As I was hacking away at some 150-year-old crown molding caked thick with lead-based paint with my sawzall yesterday, I was wondering how I was going to be able to do this in compliance with RRP regs which state that you cannot cut lead-based painted stuff without a shrouded tool connected to a HEPA vac.
I want to try comply with the spirit of the law, but where the heck am I going going to find a shrouded sawzall? Or a shrouded orbital sander? Or even a HEPA vac?
This is not a rhetorical question. Anyone know of any sources for this kind of stuff?
Steve
Replies
I have seen shrouded sanders, and I would think one could put a shroud on a MultiMaster-type tool fairly easily, for ligher weight Sawzall-class applications.
Don't know of any sources.
I want to try comply with the spirit of the law
M, you should think about complying with the law which would require you to take the class and rcv a Renovators Certificate, then register with the EPA if you are the owner of the company or a sole proprietor. I had heard a few months ago when all this was fast approaching the misleading info that for a sole prop there would be the class cost , the EPA reg. for the individulal 300.00 and then a firm registration for another 300.00. That is not true-for a one man operation-class cost plus the 300.00 EPA registration.
I recently took the class and there is nothing to prohibit you from using a sawzall, nor is there a need for it to be shrouded unless of course you want to to make cleanup easier.........
However, the steps for isolating the work area and clean up are very important in the eyes of the EPA. Much of the class is devoted to just that. Now for me, having been in this business for a very long time I've adopted practices that are both an attempt at worker safety and client comfort beyond the norm. So, alot of the class instruction was remedial and in some cases less stringent than the methods I already use.
Hepa Vac. Here's a place to be careful. There are a lot of HEPA vac filters offered by the various vac manufacturers. However, to be EPA compliant the vacuum must provide for sufficient containment of released particles. I have heard that Fein is going to be offering a newer/better HEPA filter along with I guess something they already have-a beater bar floor tool that is another recommendation (requirement?) of the EPA. This enables better pickup of dust and debris from carpet. As to the vacs themselves (and I do not have the pertinent numbers in front of me) they must not emit a certain amount from the exhaust. That's the sticking point if the vacs do not meet and certify that standard.
My supplier that put together the class is offering 3 approved vacuums at a not outrageous price-from the small at 250.00 up to a 5 gal at 450.00 with the beater bar attmnt included. Their BBar are air powered and about 50.00/the Fein is electric (runs off the attmnt power switch).
What I got from the class was good. What I found from the class is that there's still a few unanswered questions. Will they keep the OPT OUT possibility where a customer can sign a release that there are no pregnant women nor children under 6 in the house (PRE 1978). This would absolve you of having to use the containment / cleanup guidelines.
What are the specific HEPA vac rules-is the EPA or a testing company going to certify additional vacs as compliant - I believe there's only a couple now-an electrolux model and some from Pullman Holt.
For your safety they recommend an N-100 mask, Will the P-100 and R-100 also comply with lead dust ratings. Remember, this is for your safety, for homowners the masks, nitrile gloves, tyvek suits......mean nothing (sort of-you don't want to bring your demo dust/scraps into other areas of the home, nor to your wife and kids via the back of the van, the truck seat or your clothes.
After class I wondered how I could possibly be walking around at 60 years old after 38yrs of attempted suicide.
I would go to the EPA site for lead and start reading. I did b/4 the class and am convinced I could have passed the test from just that advanced education. The book they issue at class and the additional information is important to know and worth the effort. After you go (during) through all the containment and cleanup you need to do some pretty serious record keeping. There's checklists available from the EPA site for just that purpose. The documentation needs full compliance and keeping for at least 3 yrs.
Check with your suppliers-here in NW Oh Sherwin Williams is offering the class for 99.00. Andersen Windows is doing some around the country for I think 175.00 and you get a 100.00 coupon to apply to any window or door purchase. The one I took was from ModernBuildersSupply, a regional company-225.00. There's a class aitchkay from Ann Arbor mentioined for maybe 150.00 with HBAor Remodelers Org. membership.
Hi Calvin,
I've taken the class and am waiting for my certificate in order to apply for my firm certification. For me and my two guys to take the class, miss a day of work wages and pay the firm's EPA fee, I'm out nearly $2000.00 And I'm going to have to make some hefty equipment investments.
I specifically asked my instructor if you needed to use shrouded saws. He said any power tool that cuts or abrades. I'm not sure he is right though. I read the actual regulation and it says the prohibited practices are:
(i) Open-flame burning or torching of lead-based paint is prohibited.
(ii) The use of machines that remove lead-based paint through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, is prohibited unless such machines are used with HEPA exhaust control.
(iii) Operating a heat gun on lead-based paint is permitted only at temperatures below 1100 degrees Fahrenheit.
I guess it depends on how you define "high-speed operation". One could probably argue that a sawzall is not a high-speed operation, but less successfully argue that a circular saw is not.
Anyway, as I said, I do plan to comply with the spirit of the law, but some of their prescribed way of doing things are not going to be realistically feasible. It's clear the what they can effectively monitor is your record keeping and the actual cleanliness of the site, so what's going to be of primary importance is clean-up, and record keeping. What happens between starting work and clean up is not realistically going to be monitored, but WILL affect the workers' health and the ease of clean-up. So I want to run as safe and efficient a job as possible.
Steve
I understand now that you have taken the class.
I would not consider the sawzall a paint removal tool. That paint is removed somewhat during the cutting-a vac hose close should get alot of the airborne and/or misting it.
Boy, what a chore this is going to be. Besides the prep and cleanup-the actual operation is going to be extra time ($) consuming.
I assume you know that only the firm needs the EPA registration. And I would go ahead and file your form and 300.00 now. You don't need the certification certificate to do so.
Best of luck.
RRP compliant vac's
HI Calvin,
Could you post the list of "3 approved vacuums" from your supplier? That seems to be the rub, the aledged difference between HEPA filter and HEPA vac. In my shopping for appropriate equipement I've found web site's to not be clear on qualifying for use. I did speak with customer service at Festool who said their tool is being tested this week for compiance, unsure on when results will be published.
Thanks,
Kurt
http://www.bayerbuilders.com
Vacs.
Here's the big one they (Modern Builders Supply-Ohio Region) offer for 399.00, with added beater bar-47.92.
I searched online and came up with an internet sales place-600.00 w/o the beater bar.......whoa. If in Ohio or surrounding states, check into MBS.
http://www.atrix.com/pdf/HCTV5H%20w%20BB%20Brochure.pdf
From the same company, Green Supreme HEPA Vac-model VACGRNS-MBS-229.00 plus 47.82 for beater bar.
Saw online for 349.00-no beater bar.
http://www.atrix.com/pdf/VACGRNS%20Brochure%20w%20BB.pdf
And the Omega Hepa Abatement Vacuum Vacomegah-209 plus the 47.92 beater bar from MBS
http://www.rrp-training.com/pdf/atrixhepahandoutcolor.pdf
Please note, The specs seem to be in line with the EPA guidelines. However, there's NO REAL approval other than what you can search for and read. Whether they are recognized by the EPA I have no idea. These vacs go from large (5 gal to 1 gal I believe. The last two have an optional backpack harness for about 85.00.
Additionally look through the Pullman Holt company for more vacs.
Seems a safe bet might be those used in Lead and asbestos abatement-BUT, beats me. I'm hoping I can get my Festool vac up to par.
Best of luck, and if you think that anything from MBS is something you'd like-please if not in our area-OHIO, IN, Mi. Ky, W.Va and Penn. (I think on those other states) and you want to talk to a good looking sales rep-lemme know-I've got a good one.
http://modernbuilderssupply.com/
Edit: I see you're from Dayton-there's an MBS there I'm sure-give them a call.