Safe Work Practices

There is a phrase being bantered about in the remodeling industry these days. It is a phrase that usually weighs most contractors down and one that puts a heavy burden on the remodeling industry. That phrase is ‘lead safe work practices’. Lead safe work practices (LSWP) are the foundation of EPA’s recently proposed Renovation, Repair and Painting rule (RRP). When enacted (a date yet to be determined) the LSWP contained within the RRP will be mandated on all renovation projects in houses built before 1978 where more than 2-square feet of painted surface is disturbed. Let’s say a contractor wants to get a jump on the competition and learn more about safe work practices, where would such a proactive remodeler start?

The following is a discussion that will help serve as a guide through the various sources of LSWP for remodeling. We will also look at other suggested good work practices for remodeling and lastly, expand the discussion to what I call Dust Safe Work Practices© (DWSP).

LEAD SAFE WORK PRACTICES

The first source of LSWP for remodeling was published in 2000 by the EPA. It is a training course titled, Model Training Course: Minimizing Lead-Base Paint Hazards During Renovation, Remodeling, and Painting (MTC). It contained general information about lead history, health hazards of exposure to lead, suggested LSWP and a reference guide titled, Lead Paint Safety: A Field Guide for Painting, Home Maintenance, and Renovation Work . The field guide can be downloaded at http://www.hud.gov/offices/lead/training/LBPguide.pdf.

The MTC was developed to satisfy lead awareness training requirements for contractors working in HUD funded projects and also lead awareness training requirements mandated by states with their own lead programs. The MTC was used as a model for what is currently being taught as the accepted LSWP in remodeling.

In 2003, EPA and HUD jointly developed Lead Safety for Remodeling, Repair, and Painting (LSRRP). This course will most likely be approved for the required training for ‘renovators’ as stipulated in the RRP and thus will be presented by approved instructors and provide certification for attendees. Currently, there are no requirements to present this course or certification to obtain by doing so. The value of taking this course now is the knowledge and understanding that is gained by doing so. The course books and PowerPoint presentation can be downloaded at for free at http://www.hud.gov/offices/lead/training/rrp/rrp_course.cfm.

The three main points of the LSRRP training are:

Set up and contain the work area.
Minimize the creation of dust.
Clean up the work area.

The LSWP contained within the RRP can be found in section §745.85 (a) Standards for Renovation Activities. Simply stated they are:

Provide occupant protection by keeping them out of the work area.
Contain the work area.
Remove or cover all objects within the work area.
Close and cover all duct openings.
Close windows and doors in the work area.
Cover the floor surface with plastic.
All personnel, tools and debris must be clean before leaving the work area.
Cover the pathway to work area.

The RRP also stipulates regimented project clean-up procedures.

GOOD WORK PRACTICES DURING REMODELING

When surfing around the internet a while back researching indoor air quality in remodeling, I came across this web-page, http://www.epa.gov/iaq/homes/hip-goodwork.html. It is the list of what EPA calls ‘Good Work Practices During Remodeling’. The list can be condensed as the following:

Correct underlying issues in the home.
Assume paint in pre-1978 housing contains lead.
Do not disturb asbestos.
Avoid exposure to mold or bacteria.
Avoid creating dust.
Provide ventilation for workers and the home.
Protect occupants from odors, pollutants and VOC’s.

DUST SAFE WORK PRACTICES©

It doesn’t matter if the dust on a remodeling project contains asbestos, lead, or mold; is drywall dust, paint fumes or just mud from workers boots. Professional remodelers need to establish policies and procedures to control it. They need to establish Dust Safe Work Practices© (DSWP) for their company. This process starts by training yourself and your personnel on EPA’s lead safe work practices and follow the recommendations found in the list of good work practices during general remodeling. Use these as models to develop standards to control ALL dust on your remodeling projects.

If you compare the lists above, you can see some common points: contain and isolate the work area, minimize creating dust, and keep jobsites clean. Now think about what your customers’ expectations are with these issues. We know that customer satisfaction increases with their perception on how well their project was kept clean. Utilizing DSWP increases the likelihood that your customers will be more satisfied with their remodeling experience.

If you are a professional remodeler looking to get a competitive advantage over your competition and are at all interested in protecting the health or your workers and your customers, develop standards for Dust Safe Work Practices©. Over time your workers will efficiently incorporate these methods into daily operations. Doing so now will put your company in the lead of your competition and prepare your business for a future when LSWP are the law of the land.

Article in Remodeling Magazine April, 2006

What does Dust Control mean? As a professional remodeler, the better you answer this question the better off you will be. There is increasing pressure being put upon the remodeling industry regarding proper procedures of dust control with pressure from litigation, liability, regulations and customer demands to control dust on residential remodeling projects. Remodelers cannot concern themselves with just the dust itself, they must also be responsible for protecting workers and customers from health risks associated with exposure to hazardous dust. And, as a professional remodeler they must always be mindful of earning and maintaining company profits.

One fact we are all know in remodeling- all projects produce some sort of dust particles. Normal household dust released by removing window treatments or carpeting; construction dust created by cutting and handling of materials such as OSB, non-treated lumber, concrete, drywall, cement-fiber products or insulation; hazardous dust such as fibers from disturbed asbestos, lead dust created by disturbing or removing building components painted with lead-based paint products or spores from mold hidden in walls or floors. There is no avoiding dust in remodeling -- the trick is how your company controls it.

PROTECT WORKERS

There are regulations imposed by the Occupation Safety and Health Administration (OSHA), to work in such a fashion so as not to expose workers beyond what is called the “action level” for lead and the “excursion limit” for asbestos and to never exceed what is called the “permissible exposure-limit” for either hazardous material. Additionally, OSHA mandates that workers do not exceed the “threshold limit value” listed on material safety data sheets for exposure to dust of all construction materials which are potentially harmful. Proper methods of employee personal protection, monitoring and record-keeping ensure workers are safe.

PROTECT CUSTOMERS

The Environmental Protection Agency (EPA) is responsible for protecting the public health and has established a goal of eliminating childhood lead poisoning by 2010. EPA’s Pre-Renovation Rule is one of several strategies used to reach this goal. It requires that remodelers or specialty trades contractors who disturb more than two-square feet of painted surface in a house or housing-unit built before 1978 provide the owner or occupant the EPA brochure titled “Protecting Your Family from Lead” prior to commencement of work. Further, as of January 10th, 2006 EPA released “Lead; Renovation, Repair, and Painting Program; Proposed Rule” which proposes regulations upon renovators or specialty trade contractors who work in pre-1978 housing and mandates company certification and worker training on lead safe work practices. This proposed regulation targets proper containment and clean-up procedures as another means of eliminating lead poisoning and puts this responsibility squarely on the shoulders of the remodeling industry.

PROTECT PROFITS

There exists a direct relationship between customer satisfaction and how well you keep your project neat, clean and orderly. Keeping a project clean is not just good for worker health, but also their productivity and ultimately your customer’s satisfaction. A well completed renovation, with a satisfied customer leads to solid profits and a strong potential referral customer. Linking company policies and procedures to dust control will not only earn your company profits, but protect them should anything go tragically wrong. Having an established system for delivery of your remodeling services focused on controlling dust should be weaved through your entire company from sales, estimating, and production to project close-out.

WHAT CAN YOU DO?

First, become personally committed to Dust Control in your company. A dedicated and comprehensive approach to controlling dust is the best way to ensure success in the remodeling industry of tomorrow. This dedication will need to manifest itself in the form of policies, procedures and standards that can be found in your company’s employee manual, health and safety program, training materials, project estimates and by the way in which your workers go about their work.

Second, become knowledgeable of occupational safety requirements to which your company must comply. OSHA is a federal level enforcement agency and has jurisdiction only in states that do not have approved state level occupational health and safety programs. Chances are that the state(s) your company operates within has an approved program and thus you are required to comply with those regulations, not necessarily those of OSHA. No matter the enforcement jurisdiction, all remodeling businesses need to have their own written health and safety program.

Third, ensure your employees, sub-contractors and sub-contractor’s employees have received adequate and proper training. This training must include that which is necessary for occupational safety and information of the hazards caused by exposure to the various types of remodeling dust, best practices to minimize exposure to dust, setting up and maintaining dust containment systems and clean-up procedures. Inclusion of sales staff in such training will help them build the value of the services your company offers and help explain the reason behind them.

Lastly, get ahead of the curve. Now is the time to differentiate your company from the competition with a comprehensive dust control program. Be sure to keep a watchful eye on EPA’s proposed lead regulations for remodeling. Once enacted, all remodeling firms will be mandated to have just that. Protect your workers, customers and profits by getting a jump-start on controlling dust.