What is industry standard for catching exterior lead paint scrapings?


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Old 04-21-10, 06:30 PM
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What is industry standard for catching exterior lead paint scrapings?

One of those crunchy blue tarps? Then what do you do with it? Jiggle the tarp to get the paint to gather to one spot on the tarp, and then funnel the tarp to get the paint to slide into a plastic garbage bag?

Or is one better say to use thin plastic sheeting, perhaps weighing it down with bricks, so that when you are through scraping, you can gather up plastic film and paint together, disposing of the whole works?

Or ????

If it is windy out, the day they scrape the wood garage, there might get to be a lot of paint caught up in the wind and taking off like those maple tree seeds with wings. That be frustrating.

Any laws against scraping lead paint on windy days(in most regions)? I sure ain't calling up the city to tell them I have code red lead paint, and get their advise. They'd probably want the landlord to spend thousands of dollars with some abatement company!

One tempting way is to forget anything with worrying about tarps and simply rake and rake somemore, to get up as much as possible, and then maybe go over the area with a shop vac, (if the scrapings are loose) and on dry dirt or concrete, which is what will be blow the wood siding - concrete on 2 sides, already raked dirt on 2 sides.

Consider the fact the building is a million years old, and has already lost 1/6th of it's paint into the surrounding soil already.
 
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Old 04-21-10, 07:04 PM
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there are laws covering this, the paint must be contained, best is with a vacum with a hepa filter. American International Tool Industries, Inc. LLC | Makers of the Paint Shaver Pro paint stripping, paint stripping tools, paint removal, paint removal tools, paint scrapers, lead paint removal, stripping lead paint, infrared paint heater
something like this, should be used or a liquid paint remover that keeps you from making dust.
The EPA is very strict on lead based paint removal even for homeowners.

murphy was an optimist
 
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Old 04-21-10, 07:42 PM
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I just finished my EPA lead paint renovation course, so I should be able to answer this without looking in my manual. LOL

According to the EPA publication, Lead Safety for Renovation, Repair and Painting, page 22, the EPA renovation, repair and painting rule (RRP) does not apply to homeowners that are living in the home under renovation and doing their own work. Therefore YOU can do what you want. But that doesn't mean it would be wise.

For contracted work, homeowners have the option to sign off on all lead precautions provided they sign a release form and that there are no pregnant women or children under age 6 in the home, and provided the home is not used for daycare. (Owners can NOT opt out on rental property) Contractors are now REQUIRED to be lead certified by the EPA and must have completed 8 hrs of training to legally work on homes pre-1978 with lead paint. They must also keep tons of records, and do testing if lead is not "assumed" to be present. They must give you a lead brochure and you must sign that you received it. You should also receive the results of any testing that was done, and an all clear form when work is complete.

If you'd like to know what i would do... if you hired me as a lead certified renovator, and wanted me to use lead safe practices...

I would be required to completely surround the work area with a perimeter 20' away. (Caution tape, complete with warning signs to stay out, poison, no eating, drinking smoking.) For a 1 story building, 10' of 6 mil poly would be put down. It should lap up onto the building about 6". If it is windy, yes, weigh it down with bricks or stake the perimeter with tent stakes. Folding all edges of the poly upward with strips of plywood and stakes will help contain particles. Staple poly to plywood. When you are done, best thing to do is to collect all the particles, funnel into plastic waste bag. Gooseneck tape the bag. And dispose of as waste. The plastic should be lightly misted with water (garden sprayer), folded together to enclose the side that was facing up, bag it and dispose of as waste.

Keep in mind that clear poly will kill your grass pretty quick in the sun. If that is an issue put sheets of 1/4" osb down first.

If conditions are too windy to contain dust on the 10' sheet you can always use a bigger sheet, otherwise work should stop. (If your neighbor's windows were open and they had a child, you'd be responsible for contaminating their home. It only takes 1 gram of lead dust- about the size of a coffee creamer- to contaminate an entire 2000 sq ft house.) If you are 2 stories high, sheet must be 20' wide. Side scaffolds can be erected with poly barriers as the need arises. (say, for instance you're neighbor's house is 8 ft away and he doesn't want you coming onto his property or getting chips on it.)

Dry scraping, sanding, grinding, or heat guns > 1100F are no longer legal ways to remove lead paint. Wet scraping is allowed. Mist the area with water, then scrape. Wet lead chips will fall to the ground whereas dry lead chips will blow away.

Employees of lead certified renovators must be in full PPE from head to toe. disposable hat and shoe bonnets, coveralls, gloves, N-100 respirator, and so on. All must be disposed of as waste except for the respirator which can be reused if it is labeled and put in a ziplock bag with a name tag. Wash hands and face and shoes with soap and water before eating or ending work for the day.

Lead paint waste can just go in the garbage but they do recommend it be sealed in bags just to keep it from blowing around and contaminating more areas than it has to.

Additionally all windows must be closed on the side of the house where work is being done (within 20' of work area)

At the end of the job, no paint chips should be visible. A shop vac with a hepa filter could be used outside to vacuum, but the best way to eliminate visual signs of paint chips is to either cover with fresh soil, mulch etc. EPA is not as concerned about the soil because like you said, there are already preexisting chips in it. Shop vacs are not Hepa vacuums, and are not as clean as commercial Hepa vacuums. So while you might use a shop vac to suck up lead paint outside, you would never use that same vacuum inside, since it would spread lead dust in the air from its own exhaust.

And don't ever use the word "abatement". The correct term is renovation. Lead abatement is a whole 'nother ball of wax. And so is working INSIDE the home. And if the home or rental property receives HUD assistance things get even more complicated.
 

Last edited by XSleeper; 04-21-10 at 08:37 PM. Reason: Added rental property clause
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Old 04-22-10, 08:10 AM
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Oh dear! This law has already taken effect and is federally mandated?

The house is a rental, and the landlord wants me, as her maintenance man, to contract out to have someone scrape, prime and paint the outbuilding, that is of the dimensions of a small garage, 1 story, next to alley maybe 40 feet to it's nearest side, from the house. Garage is peeling paint extremely badly. Much paint must already be in soil. Had building high pressure washed. Trouble is - with wetting building (for wet-scraping) at this stage is - after it dries, that promotes more paint to peel! It is peeling more now since it was recently pressure washed and then dried out. Inevitibly, you really should dry scrape some, in the end, because of this.

Why not just rake the ground, as I did that after pressure washing, and it actually looks perhaps 99% free of particles.......to just do that and forget the rest? The surrounding ground surface is either pure dirt or concrete - no shrubs, flowers or grass for it to fall in, or get hung up in.

But if this is the landlord's place, a contractor then cannot even do this work unless lead certified, by law? Is that right?

And that is seriously being honored by people? How many people would claim ignorance(especially if law is new and not advertised often on tv) they never heard of such a law? And maybe they would be telling the truth? They'd say, "Who would think you can't scrape and paint? People have always done that!" What if they did not even know nor thought about the lead aspect? We all know that "schooled and certified" 'renovators', means cha-ching......big bucks. The landlord wants to only pay kid-like wages to repaint (say $3-500), thinking anybody can scrape and slop on some paint, to pass inspection.

The inspection(health inspector) sheet itself only said how the garage has to be repainted and said nothing about checking for lead and hiring certified workers. Maybe this could open up a legal reprieve if push came to shove?

MY fault is I know too much. Now I feel guilty. I wish I WAS totally ignorant. Now I do not know WHAT to do. It is like the suggestion to have the place resided with vinyl is the answer, even though that might cost a couple grand or so.
 
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Old 04-22-10, 01:21 PM
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Have you verified that there is lead based paint still on [or peeling] the building?

I've been retired for awhile so I'm not current on all the new laws. Often enforcement can vary greatly in different locales. In my region there used to be no enforcement at all when dealing with lead paint but I don't know if that is still true. Have you talked to any of the local paint contractors to get their take on exterior repaints of buildings that still have some lead based coatings on them? One would think that exterior lead based paint that was applied 35 or more years ago would have peeled off long ago.
 
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Old 04-22-10, 03:47 PM
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The lead paint test kit turns bright red, instantly. They say to rub the stick for 30 seconds in order to find out. Ha. As soon as the indicator stick touches the paint, it turns.

Good idea about asking paint store, about local laws and what they might know about how others deal with it. I will check that out.
 

Last edited by marksr; 04-23-10 at 03:47 AM. Reason: removed unneeded quote
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Old 04-22-10, 04:51 PM
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I'm not sure if it went into effect at midnight last night or at midnight today. If it's the latter you still have 5 hours to make a mess. LOL But yes, anyone working on a rental unit with lead paint, HAS to be a lead certified renovator. If the rental recieves HUD dollars, then someone who is certified for "lead-based paint activities" (abatement, inspection, risk assessment) must be involved in the process.

Since the house is a rental there is no legal way around it for you or the owner.

the argument ignorance is bliss only applies until you get caught, and I am by no means advocating breaking the law. As I mentioned, the only legal way is to be lead certified, which costs around $450, depending on the cost of the training. $300 to epa, $150 for training.

You might be surprised how well wet scraping works, but you are right, some paint will likely fleck loose after it dries. But keep in mind that "wet scraping" is not defined, so a light mist with the garden sprayer would satisfy the EPA, it's not like you need to douse the wood and saturate it. It's just to keep the dust down.

You can also use heat guns to strip lead paint provided the temp setting does not exceed 1099 F.

You definitely want to put plastic down, and just use one of those dust pan scoopers on a handle to clean up your chips on the plastic. You don't want them getting into the grass, and no I wouldn't recommend raking them in when they are so easy to contain. The final walk through after the job should show no signs of paint chips. So like I said, if that means adding a few bags of soil on top of the existing soil, that is enough. Raking will only continue to stir up more chips.

Also these EPA laws are national, so local laws might "add to" EPA laws (such as what your local landfill requires when it comes to disposing waste) but local laws cannot minimize the new EPA laws.

"But if this is the landlord's place, a contractor then cannot even do this work unless lead certified, by law? Is that right? "... under the new laws, yes, that's correct. But you can bet there will be plenty of people out there doing it, business as normal. The certified ones will be in the minority. Even the landlord cannot do lead paint work on his own property when it is a rental. His own work is considered as "a compensated renovation" which means if a landlord wants to work on his own housing units he must be lead certified and abide by the RRP rule in all his pre-1978 units where lead is present in the affected components.

Vinyl might be the answer, but then again, I would imagine the installers would need to be lead certified since they would surely disturb the surface of the paint. But maybe not as long as they aren't cutting or grinding into the old paint? It's a slippery slope. Good question though, I ought to pose that question to the EPA site and see if I get an answer.
 
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Old 04-22-10, 05:16 PM
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Can't you just go away? You are the bearer of bad tidings. Seriously - interesting read. We are a land of governance by many laws that keep coming on the books.

Good idea about not soaking the wood! Good tip.

Funny how the heat gun temp = a form you get for taxes, for doing contracting work for others. I wonder what kind of thermometer you can get will test to make sure it is not at 1100? , again.

Good tip once again about spreading some loose dirt ontop.

So do you prefer the heavy tarp method?, and then using a broom and dust pan on a stick, to get the paint off the tarp(wouldn't this stir up dust?)? Or - to use thinner disposable plastic sheeting, and throw the whole works away?

You do not have to take the paint to a hazardous waste reclamation center do you? Then again....if you are not certified to do it, and take it there.......ooohhh, the questions?
 

Last edited by marksr; 04-23-10 at 03:47 AM. Reason: removed unneeded quote
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Old 04-22-10, 08:25 PM
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Ha ha, well I imagine that this will become a heated topic given enough time. No one likes someone else telling us our business, but I guess a person has to admit that they are just trying to protect us from ourselves. LOL

I think a lot of heat guns have various settings... Some heat guns are limited by design to no more than 750F, for example, and these would be the sort of heat guns you'd want to use since it isn't even possible for them to exceed their maximum rated temperature... therefore they are safer than the ones that exceed 1100F since that is when lead paint starts to give off toxic fumes. You'd really only want to use the heat gun if you were going for total paint removal.

The ground cover of choice for a lead certified renovator is clear poly. The EPA handbook does not specifically mention a thickness, they just say "plastic sheeting". If you are going to be walking on it, you don't want it to tear so you obviously need something durable. 6 mil seems to me to be a good heavy quality. If you were draping something just to cover it, 1 mil would be fine (but its so light that a breeze would carry it away). Buy poly in a roll that is the right width that you need... say 12' so that you can roll it up onto the foundation and still have at least 10' covering the ground. And poly is cheap enough that it isn't going to make you cry if you roll it up and throw it all away, which is what you are required to do after all chips have been collected and work is done.

The EPA instructions tell you to control the amount of contamination by containing paint chips, cleaning up often. Not making it spotless, but just preventing the chips from spilling over, blowing away, etc. The instructions say to HEPA vac them from protective sheeting. My instructor said he likes to mist the plastic with his garden sprayer / water then use the dust pan sweeper and a broom... to do a quick "control cleanup".

Whatever you put on the ground should be disposable. If you used a blue tarp, you'd have to dispose of it. So yeah, plastic sheeting is probably more economical. Stake the edge with tent stakes or weigh it down along the edge with bricks.

Unless your state or local laws say otherwise, EPA says it is OK to bag your chips and throw them away. Use heavy duty bags. Double bagging is a good idea since you don't want to tear a cheap bag and spill the contents all over. You are supposed to hold the bag, spin it, tape the neck, fold the top half of the neck over onto itself, and tape it again. (gooseneck) And then hepa vacuum the bag itself if it is dusty.

Again, these are the steps a certified renovator would take to limit the spread of lead dust. I encourage anyone who needs to work with lead paint to submit their EPA application and follow it up with the required 8 hr training course. (end of disclaimer)
 
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Old 04-23-10, 07:13 AM
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Just got back from the national chain paint store. Discussed with worker. Got publication effective April 2010. -seriously. Like a $32,500 fine per day. Must be EPA certified. Courses in the area are booked up! Worker said some are traveling 240 miles to Milwaukee to take the course! Cost is $$hundreds for courses. And likely more hundreds to get certification paper.

This is ridiculous. Not from the aspect of having rules/laws to protect people, but from an enforcement standpoint. You know there will be lots of people doing stuff, the way they always have and will either claim or are ignorant of the latest facts -and/or will get away with it?, while someone else might get fined? That's what always happens wirh laws and illegal acvtivity. Just like how I see red light runners all the time here, and I keep exclaiming, "Where's the cops when you need one! - our taxes could be lower if they were out catching and fining these people!"

You ARE allowed to scrape off 20 square feet (exterior) of lead paint, and not to be certified. How they going to know if half the paint is already gone? But even say if one complies, maybe extra heavy paint slopped on with emulsibond to lock what is there in place?

I'm going down to take a finer look now at that garage.
 
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Old 04-24-10, 03:50 PM
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Go figure!

Thanx xsleeper! I missed seeing your last post. Excellent read!

Now -Go figure! I read the new lead rule glossy flyer from SW, and it says you can "disturb" 20 exterior square feet and up to 6 square feet interior, per room. What?!

I thought the idea of this new law was to be strict? Is it actually LESS strict? Years ago, (like 20)I thought it was illegal to scrape inside window sills-jambs-mullion dividers, if lead paint. In fact, because of this, this one landlord removed all the windows to have them dip-tank stripped to comply with health dept. to do that, or replace the windows with vinyl!! He also had to install jamb guides so that the window would not rub off any more paint from the jamb!

Well - if you can "disturb" 6 feet per room(without being EPA certified), that means you could scrape every window sill and jamb and mullion probably in the house!

I thought they wanted to protect kids from eating paint chips - even one chip! What?!

And the rules are not specific as to what "disturb" means, nor do they say anything about that if you do, you need to hepa vacuum if you do.
 
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Old 04-24-10, 04:43 PM
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The 6 ft work exception does not apply to windows. Window work is not included under the RRP rule, so you must use safe lead practices anytime you are working on a window. This is by far, more strict.

I highly doubt that the "glossy flier" that you read contains as much information as the 312 page Lead safety curriculum contains. I'm sure the flier was oversimplified.
 
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Old 04-24-10, 05:25 PM
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Originally Posted by XSleeper View Post
The 6 ft work exception does not apply to windows. Window work is not included under the RRP rule, so you must use safe lead practices anytime you are working on a window. This is by far, more strict.

I highly doubt that the "glossy flier" that you read contains as much information as the 312 page Lead safety curriculum contains. I'm sure the flier was oversimplified.
Hmmmm. If one recieves such an official multi-colored flyer that claims this is the new rules for lead paint effective April 2010, and does not refer you to a website or manual, I think one could claim ignorance, regarding anything else, and get away with it.

I will give that flyer another look, to be sure I did not overlook something, and that it might be my fault.

Okay I found it. Yes, it says on the back that there is some sites you can go to to read more about it. HOWEVER, it says right on the flyer, with a bullet, that the exception to the rule is if you disturb no more than 6 square feet per room. No ifs ands or buts or asterisks mentioned.

That is THEIR fault for writing this flyer up that way. Grave ommission, if what you say is true. They do not say on that flyer that you MUST go to some site to learn all that applies. Nor do they say that exceptions to the rule may not always be applicable. THEIR mistake!
 
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Old 04-24-10, 06:17 PM
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The RRP rule covers renovation, repair and painting. Since you got the flier at a paint store, it is likely specifically written to cover painting. The line about looking for more info likely implies that there is more to it than just what's mentioned on the flier. I'm not surprised if this seems confusing... you ought to read all 312 pages. Some things seem contradictory, and clear as mud.

By "working on a window" which I mentioned earlier, I meant removing and replacing a window, not simply repainting one. If you remove a window, even one that is less than 6 sq ft. in size, it is not considered "minor repair and maintenance" under the EPA's RRP rule. However, it also states that the 6 ft. rule does not include "activities involving prohibited practices". Dry scraping even 1 sq inch of lead paint would be an example of a prohibited practice.

All this makes me want to steer away from the window business altogether. LOL But now I've got $500 invested... so far.
 
 

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