Removing Aluminum Siding Over Lead-Painted Siding

In the course of exterior work, It Is possible you will run Into aluminum siding that has been Installed over lead-painted siding. A question posed by a renovator to the EPA addresses this situation: “I am removing aluminum siding from a pre-1978 home. The aluminum siding was nailed over the top of painted wood siding that tested positive for lead. The underlying painted surface is greater than twenty-square feet. Must I comply with the Rule when removing the aluminum siding?” The EPA answered with this response: "The work practices for exterior projects are based on a performance standard – if the activity disturbs a painted surface (generally,by creating paint chips or dust) in excess of 20 square feet, the work area must be contained so that dust or debris does not leave the work area while the renovation is being performed. In this case, if the removal of the aluminum siding results in the disturbance of paint in excess of 20 square feet, then the RRP Rule applies. However, if the removal activity could be performed in such a way that does not disturb 20 square feet of painted surface, then the RRP Rule would not apply." As a renovator, I see that the EPA recognizes that it may be difficult to determine in advance of the renovation activity the full extent of the job. However, the renovator is the person with the expertise and experience to make this determination on a case-by-case basis. In such a situation, a renovator should consider how factors like the condition of the underlying paint or the chosen method of removal may increase or decrease the likelihood for a disturbance of paint. If there is still uncertainty, EPA recommends that renovators err on the side of caution and be prepared to contain any dust and debris. I am convinced that this is a circumstance where careful removal could keep most of these kind of jobs out of RRP, by avoiding any methods that encourage dust or chipping of lead paint, even though a contractor would be removing a great quantity larger than the 20 square feet mentioned in the rule.  The key words are “disturbs” “creating paint chips or dust”—meaning that you could theoretically disturb some of the paint and still be in compliance. Obviously, if it gets close enough to keep track of,  it is probably a good idea to consider it an RRP situation, but the best conclusion seems that careful removal is what the rule is after, and avoiding as much dust and paint chipping. This would mean that you may need to spend more time getting the siding off the building to comply, and at some point that may be more costly than using RRP but I seriously doubt it, when we consider that it may involve a large area, possibly a wrapped dumpster and enclosed landscaping, etc. It would appear also, that most painted siding could be removed without losing that much paint—all but the most severe flaking should be possible. Would love to hear your comments on this situation and interpretation of the EPA guidance.