B. Federal Lead-Based Paint Enforcement Bench Book - National ...

• Work Area Containment
o All Renovations
Firms must use plastic sheeting or other impermeable material to contain the work area and
stationary items therein, and use tape to seal exposed edges. The firm must:
� Isolate the work area before the renovation so that no dust or debris leaves the area during the
renovation;
� Maintain the integrity of the containment;
� Ensure that no dust or debris leaves the work area; and
� Ensure that containment does not prevent emergency egress. 368
o Interior Renovations – Additional Requirements
The firm also must:
� Remove, or cover and seal, all objects (e.g., furniture, rugs, window coverings);
� Close and cover duct openings, close windows and doors, and cover doors;
� Cover and seal the floor surface at least 6 feet beyond the perimeter of the renovation surface; and
� Ensure that personnel, tools, and other items are free of dust and debris before leaving the work
area. 369
o Exterior Renovations – Additional Requirements
The firm also must:
� Close doors and windows within 20 feet of the renovation (including, those on the same floor
and on all lower floors for a multi-story building);
� Ensure that doors are covered, but also allow worker ingress/egress while confining dust and
debris to the work area;
� Cover the ground for at least 10 feet beyond the perimeter of the renovation surface; and
� “Take extra precautions” to ensure that renovation dust and debris do not contaminate other
areas or properties. 370
• Prohibited Practices
o The RRP Rule prohibits:
� Open-flame burning or torching of LBP;
� Operating a heat gun on LBP at temperatures at or above 1,100 degrees Fahrenheit
(>1,100 o F 371 ); and
� Using machines that remove LBP “through high speed operation” (such as sanding, grinding,
power planing, needle gun, abrasive blasting, or sandblasting 372 ) without “HEPA” exhaust
control. 373
368 40 C.F.R. § 745.85(a)(2). See also 73 Fed. Reg. 21692, 21728-21729, supra note 160 (if an EPA inspector observes dust or
debris escaping from the containment, then the renovator and firm would be in violation; renovator must determine size and
type of containment for each project to prevent the escape of dust and debris; EPA believes at least 6 feet of containment is
necessary for most projects).
369 40 C.F.R. § 745.85(a)(2)(i).
370 40 C.F.R. § 745.85(a)(2)(ii). See 73 Fed. Reg. 21692, 21729, supra note 160 (e.g., vertical containment in windy
conditions or when properties abut).
371 40 C.F.R. § 745.85(a)(3).
372 EPA sources indicate that this prohibition is intended to include hydroblasting.
373 40 C.F.R. § 745.85(a)(3).
52 FEDERAL LEAD-SAFE PAINT ENFORCEMENT BENCHBOOK