During the demolition, I hauled the tile and debris out using trash cans with tops on them. (Heavy-duty bags are required during the final cleanup stage, but not necessarily during demo.) On larger jobs, we’ll cut demolition waste into pieces small enough to fit into the trash cans; one person loads the trash cans inside the containment area, while the other stays outside the containment area and hauls the cans to the dumping area. When we were done disturbing the bathroom’s painted surfaces, I vacuumed up leftover dust and debris using a Pullman-Holt HEPA vacuum (800/237-7582, pullman-holt.com), then performed final cleanup and cleaning verification. From that point on, we could rebuild the bathroom without thinking about RRP compliance.
Because the RRP has specific cleanup and verification procedures, it took us about 45 minutes longer to vacuum and wipe down the bathroom than it would have for a non-RRP job. Additional materials (above my normal material costs) were around $20, which included wet wipes and partial use of the vacuum’s HEPA filter.
Finally, I filled out the recordkeeping checklist, which took around 10 minutes. On this project, which had a total labor charge of about $13,000, RRP compliance added about two hours of labor and $35 in additional materials cost, or around 1 percent to 2 percent of the total cost.
OSHA Lead Rules
OSHA lead regulations – which are far more comprehensive than RRP rules – take effect whenever airborne lead concentrations exceed 30 mg/cm3 during any particular activity (the “action level”) and there is at least one employee (or a subcontractor acting like an employee) on the job site. OSHA rules can apply even when the RRP doesn’t, since paint with lead concentrations below RRP thresholds can still generate plenty of lead dust when sanded. In fact, lead dust can be present when there is no lead-based paint at all, because it can come from other sources, such as broken tile.
To be safe, there are some jobs where we follow OSHA procedures. On those jobs, we wear disposable suits, gloves, hats, booties, eye protection, and respirators. OSHA also requires a written compliance program, a clean area for changing clothes, and a hand-washing area. Blood monitoring, respirator fitting, training, site showers, extensive recordkeeping, and other OSHA procedures may also be required depending on the task and the number of employees.
To avoid the costs of OSHA compliance on every job, large companies often do testing and air sampling to determine that an activity – like sanding – won’t exceed OSHA’s 30 mg/cm3 action level. For smaller companies like ours, wet-sanding instead of dry-sanding and using shrouded equipment hooked up to a HEPA vac are cost-effective practices that can often keep dust levels below OSHA action levels.