Musings Of The New Lead Paint Renovation Program (Part 1)

Today I was sitting down and once again reading over the new Renovation Repair and Painting Rule (RRP).  As a contractor I was doing some checking into something that I heard about last week and it really made be concerned about the legal issues with this law.  I began to think about all the parts of the law and the requirements of the containment process when working on a home that was built prior to 1978 that had lead paint detection  test completed on it and they were found to be positive. 

The new law has provided for some very specific items that must be done when lead is found in a residential dwelling that has made my head spin.  Some of the items I have trouble understanding is:

1- The protection of items in the renovation area:  If you are doing a window replacement everything that can be removed from the room is to be removed.  However if it can not be removed it is to be wrapped like a Christmas gift and then around the bottom of the item it is to be taped to the floor so that no dust can get on the item and be a hazard.  However the law requires during the clean up procedure that we are only responsible for horizontal surfaces and not vertical surfaces.  Does this mean that the dust can only travel upwards around certain items and land on the flat surface of this item and yet there is no concerns about other vertical surfaces in the room?

2- The amount of dust that is dangerous: I have read in several places that the amount of lead dust that can be found in a sugar packet is enough to contaminate an area as large as a football stadium.  This raises a flag to me because I wonder if this is the case,  Why do I Only need to tarp of a 10' x 10' area in front of the window or door area that I am working on.  Once this dust travels out of the 10' x 10' area, Is it no longer dangerous?

3- Safety: The EPA obviously has not sat down next to our good friends at the Occupational, Safety and Health Administration (O.S.H.A.) and discussed what kind of dangerous situations they are creating.  I was reading about the fact that all area inside and outside need to be tarped with heavy plastic in order to catch any paint chips that can fly away from the work area.  I was thinking about the safety of laying a plastic tarp down on the ground and then setting a ladder on top of it to reach your work area.  Does this sound a little dangerous to you?

4- Disposal of the trash:  The law states that if I am removing any trash from within a house that I need to bag it and goose neck tie the top of the bag before walking through the house to take it outside.   I find this as crazy on so many levels.  I believe the point that I find the craziest of all of this is the fact that We have now taken a item that is biodegradable when placed in a landfill and now wrapped it in plastic,  Our government speaks about going green, What happened here?  This is the best part: We are removing this so hazardous item from our homes and then we can place it outside on the curb for local trash pick up or if the contractor removes it from the work site he or she will most likely pitch it into a landfill.  Now I am not a scientist here but does this not cause a problem for groundwater when the lead leaches off of the trash into the water supply? 

In closing it seems to me that no one person has stopped and stood back and looked at the crazy law that has been put forward here.  I urge you that you sit back and look at this law if you are a contractor.  Make sure that you are following the law and make sure that you use a lead test kit on  every home that you are going to work on if you believe there is even a slight chance of lead being present.

For now I am moving on and will soon write another edition of Musings of the Lead Paint Renovation Program soon.