions.
The use of machines designed to remove paint or other surface coatings through high speed operation such as sanding, grinding, power planning, using a needle gun, abrasive blasting, or sandblasting, is prohibited on painted surfaces unless such machines have shrouds or containment systems and are equipped with a HEPA vacuum attachment to collect dust and debris at the point of generation. Machines must be operated so that no visible dust or release of air occurs outside the shroud or containment system.
Asbestos Regulations, Commercial Renovations, and Fines
by Francis Xavier (Rich) Finigan
If you conduct commercial renovations, avoid fines by understanding current asbestos regulations. According to NESHAP (National Emission Standards for Hazardous Air Pollutants) before any renovation or demolition of a commercial or public building begins, an asbestos survey must occur. NESHAP is a federal regulation that has been in effect for well over a decade. In recent years this regulation has been enforced more vigorously.
Before we discuss the responsibilities under NESHAP let's try to understand a little about asbestos.
The use of asbestos by humans dates back thousands of years. Charlemagne is said to have amazed his guests at banquets by burning food from tablecloths woven from asbestos fibers. Pliny, an ancient Roman nobleman, scientist, and historian cautioned against buying slaves that had worked mining asbestos, because they tended to die young.
Asbestos is a naturally occurring fibrous mineral. It has good tensile strength, flexibility, chemical resistance, electrical resistance and is a good insulator.
Throughout the world uses for asbestos grew along with the Industrial Revolution . Today asbestos can still be found in over 3000 applications in both residential and commercial buildings.
For building materials to be considered asbestos containing materials, they must have concentrations of 1% or more asbestos fiber
Asbestos can be hazardous to the health of those exposed causing severe lung disease. Asbestos is most hazardous when it is “FRIABLE” or reduced to a powder.
There are approximately 10,000 deaths annually from asbestos exposure and thousands more that live a lesser quality of life because of asbestos illness. Symptoms can take 15 to 30 years to develop. The health effects from asbestos exposure may continue to progress even after exposure is stopped.
Because of the health risks, asbestos was banned in the early 1970s, but that ban was overturned for most uses in the 80s. Building materials containing asbestos can still be purchased today.
Common building materials were asbestos might be found include the following: joint compound, plaster, sheet vinyl flooring, vinyl asbestos flooring (not exclusively 9" x 9"), pipe insulation, roof materials, ceiling tiles, mastics used to adhere flooring or roofing.
Contractors conducting renovations or demolition in commercial of public buildings must have an asbestos survey before work commences. Violations usually result in significant administrative fines. One VT company was initially fined over $300,000 for removing floor tiles that contained asbestos.
The state of Vermont has a list of asbestos inspectors that can provide the service you need. To get a copy of that list called 1-800-439-8550 or visit the state of Vermont's health department website.
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