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If a door is outside the work area but used by workers to enter and exit the room, does the door need to be covered with plastic?
If the work area is smaller than the entire room, and the door is not within the work area, you do not need to cover the door with plastic. However, all personnel, tools, and other items, including the exterior of containers of waste, must be free of dust and debris…
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For an exterior renovation where vertical containment is set up at a distance of less than ten feet from the work surface, must we still extend the ground containment beyond the vertical barrier to meet the ten-foot requirement?
My firm replaces windows. Various obstacles make it difficult to set up the ten-foot exterior ground containment in a way that would enable our renovators to perform the work and still effectively contain dust. In these cases, we lay the ground containment, but also use vertical containment measures to completely…
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In the EPA Certified Renovator Initial course, plastic sheeting is taped to the floor at several corners, but not around the entire perimeter. Must the plastic be "sealed" to the floor on all four edges by tape or just taped at several locations?
It depends on the specifics of the renovation job. The RRP Rule requires the renovation firm to cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to…
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What are the requirements for covering doorways used to access the work area?
Doors used as an entrance to the work area must be covered with plastic sheeting or other impermeable material in a manner that allows workers to pass through while confining dust and debris to the work area. Question Number: 23002-21413 Find a printable PDF copy of all frequent questions pertaining…
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To avoid harming the homeowner's grass and landscaping, may my firm fold up the plastic sheeting used for containment at night and re-use it the next day?
Yes, as long as your firm does so in a way that contains any dust and debris on the plastic. One way to accomplish this is to collect and remove the paint chips and debris from the plastic sheeting at the end of each day, mist the sheeting and fold…
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What mil plastic is considered impermeable?
The regulation does not specify a particular thickness of plastic sheeting considered to be impermeable, but rather includes a performance standard. The performance standard requires firms to isolate the work area, prevent dust and debris from exiting and ensure plastic sheeting is not torn or displaced. Certain guidance materials recommend…
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When must scaffolding and vertical shrouding be used on an exterior renovation when other buildings are in close proximity to the work area?
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…
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What, if any, additional requirements or liabilities exist if a homeowner independently removes the protective barriers and containment measures implemented by the firm during a renovation?
Before a firm begins a renovation, they are required to comply with all information distribution requirements under the Lead Renovation, Repair and Painting (RRP) Rule and to post signs that clearly define the work area and warn occupants and other persons not involved in renovation activities to remain outside of…
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Where can I go to learn more?
PitWatch.org is the online home of the Berkeley Pit Public Education Committee. This volunteer committee educates residents, students, and the public about the environmental management of the Berkeley Pit. Information includes the geology, hydrology, current events, and ongoing academic research associated with the Berkeley Pit. This committee frequently shares their…
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Do I need to cover a closet door with plastic?
Answer: Yes, if the door is inside the work area. When containing the work area during an interior renovation, the firm must close windows and doors in the work area. Doors must be covered with plastic sheeting or other impermeable material. Question Number: 23002-15162 Find a printable PDF copy of…
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Is it permissible for a training provider to employ more than one training manager?
Answer : Yes. The Rule requires that a training provider employ a training manager that meets the qualifications in 40 CFR 745.225(c)(1). EPA does not interpret this to be a limitation on the permissible number of training managers. Therefore, a training provider may employ more than one training manager so…
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Plastic can be a slip hazard in some jobs, such as handling granite counter tops. This creates a more immediate safety concern than protecting the floor from dust. Can't I just clean the floor at the end of the job?
Answer: No. For interior renovations, before beginning the renovation the renovation firm must cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area six feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust, whichever…
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My firm is replacing windows on the second floor of a home. The windows are built into a bay that projects out from a steeply pitched slate roof. Does the RRP Rule require me to install plastic on the roof under the windows?
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…
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Under the Renovation, Repair, and Painting (RRP) Rule, 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 Lead Renovation, Repair, and Painting (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…
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What is your recommendation if work under the Lead Renovation, Repair and Painting (RRP) Rule has started and it begins to rain? What do we do with the water that is on the plastic in the containment area?
Before beginning the renovation, the firm must isolate the work area so that no dust or debris (including in the waste water) leaves the work area while the renovation is being performed. In addition, the firm must maintain the integrity of the containment by ensuring that any plastic or other…
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