Vertical Containment: In Search of Clarification

Our feature article this week discusses the proposed changes the EPA is considering for exterior containment. We anticipate these revisions to be disclosed in the next six months. What is the current RRP Rule regarding exterior containment, and in particular regarding exterior work done in urban areas where buildings are close together? In regards to when scaffolding and vertical shrouding needs to be used (where adjacent buildings are within 10 - 15 feet of the work area), the current RRP Rule guidance states (FAQ document, question 23002-238447): "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 must be on site while the containment is established and is responsible for ensuring that dust or debris does not spread beyond the work area. The extent to which scaffolding and vertical shrouding are needed to meet this standard will depend on the conditions at the work site. At a minimum, you must cover the ground 10 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to collect falling paint debris, whichever is greater, unless the property line prevents 10 feet of such ground covering.  This distance accounts for dispersal of dust or debris that is likely as a result of air movement, even on relatively calm days. In situations where other buildings are in close proximity to the work area, where the work area abuts a property line, or weather conditions dictate the need for additional containment (for example, during windy conditions) the certified renovator or a worker under the direction of the certified renovator performing the renovation may have to take extra precautions in containing the work area to ensure that dust and debris from the renovation does not contaminate other buildings or migrate to adjacent property. This may include erecting vertical containment designed to prevent dust and debris from contaminating the ground or any object beyond the work area. Let's compare EPA's direction to those provided by HUD  in its "HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing," chapter 8, "Resident Protection and Worksite Preparation," table 8.2 (page 8-13, 14) that "Containment and Barrier System" for all levels of worksite preparation is as described: HUD Containment: One layer of plastic on ground extending 10 feet beyond the perimeter of working surfaces. Do not anchor ladder feet on top of plastic (puncture the plastic to anchor ladders securely to ground). For all other exterior plastic surfaces, protect plastic with boards to prevent puncture from falling debris, nails, etc., if necessary. Raise edges of plastic to create a basin to prevent contaminated runoff in the event of unexpected precipitation. Secure plastic to side of building with tape or other anchoring system (no gaps between plastic and building). Weight all plastic sheets down with two-by-fours or similar objects. Keep all windows within 20 feet of working surfaces closed, including windows of adjacent structures. EPA, in its proposal to amend exterior containment requirements, notes, "this proposal would add a definition of the term that is based on the definition of "worksite preparation level" from the HUD Guidelines. The definition includes additional information on what constitutes vertical containment."

But ... HUD does not mention vertical containment except when discussing "Security" and entryways, and  "if practical, install vertical containment to prevent exposure."

We were unable to locate in the entire HUD document any reference to what constitutes "vertical containment." Let us know if any of you find that reference - here's the link:

So, we are left shrugging our shoulders ... what exactly is EPA proposing for exterior vertical containment?