RRP in some ways is "Lead Safe Lite" in that RRP's requirements are more lax than true abatement and even those in OSHA standards. To be considered worrisome under RRP, EPA points to the Toxic Substances Control Act (TSCA) section 403 regulations that define dust-lead hazards as levels that equal or exceed 40 µg/ft2 of lead on floors or 250 µg/ft2 of lead on interior windowsills (troughs).
If a contractor were able to reduce the existing dust levels in a home to below these numbers, conceivably the area where the project was to be done might avoid RRP – certainly lessen the cost, time, and effort in mitigation, collection and disposal.
There is precedent for this approach in the EPA's work analyzing dust levels created by certain projects when they worked on the final version of RRP.
The EPA conducted a field study (Characterization of Dust Lead Levels after Renovation, Repair, and Painting Activities) known as the ''Dust Study'' (40 CFR Part 745 Section II, part 5), to characterize dust lead levels resulting from various renovation, repair, and painting activities.
The design of the Dust Study was peer-reviewed by experts in fields related to the study. They reviewed the design and quality assurance plan independently and provided written comments to EPA.
In the Dust Study, 12 different interior and 12 different exterior renovation activities were performed at 7 vacant target housing units in Columbus, Ohio, and 8 vacant target housing units (including four apartments) in Pittsburgh, Pennsylvania. Three different interior and three different exterior renovation activities were conducted at a building representing a child-occupied facility, a vacant school in Columbus. The presence of lead-based paint was confirmed by laboratory analysis before a building was assigned a particular renovation activity or set of activities.
Before interior renovation activities were performed, the floors and windowsills in the work area and adjacent rooms were cleaned. In most cases, pre-work cleaning resulted in dust lead levels on floors of less than 10 µg/ft2; nearly all floors were less than 40 µg/ft2 before work started. Most windowsills that would be used for later sampling were cleaned to dust lead levels less than 250 µg/ft2.
Dust samples were collected after the renovation work was completed, after cleaning, and after cleaning verification.
After a variety of projects were completed, t he Lead Dust Levels measured in these buildings, without pre-cleaning, were as follows (in µg/ft2):
- Kitchen cabinet removal--958.
- Low temperature heat gun--2,080.
- Dry scraping--2,686.
- Window replacement--3,993.
- High temperature heat gun--7,737.
- Power planing--32,644.
If there the areas were pre-cleaned, which meant reducing the pre-existing levels of dust to numbers below 40µg/ft on the floors and 250µg/ft2 on windowsills/troughs, the activities produces an after project dust level significantly lower:
- Kitchen cabinet removal--58.
- Low temperature heat gun--41.
- Dry scraping--66.
- Window replacement--135.
- High temperature heat gun--445.
- Power planing--450.
To be completely accurate, using RRP, the residual dust levels for these projects were almost statistically non-existent proving the value of RRP:
- Kitchen cabinet removal--12.
- Low temperature heat gun--24.
- Dry scraping--30.
- Window replacement--33.
- High temperature heat gun--36.
- Power planing--148.
What does the Dust Study teach us? If an area is pre-cleaned, it is possible to reduce the levels of pre-existing lead dust to levels close to safe levels. In fact, using some of the available products like D-Lead from Esca-Tech, Inc. and others, the area can be wiped down with these lead mitigation chemicals, and wipe sampled to show that the lead levels are below the standard for toxicity, and may eliminate the need for RRP at best, or a reduced effort in containment at least.
Pre-cleaning can also be used to help your customer reduce their lead problem throughout the home. After all, you are identifying that there is lead in the house, but you may only be working on part of the house leaving them with perceived lead hazards elsewhere without treatment after you leave. A real downer.
Perhaps offering this process throughout the house, in addition to the area in which you are working, may be the "value added" approach that can turn lead containment from a fear-based sale to a solution-based sale.
Pre-cleaning can offer the following advantages: