The ABCs of the RRP: Overview of EPA’s New Lead Rule and Best Cleaning Practices

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The presentation reviews EPA's rules on lead and lead abatement. It explains the guidelines for cleaning lead-contaminated areas using best practices for industrial hygiene. It explains HEPA …

The presentation reviews EPA's rules on lead and lead abatement. It explains the guidelines for cleaning lead-contaminated areas using best practices for industrial hygiene. It explains HEPA filtration and how to choose a HEPA vacuum for cleaning lead to ensure workplace safety.

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  • 1. Nilfisk Industrial Vacuums The ABCs of the RRP Overview of EPA’s New Lead Rule and Best Cleaning Practices 2011Presented by Corry Luckenbach, Product Manager, Nilfisk-CFM
  • 2. Presentation Topics General Info about the RRP Rule - Purpose & Target Areas of RRP Standard - Deadline Extension Lead-Based Paint (LBP) - What is LBP? - Dangers of Exposure to LBP Overview of EPA-certified, RRP Training Program - Quick Facts - Highlights from the RRP Training Course “HEPA Vacs 101” - Definitions and FAQs - How to Choose a HEPA Vacuum - Recommended Nilfisk RRP Vacs
  • 3. The ABC’s of the RRP General Info about the Lead RRP Rule
  • 4. General Info about the RRP Rule• First published on April 22, 2008 under authority of Toxic Substance Control Act section 402(c)(3)• RRP final ruling is being enforced by the Environmental Protection Agency (EPA)• Purpose is to focus attention on activities that disturb LBP in target housing and child-occupied facilities. Target Housing - Home or residential unit built on or before Dec 31, 1977 (some exceptions) Child-Occupied Facilities - A pre-1978 building that meets all 3 of the following criteria: - Visited regularly by same child under 6 years old - Visits last min. of 3 hrs. each, twice per week - Weekly visit total 6 hrs. min., annual total 60 hrs. min.
  • 5. General Info about the RRP Rule RRP Ruling Requirements: • Renovators and dust sampling technicians must be trained and certified • Renovation Firms must be certified • Training providers must be accredited • Lead-safe work practices used during renovations • Non-certified workers must work under and be trained on-the-job by a Certified Renovator • Renovators must educate owners/occupants
  • 6. General Info about the RRP initiative Some Exceptions to the RRP Rule: • Painting only (not disturbing paint surface) • Disturbing less than 6 ft2 (inside) of paint surface or less than 30 ft2 (outside) within a 30 day period • You as the home owner complete all work yourself • Your home was built after December 31, 1977 • RRP work is being donated (charity work) • Emergency renovations (cleaning is still required at the end of project)
  • 7. General Info about the RRP initiative RRP Deadline Extension: • Initial enforcement date was April 22, 2010 • EPA extended deadline to October 1, 2010 taken directly from EPA memo dated June 18, 2010……..
  • 8. The ABCs of the RRP Lead-Based Paint
  • 9. Lead-Based Paint (LBP) What is LBP? • Any paint or surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or more than 0.5% by weight 1 • Paint having lead concentrations higher than 5000ppm 2 Why was lead used in paint? • pigment (yellow, white) • reduced drying time • improved flexibility and durability • enhanced appearance and shine • improved moisture resistance 1 Lead Safety for Renovation, Repair and Painting Student Manual, EPA-740-R-09-002 2 Residential Lead-Based Paint Hazard Reduction Act 1992
  • 10. Lead-Based Paint (LBP) Dangers of exposure to LBP • Especially damaging to children under the age of 6 as their bodies are still developing • Lead causes nervous system damage, stunted growth and delayed development • It can cause kidney damage and can affect every organ system of the body • Lead is also dangerous to adults and can cause reproductive problems for both men and women • Lead can be tempting for children to ingest because of its sweet taste
  • 11. Lead-Based Paint (LBP) How are painted surfaces tested? • Swab tests • X-Ray Fluorescence (XRF) Analyzer • Paint chip sampling, followed by analysis by an accredited laboratory
  • 12. The ABC’s of the RRP Overview of EPA-certified RRP training program
  • 13. Overview of EPA-certified, RRP training program Quick Facts: • Approx. cost $195.00 • 1 day, 8 hour session • Combination of classroom and “hands-on” exercises • Short test at the end • Training manual (at right) is yours to keep • Find local training locations near you at
  • 14. Overview of EPA-certified, RRP training program The RRP course will teach you: • Why lead based paint is a problem during renovations • What the EPA / HUD regulations require of Certified Firms and Certified Renovators • How to determine if lead-based paint affects work • How to begin work • How to set up the work area to contain dust • How to work in a lead-safe manner • How to clean the work area and verify cleanliness • How to dispose of waste safely • How to document your work
  • 15. Overview of EPA-certified, RRP training program “Hands-on” highlights: • Learn how to test paint surface using Lead Check swab (new EPA-approved D-Lead test swab for plaster, drywall, metal and wood, see • Learn how to setup work area (limit access, signage) • Practice masking techniques on doors, furniture, windows, vents and floors • Practice cleanup and proper waste disposal technique • Perform a final wipe down to verify cleanliness • Establish containment area for exterior work
  • 16. Overview of EPA-certified, RRP training program Certificate: “EPA-certified Lead Renovator” Certification valid for 5 years
  • 17. Overview of EPA-certified, RRP training program What the RRP training course is NOT: • The course is not an abatement course • It does not satisfy OSHA training requirements • May not satisfy state, local or tribal training requirements
  • 18. The ABCs of the RRP HEPA Vacuums 101
  • 19. HEPA Vacs 101“HEPA” = High Efficiency Particulate Air• Minimum efficiency for a HEPA filter as defined in MIL-STD-282 is 99.97% capture of particles down to and including 0.3 microns• 1 micron = “one millionth of an inch” (0.000001 inches)• A human hair is generally between 80-100 microns• “Certified” HEPA filters are tested (usually by the manufacturer) to prove they meet the minimum efficiency
  • 20. HEPA Vacs 101 A laser photometer (particle scanner) is used to measure the amount of penetration HEPA A “challenge aerosol” made up of 0.3 micron sized particles is drawn into the filter
  • 21. HEPA Vacs 101
  • 22. HEPA Vacs 101FAQs Q: If I purchase a HEPA vacuum, is the entire vacuum certified or just the filter? A: In most cases, only the filter is certified. As of today there are no standards in the US that require the entire vacuum cleaner to the certified. For special applications, some manufacturers will perform testing on the entire vacuum.
  • 23. HEPA Vacs 101FAQsQ: Why isn’t the entire vacuum tested for HEPA efficiency?A: The only way to verify HEPA efficiency is to test and retest. A vacuum that passes successfully one day may not pass the next (i.e. vacuum or filter could be damaged during use). Testing requires special equipment and can be very costly to perform. Without an “enforceable” standard in place, manufacturers have been slow to adopt machine testing.Q: Does the EPA certify vacuums for RRP use?A: No, the EPA does not provide certifications for vacuums.
  • 24. HEPA Vacs 101FAQsQ: Can I add an optional HEPA filter to my existing vacuum and use it for RRP work?A: Low-cost, general-purpose, vacuums that have optional HEPA filters are not being recommended for RRP work. Only vacuums equipped with a HEPA filter as standard that are designed to collect toxic materials are being recommended.Q: What other tools will I need with my HEPA vacuum to perform RRP work? A: Any carpets/rugs in the area of RRP work will have to be cleaned using a floor tool with a “beater bar.”
  • 25. HEPA Vacs 101Beater Bar Options Power Nozzle Kit • Motor-driven beater bar • Higher performance & price Turbo Nozzle • Air-driven beater bar (air from vac drives bar) • Lower performance & price
  • 26. HEPA vacs 101How to choose a HEPA vacuumStart with the HEPA filter. Ask the manufacturer iffilter testing documentation is provided with thevacuum/filter or if it is available upon request?
  • 27. HEPA vacs 101How to choose a HEPA vacuumWhat kinds of materials will you be collecting?Different filters may be needed to collect the following:• Fine, dry powders/dust• Heavy soil• Liquids• Dry, chunky debris• Wet and dry materials at the same time• Toxic materials (lead, asbestos, mold, etc.)
  • 28. HEPA vacs 101 How to choose a HEPA vacuumWhat environment(s) are you working in?• Residential home (want low noise level, 100% dust capture)• Outdoor jobsite (portability, long cord, big wheels, rugged)• Commercial building/factory (large areas, improved surfaces)• Hospital/Laboratory (low noise level, EMI suppression, conductive tools, HEPA filter mounted after motor)What is the air quality in the work area (dusty, humid)?• Choose a vacuum based on how it’s motor is cooled o “Through-flow” cooled motors are better for dry, dusty areas o “Bypass” cooled motors are better for wet collection
  • 29. HEPA vacs 101How to choose a HEPA vacuumWhere is the HEPA filter mounted on the vac?Before the motor (Upstream)• Filter out hazardous materials before they enter the motor• Safer when repairing and maintaining the vac• Easier to maintain seal of HEPA while under vacuum• Most popular method used in “abatement” vacuumsAfter the motor (Downstream)• Most commonly used in cleanroom/pharmaceutical areas• Captures all carbon brush and motor residue• Tends to be more expensive
  • 30. HEPA vacs 101How to choose a HEPA vacuumWhat quantity of material will you be collecting?• Choose the right size/capacity of vacuum for the job• Bigger is not always better (keep in mind portability, available storage space, noise level of vacuum, etc.)
  • 31. HEPA vacs 101Recommended RRP Vac: Model GD930 Lid Upstream HEPA Dust Bag .. Power Nozzle Outlet
  • 32. HEPA vacs 101Recommended RRP Vac: Model GD10 Back Upstream Dust bag fits HEPA inside of sack filter
  • 33. HEPA vacs 101 Recommended RRP Vac: Eliminator models I/IIEliminator I Upstream HEPA Wet/Dry Sack Filter Float Chamber (for conversionEliminator II to wet collection) Synthetic Dust Bags available
  • 34. HEPA vacs 101Other popular Nilfisk RRP HEPA Vacs UZ964 UZ934 GWD120 Wet/Dry GWD255 Wet/Dry“Hip Vac” Dry Only GWD220 Wet/Dry Drum Top Vac Dry Only
  • 35. The ABCs of the RRP Questions? Email: Phone: 800-645-3475