Remodeling Dust

Significant Expansion of the RRP

2007-06-23T18:08:00.000-07:00

Pop Quiz!!

What is the over all goal of EPA’s comprehensive set of lead regulations called Title X?

Answer: To eliminate childhood lead poisoning by 2010.

With this in mind, it should be no surprise that during an almost two year long process of developing a regulation controlling exposure to lead on remodeling projects that the EPA would hoist the weight of their lofty goal directly upon the backs of the remodeling contractors across the country.

Let’s not forget that contractors in business today do not use lead based paint and subsequently did not create the lead paint hazards plaguing our industry. Nor are we specifically hired to remove any such hazards.

Earlier this year I talked about holding on to your hat due to the amount of activity on the RRP. Now would be one of those times.

On June 5, 2007, the EPA released a revised “Lead: Renovation, Repair and Painting Rule” (RRP). This revision expanded the scope of the RRP to include what the EPA calls ‘child occupied facilities.’

The EPA has concocted a typically governmental definition of a child occupied facility (COF). Basically, a COF is any building wear a child under six spends at least 3 hours per week for a minimum of 60 hours per year.

Schools, day care facilities, hospitals, the piano teacher’s house, dance studios, churches, grandma’s house are all included in this new scope. The RRP is not just for contractors working in old houses anymore. It has crossed into the commercial remodeling sector.

Additionally, the notification requirements that contractors must comply have expanded.

The revised RRP includes provisions requiring contractors to notify the parents or guardians of all children who meet the minimum hours of occupation in the building where the work is to take place. Contractors are to tell parents and guardians the project scope, dust control measures and the expected completion date of the project.

Just think of the time a contractor would have to spend answering the onslaught of questions from thirty to forty parents as to the potential health risks to their children and the precautions the contractor will take to safe guard their children from those risks during the renovations of say an elementary school, a hospital childrens' ward, etc.

Just think about the liability for not doing so. How much time would you spend defending a multi-party lawsuit for not following these very prescriptive requirements?

Still have your hat?

Safe Enough for a Three Year Old

2007-05-23T17:59:00.000-07:00

After being contacted by Cati O’Keefe with Remodeling Magazine to schedule time to speak about job site cleanliness and safety on remodeling projects, I asked myself the question, “How clean is safe?” The answer came to me a couple days later when I installed some recessed lighting in my own home.

My wife and I are blessed with twin boys that happen to be 3 years old. After answering them at least twenty times as to why I had to go into the attic, I found myself working in such a fashion that my boys could be around watching and ‘helping’.

For the record, my house was built in 1994. So, there is no threat of exposure to lead based paint. There was however, the expected amount of drywall dust generated during the removal of the surface mount outlet boxes and the cutting of holes for the new fixtures.

During the installation of three recessed lights in our upstairs hallway, I vacuumed no less than four times; once after preparing each new opening and once again at the completion of the project. At no time was there debris on the floor. Keeping the work area this clean and safe allowed my boys to be around.

I realize that this work process did take longer to complete than it could have, but it was well worth it to have my little helpers there.

This experience kept me thinking about my discussion with Ms. O’Keefe. Costumers continually complain about how messy their remodeling projects were. The EPA is moving ahead on mandating lead safe work practices. How does a remodeler know they are working safely and cleanly?

The simple answer to this the question, “Safe enough for a three year old.”

On projects where this is just not feasible, install physical barriers, such as visqueen plastic to keep occupants from entering the work space. Your contract may need to stipulate that occupants must be out of the house during certain phases of the project: demolition, drywall sanding, window installation, etc.

If workers manage their work processes and job site such that if a three year happened walk through it would be no big deal. Doing so is much safer for the worker, more productive for the contractor and provides a better remodeling experience for your customers.

Go for Gold

2007-04-17T19:16:00.000-07:00

“Professional remodeling following LSWP remains the gold standard for home renovation…,” according to the National Association of Home Builders (NAHB).

In comments submitted to the EPA regarding the proposed “Lead: Renovation, Repair and Painting Rule,” on April 16, 2007, the NAHB puts forth two points that again show that only trained professionals should do remodeling.

Point One:

“Remodeling Using Lead Safe Work Practices Improves a Home’s Condition”

According to results from the 2006 NAHB lead study where workers followed EPA’s suggested lead safe work practices (LSWP) or what are called ‘modified’ lead safe work practices, a remodeling project is ‘cleaner’ then if the workers used standard remodeling work and clean up techniques, such as the woefully inadequate term, “broom swept.”

Some specific LSWP include:

· Repeated use of HEPA filter equipped vacuums.
· Wet-wiping of the work area.
· Use of 6-mil plastic.
· Misting surfaces before removing, cutting or scraping.

Other methods can be used as part of an overall LSWP strategy. The NAHB understands there are additional costs in using LSWP, but asserts the benefit to health and safety out weigh those costs.

Only trained professionals will know the proper lead safe methods to employ on a given project. All too often, reports of a child being lead poisoned come from a story where a homeowner or untrained contractor unknowingly creates and leaves behind a lead hazard.

Point Two:

“Encourage Trained Remodeling Work in Target Housing”

Here again, the NAHB asserts the need for remodelers to be trained on LSWP. Having remodeling completed by trained professionals not only improves the value of the house and improves the quality of life for the occupants, but increases the “…safety value of a home.” Scoring this hat trick for occupants certainly shows that hiring a professional to do your remodeling makes the most sense.

Offer your clients the Gold Level of service -- get trained in LSWP.

Gotta Love Those Loop Holes

2007-03-14T20:03:00.000-07:00

If you are like most people, reading federal regulations is not something you do on a regular basis. Doing so can definitely lead one to want to chew on aluminum foil, get your teeth cleaned or some other such relatively fun activity. However, if you can bare reading through certain regulations you can not only find little gold nuggets of information to improve your production, you can find lovely little loop holes to boost your profits.

OSHA’s 29CFR 1910.134 Respirator Protection is one such regulation. It provides valuable information for companies whose workers must wear respirators and has one of those loops holes that helps residential remodeling companies avoid the expense of complying with all the stipulations of the Respirator Protection regulation.

1910.134 has three main goals:

1. Advise workers on the types of respirators available.
2. Institute medical surveillance of workers before they wear a respirator.
3. Provide methods of ‘fit testing’ ensuring workers are protected.

The Respirator Protection regulation further requires employers to develop and maintain a written respirator protection program when respirators are required. So, the next obvious question is, “Are respirators required on your remodeling jobs?”

For those of you that do have workers wearing charcoal filtered respirators such as those worn during painting activities using airless or HVLP the answer is yes.

If your operations are those typically found in residential remodeling projects around the county, those that create dust or are potentially exposed to mold or lead dust, the answer is no.

Why is the answer no? Well, after slogging through the Respirator Protection regulation you will come across section 1910.134(c)(2)(ii). The second sentence of this section states, “Exception: Employers are not required to include a written respiratory protection program for those employees whose only use of respirators involves the voluntary use of filtering face pieces (dust masks).”

Translation: Loop hole.

Well, sort of. You still need to look out for the respiratory safety of your workers. You do not necessarily need a written respirator protection program if your employees only wear dust masks. But, we all know that the run of the mill dust mask isn’t worth a darn. There is a dust mask that provides a high level of protection for workers and thus allows you to drive through the loop hole.

The National Institute for Occupational Safety and Health (NIOSH) does have standards for dust masks. The type of dust mask that provides protection against lead particles and has a HEPA rating is a NIOSHA N100 dust mask.

If you want to protect your workers and avoid the costs of designing, implementing and maintaining a costly written respirator protection program, run out and buy your workers NIOSH N100 dust masks. Be sure to train them on the proper use of these personal protective devices and the potential health hazards for not wearing them.

For further information as to whether respirators are required, refer to the MSDS sheets of the products you workers are using. For those of you merely performing tasks where you are exposed to mold, lead dust or other types of remodeling dust, the N100 dust mask is just the ticket.

$31.4 Million Dollars to Clean Up Lead

2007-02-20T08:15:00.000-08:00

With all the lead and dust talk lately focusing on the EPA, I would be remiss if I did not give kudos to HUD for continuing its efforts to eliminate childhood lead poisoning by 2010 (EPA’s unattainable goal date). In a press release dated January 5, 2007 HUD announced this year’s recipients of $31.4 million dollars in Lead Hazard Reduction Demonstration Grant funding.

According to Secretary Alphonso Jackson, "The communities receiving grants today have demonstrated that they are fully committed to making their older housing safer and healthier places for children."

This year’s grants were issued to 12 cities and counties throughout the United States. These programs will provide community education, homeowner awareness training, contractor lead safe work practices (LSWP) training and fund actual renovations to what are known as ‘target housing’ -- housing built before 1978 with a child under the age of six living there.

Remodelers will find interesting that these programs provide what is known as HUD’s 3R’s training. This training is almost the exact LSWP training required in EPA’s proposed Renovation, Repair and Painting Proposed Rule. With these classes being mandated in the future, taking them now will give you a jump start on your competition.

The best news is that taking one of these training sessions is free and gives your workers the training necessary to bid on the actual renovation projects funded by this program

To see the list of cities and counties receiving HUD’s Lead Hazard Reduction Demonstration Grant funding this year click the link ‘here’.

Hold on to Your Hat

2007-02-04T19:04:00.000-08:00

Back in November I said the wheels of the RRP are in motion. And man, are they. Do you have your hat?

The EPA released its second major study examining lead exposure during remodeling projects on January 23, 2007. The report is succinctly titled Draft Final Report on Characterization of Dust Lead Levels After Renovation, Repair and Painting Activities as prepared by Battelle in Columbus, Ohio. This report can be downloaded by clicking ‘here’. Here is what the report found. Still have your hat?

In the summary of conclusions, the EPA states, “Application of the package of plastic protective sheeting, HEPA vacuuming and wet mopping, and cleaning verification practices in EPA’s proposed rule did result in lower lead levels at the end of a job than were achieved using baseline practices (no plastic protective sheeting and cleaning with a broom and a shop-vacuum vacuum).” Where’s my hat?

So, the EPA commissioned another study that reinforced what NAHB’s study reinforced and something every mother in America knows. If you work in such a way as to not make a mess, then clean up the mess there is no mess: clean as you work! I found my hat. I’ve had it on the whole time waiting for something to blow it off.

Thus far, the only thing even remotely close to doing this is the meeting of the Clean Air Scientific Advisory Committee (CASAC) Lead Review Panel. This group of medical doctors, pathologists, and Ph.D’s in metallurgy and toxicology will be getting together in North Carolina on February 6th and 7th. This is the panel that helps the EPA establish the amount of lead in someone’s blood to be considered an elevated blood-lead level (EBL).

Their agenda includes discussion of the proposed lead rule and review of EPA’s and NAHB’s recent lead studies. Rumor has it that they are trying to establish a correlation between IQ levels in children and renovation activities. As CASAC meets fairly regularly, we’ll have to see what they come up with.

I’m holding on to my hat…

The RRP: Where are We Now?

2006-11-20T05:59:00.000-08:00

You may recall that the EPA proposed a new regulation on lead for the remodeling industry in January of 2006 called the Renovation, Repair and Painting Program. This proposed rule is commonly being referred to as the RRP. Generally speaking it contains mandated work practices and requires certification of workers and companies that disturb more than two-square feet of painted surfaces in target-housing -- houses built before 1978 that might contain lead-based paint. This rule is moving forward. So, where are we now?

Members of the NAHB Lead-Based Paint Task Force (LBPTF) met with EPA in November of 2006 to discuss this rule and present the results of a study looking at lead-dust generation commissioned by the NAHB. These discussions did not reveal EPA’s intentions on when they plan to enact this proposed rule or what the requirements of the final rule will be, but Jim Gulliford, the U.S. Environmental Protection Agency's assistant administrator for prevention, pesticides and toxic substances, did assert, ”The EPA wants an effective and efficient rule.” Hopefully, the results of the NAHB study will have a positive effect on what the final RRP looks like.

The NAHB conducted a study titled, "“Lead Safe Work Practices Project Survey Report,” which established that houses have less of a lead-dust hazard after remodeling than before, with only one exception. That exception is if a worker performs what the study identifies as ‘uncontrolled sanding’ or sanding using a power tool without supplemental or an integrated dust collection system, i.e. vacuum attachment. Lead-dust levels where lower in nine of the eleven activities measured by the study. The two activities that showed an increase in lead-dust were those where ‘uncontrolled sanding’ took place.

As a result of the lead study, the NAHB has made recommendations of what activities remodelers should not to do on remodeling projects. These recommendations follow right along with the list of prohibited practices established by HUD in 2000: no powered sanding or grinding without an attached HEPA filtered vacuum attachment, no open flame burning, no abrasive blasting or sandblasting, no use of heat guns that operate above 1100-degrees Fahrenheit, no use of volatile paint strippers and lastly no dry sanding or scraping. It is further suggested to incorporate the EPA’s suggested good work practices during remodeling on your projects. This list can be found at: http://www.epa.gov/iaq/homes/hip-goodwork.html

If you are a typical remodeler, you do not perform most of these activities. You may be saying to yourself, “Well if the study shows typical remodeling activities do not create more of a lead hazard and remodelers do not perform the types of activities that do, why do we need the RRP?” The answer is simple: lead is harmful and children all across the nation are still poisoned each year by it. This is why the EPA is adamant that such a rule is enacted and why remodelers must prepare themselves for the day this rule goes into affect. Additionally, the EPA is getting appreciable pressure from a group of congressman lead by Senator Barack Obama (D) from Illinois to release the RRP. The EPA has more than a few issues to work through to make an effective and efficient regulation over and above political pressure.

First, the NAHB study shows that typical remodeling activities do not create a lead hazard. The stated goal of the RRP is to ensure that lead hazards are not created and left behind on remodeling projects. Thus, looking at the results of the NAHB study a logical question is, “Do we need the RRP?” Second, the RRP does not address over half of the remodeling activities done in this county by the do-it-yourselfer. This issue is something the EPA will need to take a serious look at if it is committed to eliminating child lead-poisoning. And third, the EPA will need to analyze its own recently commissioned study. The results of which are not expected until early 2007.

So hold to your hats for the dust storm of the RRP is brewing in DC. The wheels are in motion on the RRP and the EPA will enact this rule sometime in the future. The LBPTF will stay vigilant that the EPA does not promulgate an onerous regulation upon the remodeling industry. A restrictive regulation would increase the cost of remodeling and provide an incentive for homeowners to do more of their own work or hire less professional contractors. This in turn could lead to the possibility of even more children getting lead-poisoned -- the exact issue the EPA is attempting to eliminate.

The best guess is that the final rule will not be published until at least 2008. Stay tuned for further updates…

Safe Work Practices

2006-06-28T05:21:00.000-07:00

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

2006-06-21T19:20:00.000-07:00

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.

Comments on EPA's proposed Renovation, Repair and Painting Rule

2006-05-26T05:32:00.000-07:00

With the stated goal of this rule being, “…to ensure that lead-based paint hazards are not created and left behind after residential renovations,” EPA has placed the responsibility of achieving the goal of Title X squarely on the shoulders of the remodeling industry. That goal of course being to eliminate childhood lead-poisoning by the year 2010. In EPA’s attempt to promulgate rules regulating lead in remodeling activities they have created a series of major issues that will greatly affect the remodeling industry as a whole.

The RRP does not correlate or reconcile with existing regulations protecting workers.

With OSHA regulating worker exposure to lead through 29CFR1926.62 Lead Exposure in Construction, it certainly strikes an odd note that the RRP does not prohibit known unsafe lead work practices such as open flame burning, chemical stripping, abrasive blasting and dry sanding or scrapping. This lack of interdepartmental collaboration will cause remodeling contractors to ask the question which regulation should one follow? A unified approach to the issue of prohibited practices and agreement on what constitutes lead safe work practices would eliminate what will undoubtedly cause confusion to the renovation firms and the renovation customers.

It provides incentive to homeowners to not hire professional remodeling contractors.

Many of the practical applications contained within the proposed rule can be used as a model for how to control the creation of and better contain not only lead dust, but all types of dust found on a remodeling project. Those renovation contractors with solid business structures and operating procedures conduct their projects in such a way as to minimize exposure to workers or occupants to any potentially hazardous materials. Subsequently, the pricing structure and customer expectations of such sophisticated contractors already factors in the costs of controlling dust; however, not to the degree of clean-up, clearance requirement and training which is called for in the RRP. For the novice, up-start or less sophisticated contractor the cost of implementing such control measures will certainly get passed along to customers. These additional costs ranging from 5-20% will undoubtedly find their way directly to the customer. Such significant cost increases will either un-motivate a homeowner from doing basic maintenance and upgrades or other renovations due to cost or hire unskilled and untrained personnel to complete their projects. Either of these options leads to an exacerbation of lead hazards or the creation of lead hazards.

This rule does nothing to provide protection for those companies or individuals working in housing built before 1978.

As a remodeling contractor that carries general liability insurance as a general contractor, I had a tough time reading the lead exclusion clause of my liability policy. This left me feeling particularly uneasy when I started thinking of all the target-housing projects I have completed that are essentially dormant potential lead liability law suites. Sure there are pollution liability riders that can be obtained if lucky enough to find one. However, the application processes and yearly premiums are cost prohibitive. Such a liability rider is difficult to obtain if a renovator is not an EPA certified lead abatement company or industrial hygienist.

The RRP does not go far enough in providing strategies to reach the goal of Title X.

Residential remodeling activity surpassed $230-billion dollars in 2005. Of that, 40-50% of that activity was conducted by do-it-yourself contractors. The RRP only applies in the case where renovations were performed for compensation. This stipulation carves out a large part of the renovation activity from being under the jurisdiction of this rule. Subsequently, combining the amount of current renovation activity being completed by non-professionals with the increased underground activity sure to happen in response to this rule, the RRP may in-fact lead to increased childhood lead-poisoning. The EPA should take the goal of Title X more seriously and shift the emphasis of lead exposure from the professional remodeler and onto this unregulated segment of the population.

Additionally, the rule has spawned some more simple questions:

How do workers clean or protect motor housings on power hand-tools from dust?
How do firms determine the age of the home?
What does a firm do if there was no child present at time of signing contract and is present at the start of a renovation?
Has the EPA considered the cost of collateral damage due to the construction of dust containment systems?
Why is there no mention of using air-scrubbers to capture dust?

Customer Protection

2006-03-18T20:49:00.000-08:00

As previously discussed OSHA concerns itself with worker protection while EPA concerns itself with protecting the public. In the remodeling business the public is the customer or occupants. Concern for protection of occupants of housing units where remodeling activities are taking place is increasing. EPA has recently released the so called Renovation, Repair and Painting (RRP) rule. The stated goal of the rule is to ensure that no lead-based paint hazards are left behind after the completion of a remodeling project. Protecting occupants from lead dust hazards is another laudable goal; however, as with most federal regulations, the proposed RRP has its challenges. Setting those challenges aside let’s look closer at the idea of customer protection.

Anyone would agree that keeping a jobsite clean and orderly is probably a good thing. We all know what is next to Godliness. The degree to which the RRP establishes work practices to reach its stated goal goes too far for most remodeling projects. But, when looking for a model by which a remodeler can design systems for dust control, the RRP certainly fits the bill. The setting up of isolation systems or dust containment systems as spelled out in the proposed rule would certainly protect occupants on a project. That which customers are being protected from is not necessarily the potential negative health effects that may develop from exposure to the hazardous dust from a remodeling project which was already present in the house before the project was even started, but rather protection against customer dissatisfaction.

Customer satisfaction is directly linked to how well the remodeler keeps their project neat and clean. In the July 2005 issue of Qualified Remodeler results of their customer satisfaction survey found that there is a direct relationship between keeping a jobsite clean and the level of customer satisfaction. Customers were more the twice as satisfied on those projects that were kept tidy than those projects that were not.

So, when looking at dust control in remodeling, one must work through the regulatory issues with focus on the satisfaction of their customers. Protecting this satisfaction is best accomplished by paying close attention to how well the job site is kept clean.

Worker Protection

2006-02-16T11:12:00.000-08:00

Project Scope: Kitchen Replacement in a 1950’s house.

My phone rang.

“I think we need to take off all the plaster on the walls,” said one of my workmen.

“Why?” I asked.

“It is in pretty bad shape and the electrician needs to do a lot of channeling to run wiring for the new outlets.”

I told my workman that I would be stopping by later in the day to look at the condition of the plaster and make a decision.

“Continue removing the plaster on the ceiling and let me know when you are done,” I said.

“Ok.”

“Are you wearing your respirator?” I inquired.

“Yeap.”

I arrived to the site during the clean-up phase of the ceiling tear-out. The walls were in bad shape. Definitely better to remove the plaster and backer board than attempt to channel it and repair the cut-outs. No surprises…

What was not so surprising was the mold found on and in the wall behind the sink base cabinet and the white-fibrous material wrapped around the heat ducting and water lines in the ceiling.

So, here you have it -- the worst case scenario for a Remodeler!!! EPA, OSHA , industrial hygienists and occupational health care providers would have a field day with this one. The exposure to lead, mold and asbestos is highly likely. EPA regulations are silent on worker protection, but worker protection is the reason OSHA exists.

The Occupational Safety Act of 1970, which created OSHA, specifically states the following laudable goal: “To assure safe and healthful working conditions for working men and women.”

Sounds simple, but in practice most remodelers do not take the necessary precautions to ensure their workers are at a minimum complying with the regulations specific to dust control or maximize profitability by implementing comprehensive dust control policies, procedures and systems. I think remodelers keep their head in the sand on this issue as opposed to addressing it head on out of shear lack of understanding and a preference for maintaining the status quo. Granted, reading government regulations is as about as exciting as sanding drywall mud, but nonetheless as important as any other requirement imposed on small business in this day and age.

It is unreasonable to expect to be in full compliance. The regulatory agencies and more importantly, the enforcement agencies realize that the vast majority of remodeling companies cannot fully comply. It is however, reasonable to expect remodelers to gain some baseline understanding and move in the direction of better dust control for the sake of protecting your workers.

Points of Contact

2006-01-29T11:19:00.000-08:00

Biological Points of Contact--

The points at which foreign bodies or particulates are ingested or somehow enter our body cavity and how such exposure effects us physiologically, physically or neurologically.

The Bends: as nitrogen precipitates from your blood as you ascend towards the surface of water, bubbles will form in your blood stream and travel to your heart and cause death or become trapped in your joints and accelerate arthritis.

Male Subfertility: a male exposed to lead who produces sperm with the incorrect proteins on the head of the sperm or misshaped head which without the aid of Artificial Reproductive Technologies would not penetrate the lining of the egg.

Asbestosis: inhalation of air-borne fibers of asbestos in such concentrations that fibers become trapped against the lining of the lungs, infects the areas, mucus grows to such a large area that the lung stops working.

Mold: inhaling mold spores that become trapped in the sinus cavities and causes an allergy attack.

Remodeling Remodeling Points of Contact--

The points at which people interact with building components that contain or cover potentially hazardous materials.

Have you ever removed a toilet? Have you had opportunity to scrap the old wax-ring from the flange and catch a wiff of the smell from the soil pipe? How about removed a sink-base cabinet in a poorly maintained house? Witnessed the plums of dust generated during removal of carpet originally installed in 1958? Replaced framing rotted by water due to improper window flashing? How about cut high-density particle-board without proper breathing protection?

Done this and more and thought nothing of it? Taken in comparison with the great many issues facing modern-humans, health effects from poor air-quality is not a real barn-burner -- unless you suffer from it.

I assert, as do all other indoor air-quality advocates, that we need to increase awareness to these Points of Contact and improve implementation of procedures to better control exposure to workers and to occupants.

Why care about dust on remodeling projects?

2006-01-28T06:46:00.000-08:00

How many ways can this be answered?

Anyone have allergies? Asthmatic? Sensitive to off-gasing of VOC's? Immune to exposure to lead or asbestos? Truly like drywall dust buggers? Wonder why their skin was irritated after building their deck last weekend? Like spending days cleaning dust off of every horizontal surface in their home after their basement was built out?

These are just some of the issues I have seen during my years in remodeling. Since a young boy, I have been exposed to lead, asbestos, mold, vermiculite, arsenic, silica, cement, lime, fiberglass, cellulose, formaldehyde, ammonia, pet dander, human dander and the list goes on and on and on. Recently, I have noticed definite physical symptoms after exposure to contact-adhesive, paint thinner, acetone, new carpet, vinyl-flooring, solid-surface adhesive and many other chemicals used on current day remodeling projects. The number of man-made products combined with the number of naturally occurring substances that are ingested during remodeling is startling.

The reason to care about dust in remodeling is simple: minimize unnecessary discomfort and health hazards to workers and occupants. This should be a no brainer. But, as we go forward designing the dust Control program we will discover there is more to this issue than meets the eye.

Debut

2006-01-27T07:16:00.000-08:00

Don't be left in the dust!!!!

Remodeling Dust is a blog devoted to improving the way in which remodelers in the United States address the issues associated with dust and other potentially hazardous particles found on remodeling projects.

Issues include:

Why should customers and contractors care about dust?
Points of Contact
Worker Protection
Customer Protection
Work Practices
Regulatory Compliance
Profitability
Liability Mitigation
Best Practices
Types of Dust
Health Issues Due to Exposure
Clean-Up Procedures

If you are considering a remodeling project or are a professional remodelor this is the blog for you...

We look forward to robust discussion on points of information that are due to follow.

Link to http://qx2.net for information about Dust Control consulting services.