25 Renovation Jobs That Won’t Trigger RRP

April 11, 2011 -- For years, the Federal Government through HUD and DOE has operated a Weatherization Assistance Program (WAP) whereby funds are made available to increase the energy efficiency of older homes by adding insulation, mitigating air infiltration, possibly adding storm windows or other HVAC equipment.

The legislated purpose of WAP is to install energy efficiency measures through the weatherization of clients‘ homes, in order to lessen their energy cost burden.  In the process of weatherizing a home, workers sometimes encounter, and have to disturb, painted surfaces that are known or presumed to contain lead-based paint. When that happens, DOE funds may be used to minimize the potential hazard associated with the speci?c painted surfaces that workers are directly disturbing in the course of installing an energy efficiency measure.  But DOE funds may not otherwise be used for abatement, stabilization, or control of the lead-based paint hazard that is in the house.

Weatherization (WAP) is an energy efficiency program, not a renovation or remodeling or rehabilitation program, and thus may not be subject to other agencies‘ rules governing renovation, remodeling- or rehabilitation work. However, there are certain instances in which particular Federal rules relating to lead-based paint hazards do apply to Weatherization work.

In each instance where you may be doing WAP work, check with the local agency funding the WAP to see if there are lead-based paint issues you will encounter that qualify for some financial assistance.

In order to help categorize what might fall under lead dust mitigation and what might not, the DOE and HUD have created a list, which they call “Lead Diminimus”, which are thresholds under which no lead containment action need to be taken. It is an interesting list because many of the actions on the list might occur in regular renovation and remodeling and might be helpful to contractors to judge whether these activities would fall under RRP.

Lead-Based Paint (LBP) Deminimus Activities:

   1. Removal of nails, screws, picture hangers, or other fasteners, etc. from a painted wall surface.
   2. Removal of cover plates, switch covers, etc. from a painted surface.
   3. Removal of hinge pins or painted door hinges.
   4. Removal of lock hardware, closers, or other hardware accessories from a painted door.
   5. Wet sanding drywall compound or spackle using a sponge.
   6. Separating and removing shoe mold (base shoe) from a painted baseboard.
   7. Planing painted wood with manual tools.
   8. Drilling or preparing a painted door from installation of new door hardware (lock set, closers, kick plates, etc.)
   9. Renailing or refastening loose building trim, moldings or panels.
  10. Reglazing of window glass.
  11. Removal of painted phone line or electrical wire.
  12. Freeing an inoperable window.
  13. Housekeeping including emptying trash, vacuuming carpets, dust mopping hallways, cleaning water fountains, buffing floors, disinfecting bathrooms.
  14. Maintenance including replacing air filters, replacing toilet flush valve, replacing light bulbs, checking and repairing shower valves, unclogging a shower drain
using a "snake", mechanical repair of an air-conditioning unit, and repairing a shower leak.
  15. Carpentry activities including removing wooden windows to measure to make screens, sweeping out the carpentry shop, planning the edge of a door and re-install the hinges, re-hang the door, removing outside entrance door, removing the kickplate, and removing the screws.
  16. Carpentry activities including removing door hinges and lockset and replacing.
  17. Carpentry activities including sanding floor with "stand-behind" power disc sander, scraping floor near corner, clean-up of debris and placing debris in container.
  18. Carpentry activities including wet hand scraping and wet sanding a column
  19. Carpentry activities including removing wooden baseboards, cut and pull up wall-to-wall carpeting, scrape walls near baseboard, scrape carpet adhesive residue from floor, sweep floor.
  20. Carpentry activities including removing window casing and wooden molding, removing the window sash, heating the glazing, scraping and removing the softened glazing, re-installing the sash, rehanging the window, and installing the wooden molding.
  21. Removing old plaster and re-plastering, manually sanding new plaster.
  22. Maintenance activities including wet scraping of window and door.
  23. Plumber activities including manually removing old lead and oakum from around shower drains, heating lead in an open ladle using a propane torch, pouring the molten lead from the ladle into the cavity surrounding the drain, rapidly cooling the unused hot lead using cooling water from a sink faucet
  24. Chipping and sanding plaster.
  25. Painter activities including spreading plastic material around the hot-water radiator and wet scraping old paint from hot-water radiator, folding up the plastic broom sweeping the floor.

For more information on the trigger levels and expectations for WAP contact www.DOE.gov and or www.HUD.gov and look into their Weatherization Assistance Programs.