Exterior Containment: More Changes Coming …

The easy part of RRP always seemed to be containing the exterior. Following the current RRP Rules, all you are required to do is put up a warning sign, make sure all doors & windows are closed within 20' and put impermeable plastic covering on the ground that extends 10' (minimum) from the building. Oh yes, and cover the shrubs.

While a good idea, you really don’t need to use caution tape, or cones. Just make sure the area is marked with warning signs. Because it is exterior work, there are no suits or masks required — even by OSHA.

Vertical containment may be helpful if job is warranted, which seems to be a decision for the on-site workers. Then you put the debris in a big contractor-grade poly bag, a trash can with a lid, or similar disposal process before taking it out of the containment area.

Even cleanup and verification is easier than interior work. It basically includes removing all the debris, making a visual inspection and removing the caution signs. You are certainly not going to HEPA vacuum the ground, although maybe doing so to window sills and other horizontal surfaces might be smart – but, again, not required.

It appears, however, the RRP exterior containment was not effective enough for the EPA and more changes appear to be around the corner.

In The May 6, 2010 edition of the Federal Register, the EPA outlined the changes it is proposing to make to the RRP Rule regarding exterior containment. In Part II of that Federal Register (pages 25038-25073) under Section E: (page 25055), "Other Proposed Amendments to the Final RRP Rule" it states the intent of the EPA to propose additional amendments to exterior vertical containment.

"Containment. EPA is proposing to be more specific about the vertical containment requirements for exterior projects. Under this proposal, the rule would specifically state that vertical containment is required for exterior renovation projects that are covered by the rule and that affect painted surfaces within 10 feet of the property line.

In such cases, vertical containment is necessary to ensure that adjacent buildings or properties are not contaminated by leaded dust or debris generated by the renovation. The rule would also note that vertical containment may be required in other situations, such as windy conditions, to prevent contamination of other buildings, other areas of the property, or adjacent buildings or properties.

Finally, to clarify what is meant by the term ‘‘containment,’’ this proposal would add a definition of the term that is based on the definition of ‘‘Worksite preparation level’’ from the HUD Guidelines. The definition includes additional information on what constitutes vertical containment. Click here for HUD guidelines found on page 13)"*

In short, EPA wants to add vertical containment to exterior work when a job is within 10 feet of another structure or property line, a somewhat common occurrence in urban areas.

EPA also recognizes that windy conditions may also contribute to further contamination that is not adequately contained under the current guidelines.

Public comment for this proposal, (lumped in with the clearance testing changes and eight other "additional" amendments in the May, 6, 2010 Federal Register), was allowed until July 6, 2010. The period was extended to August 6, 2010 under pressure.

Final resolution can be made as early as July 15, but by agreement, no later than December 15, 2011.

* Editor's Note: We could not locate in the HUD documentation of "worksite preparation" any defnition of what constitutes "vertical containment." We would welcome your comments if you have better luck.