Exterior Compliance Can Be Excruciating

Working within the parameters of RRP for exterior lead-based paint removal can be impossible.  Here are some points of practicality that need to be changed, so that work can be safely performed and still have good containment.  We've taken the advice provided on the EPA website under its Q&A section, and commented on how we see this playing out in real-life situations: EPA: “At what point is the wind too strong to allow work to continue? The work practices for exterior projects are based on a performance standard -- the certified renovator or a worker under the direction of the certified renovator must contain the work area so that dust or debris does not leave the work area while the renovation is being performed. The certified renovator is responsible for determining when the wind is so strong that no form of containment is adequate to keep dust or debris from leaving the work site, and therefore work must stop until conditions improve such that containment can be maintained.” My Comments: There is no provision here for practical problem solving regarding what happens if wind blows dust away from the area and for securing the jobsite.  Here is a dramatic way that jobs can increase in cost with the loss of work-time, setup, recovery of dust particles, extra wasted protection material. EPA: “During exterior power washing, instead of plastic, can landscaping fabric or a similar material be used to capture any paint chips or other debris, but permit the water to seep through? No.  For exterior renovations, before beginning the renovation the renovation firm must cover the ground with taped-down plastic sheeting or other impermeable material in the work area 10 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to collect falling paint debris, whichever is greater.  Landscaping fabric is not an impermeable material.” My Comments: “Taped-down plastic sheeting” is not feasible for this in any way.  The amount of water generated in a pressure washing or even in a hand-scrubbed situation prohibits safe working conditions, as well as impossible containment of the liquid produced.  A semi-permeable membrane or fabric would be of great help toward both of these ends.  Obviously the EPA either wants to eliminate power washing completely, or has not studied this under real conditions.