How thick are you? 6 MIL. 4 MIL.

Poly Vertical Containment

This question was posed to me in an RRP Lead-safe Training:

QUESTION
What does the EPA and also the State of Massachusetts require (or are they different) for the mandatory thickness of your poly? Does it have to 6 MIL? Or can it be less? What is the rule?

ANSWER
Neither has a thickness requirement for RRP. It is a “performance-based” measure that says whatever thickness the professional uses it must be able to perform the task it is intended to do.

MORE BACKGROUND
I checked with another colleague of mine to ensure my answer is correct here. The key to most questions that come up in this training often go back to the words “performance-based”. It is a “performance-based” training and a “performance-based” law, meaning that the contractor must do whatever is necessary to perform according to the standard. The RRP law says that all paint chips, dust and debris generated by the renovation, repair or painting work must be collected and not a single speck can be left behind. That is the standard to which you must “perform”. So when contractors lay down the plastic, it can be any thickness they desire, but if it rips, then they must clean and pick up and not let any dust or debris migrate outside the work zone (area where you lay down your poly). It requires planning, experience, attention to detail, continued evaluation and proper execution. If you planned and set up a certain way covering the rugs in a sunken living room, and as you begin to work you realize that what you did wasn’t going to perform or do this job; then you must stop and take the time right away to fix it so that you don’t suffer later by having to clean the next room or the whole house because you wanted to save 30 minutes of additional set-up time. This is the type of attention to detail necessary and what a good trainer will discuss and teach in the RRP training.

Let me give some more background on RRP to help clarify in case someone didn’t follow that one sentence answer above. The federal government (the EPA) put out this rule (or law) effective on April 22, 2010 mandating that all contractors, landlords or tradesman of any type who do work that disturbs painted surfaces on a residence or child-occupied facility built prior to 1978 must adhere to these safe work practices to prevent the spread of lead-based paint dust and debris throughout that residence or facility. (Wow, was the a run-on sentence or what!? Thankfully I don’t read that in a training like some lousy trainers do.) Such contractor, landlord or tradesman must take an 8-hour training and pass the written exam, as well as register themselves with the EPA or work for a company that is registered with the EPA to perform such renovation work. This 04/22/10 law is referred to as the RRP rule, which stands for “Renovation, Repair and Painting”.

As of July 9, 2010 the Commonwealth of Massachusetts took over the law for work in MA. The training is reciprocal, meaning that if you took or if you take the EPA’s RRP training in CT, NH or ME -for example- then MA will recognize that training. Likewise, if you took the 8-hr training in MA, then the EPA states (about 39 of them) will recognize your certificate from MA. You will still have to register yourself with the EPA and MA separately (2 separate fees), but you can at least just take one 8-hour training to cover pretty much all 50 states. Now, there are some differences!! And you must learn them.

If you have any specific questions on the differences between the EPA and MA rules for RRP, post them here in the comments and I will answer it right away if possible. If it requires some research on my part, I commit to picking at least one question a week to answer on my blog.

I’ll write again soon. Have a great week!

-Steve

Spanish OSHA Guy!

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