Last week I talked about the RRP parameters for exterior lead-based paint removal. There were a few more exterior issues I wanted to touch on and get your feedback, as well. Here are some additional areas for discussion that are taken from the EPA website under its Q&A section, and my comments on how I see this playing out in real-life situations: EPA: “How can I use plastic sheeting in exterior renovations without creating a safety hazard? Moisture on the plastic from precipitation can cause plastic sheeting to become slippery. Answer: 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. However, the RRP Rule allows you to place another, less slick, disposable surface (such as paper) on top of the plastic sheeting as long as the plastic sheeting remains intact. Remove and dispose of both surfaces at the completion of the job.” My Comments: This may have some short-term benefit with a small amount of water, but snow, ice, or any amount of water pooling will still create a very unsafe situation as the plastic sheeting becomes slicker than an ice skating rink. Last week's reader comment suggesting the use of sawdust was a good option, depending on the circumstances. EPA: “In exterior containment, if a large tree or shrub is within the work area, can the plastic be placed around the base and would the plant, however large, also need to be covered? Answer: The RRP Rule does not specifically address containment of trees or shrubs, but if dust, debris, or residue remains in the tree or shrub at the conclusion of the job, the site will not pass visual inspection. 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. In addition, at the end of the job, a certified renovator must perform a visual inspection to determine whether dust, debris or residue is still present on surfaces in and below the work area, including windowsills and the ground. If dust, debris or residue is present, these conditions must be eliminated and another visual inspection must be performed.” My Comments: This, by itself, can make the job impossible, causing the homeowner to be the only person capable of performing the renovation, and certainly creating exposure to anyone in the affected area. The likely result is that very little or no containment will be performed, with the nearby environment absorbing the lead contaminated byproducts from unsupervised removal. As many of you have stated in the past few months, there will be many jobs that are lost due to the increased costs, or avoidance of dealing with these situations, along with a balance of trying to stay legally compliant while dealing with a depressed economy. Since there is less business available nowadays, each job lost is that much more significant. The methods imposed by the EPA for exterior containment need a hard examination for practicality while still working to accomplish the main goal—safely removing and containing lead.