Those of us of a certain age remember “Carnac the Magnificent,” the Johnny Carson character that divined the answer first and then opened the envelope to read the question. In the spirit of Carnac, today’s answer is: The RRP Rule applies to work that disturbs painted surfaces. So, pretty much any question you may have about RRP and roofing work can use that answer. And there are questions about lead and roofing and RRP. Roofs have used lead for many years to flash valleys, flash around chimneys and vents. Roofs have used lead pipes for plumbing ventilation and even for ice dams. Lead was great because it is malleable and fits around stuff. It is natural, then, to wonder about stripping old roofs, disturbing the lead flashings and pipes, and installing new the new roof and how RRP will affect the job. See the answer above. Even the EPA uses the Carnac approach. In the very helpful EPA RRP Frequently Asked Questions, there are some direct questions about roofs and RRP. If you’ve paid attention, you already know the answers. For example: Question (23002-23787) When installing a roof, my firm does not create dust by directly sanding or cutting painted surfaces, but we do hammer the unpainted side of the lumber from above. Does the RRP Rule apply to this work? Answer The RRP Rule applies to work that disturbs painted surfaces. If hammering painted components, even on the unpainted side, disturbs paint, creating dust or chips, the RRP Rule applies. Question (23002-15689) Does the RRP Rule apply to removing a roof that is not painted? Answer The RRP Rule applies to work that disturbs painted surfaces. Where there is no paint to disturb, the RRP Rule does not apply. Question (23002-23858) When replacing an unpainted roof, sometimes sections of paint-covered lumber under the roof need to be removed as well. If my firm removed damaged lumber from only certain sections of the roof, does only this area need to be contained while we fix the lumber? Answer Yes. The renovation firm is responsible for containing the work area so that no dust or debris resulting from the disturbance of a painted surface leaves the work area while the renovation is being performed. See? It’s easy. Then there are the tangential concerns such as working on dormers and the like: Question (23002-19757) My firm is replacing windows on the second floor of a 90 year old home. The windows are built into a bay that projects out from a steeply pitched slate roof. When setting up exterior containment for this job, does the RRP Rule require me to install plastic on the roof under the windows? Answer No. The RRP Rule does not require you to install plastic sheeting on the roof. You must cover the ground with plastic sheeting or other disposable impermeable material extending 10 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to collect falling paint debris. A little tougher question, but there it is again: the word “paint”. So, to be safe, when renovating roofs, consider RRP when you disturb anything seen, and unseen, that contains lead based paint. Oh, and while we’re talking safety, please remember OSHA wants you to use fall protection – if the roof is above 4 feet off the ground (they usually are), whether or not you will be disturbing components coated with lead paint. Here’s where it gets tricky: When dismantling the old roof will create mixed debris. That’s when the shingles, some of the old fascia board or roof sheathing, and other debris is all mixed together. Usually there is a dumpster on site where it is all shoveled to find its way to the local landfill. The EPA doesn’t answer that question very well: Question (23002-20763) Under the RRP Rule, what type of container is adequate for on-site storage of debris? Must the container be covered and locked? Must it be placed behind a locked barrier? Answer At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to dust and debris. Using a covered container is one way to prevent release of dust and debris. Locking the container and placing it behind a locked barrier are good examples of ways to prevent access to the dust and debris. Seems tearing off the old roof may not lend itself to covered containers, or containers that can be secured out of the work area. So what do you do? It’s not clear. Where is Carnac when we need him?