1. Follow work practice standards EPA RRP rules 

• RRP work must be performed by a certified renovator or trained staff being supervised by a certified renovator. Following the RRP Rule see 40 CRF 745

2. Occupant education 

• The Renovate Right pamphlet must be distributed to own­ers and occupants of buildings where lead safe renovations will occur before work begins see 40 CFR 745.84

3. Occupant protection 

• Renovator must post signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area. 

• To the extent practicable, these signs must be in the primary language of the occupants. 

• These signs must be posted before beginning the renovation and must remain in place and readable until the renovation and the post-renovation cleaning verification have been completed. see 40 CFR 745.85(a)(1) 

4. Containing the work area 

• Before beginning the renovation, the firm must isolate the work area so that no dust or debris leaves the work area while the renovation is being performed. 

• The firm must maintain the integrity of the containment by ensuring that any plastic or other impermeable materials are not torn or displaced, and taking any other steps necessary to ensure that no dust or debris leaves the work area while the renovation is being performed. 

• The firm must also ensure that containment is installed in such a manner that it does not interfere with occupant and worker egress in an emergency. see 40 CFR 745.85(a)(2)

5. Interior containment 

• Steps 5a-5d are specific to interior RRP work. see 40 CFR 745.85(a)(2)(i) 

5a. Remove objects from work area 

• Remove all objects from the work area, including furniture, rugs, and window coverings, or cover them with plastic sheeting or other impermeable material with all seams and edges taped or otherwise sealed. see 40 CFR 745.85(a)(2)(i)(A)

5b. Close and cover all duct openings 

• Close and cover all duct openings in the work area with taped-down plastic sheeting or other impermeable material. see 40 CFR 745.85(a)(2)(i)(B) 

5c. Close windows and doors in the work area 

• Doors must be covered with plastic sheeting or other impermeable material. 

• Doors used as an entrance to the work area must be covered with plastic sheeting or other impermeable material in a manner that allows workers to pass through while confining dust and debris to the work area. see 40 CFR 745.85(a)(2)(i)(C) 

5d. Cover floor surfaces 

• Cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust, whichever is greater. 

• Floor containment measures may stop at the edge of the vertical barrier when using a vertical containment system consisting of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls. see 40 CFR 745.85(a)(2)(i)(D)

6. Exterior containment 

• Steps 6a -6d are specific to exterior RRP work. see 40 CFR 745.85(a)(2)(ii)

6a. Close all doors and windows 

• Close all doors and windows within 20 feet of the renovation. On multi-story buildings, close all doors and windows within 20 feet of the renovation on the same floor as the renovation, and close all doors and windows on all floors below that are the same horizontal distance from the renovation. see 40 CFR 745.85(a)(2)(ii)(A)

6b. Doors used during work 

• Ensure that doors within the work area that will be used while the job is being performed are covered with plastic sheeting or other impermeable material in a manner that allows workers to pass through while confining dust and debris to the work area. see 40 CFR 745.85(a)(2)(ii)(B)

6c. Cover the ground with plastic sheeting 

• Cover the ground with plastic sheeting or other disposable impermeable material extending 10 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to collect falling paint debris, whichever is greater, unless the property line prevents 10 feet of such ground covering. 

• Ground containment measures may stop at the edge of the vertical barrier when using a vertical containment system.see 40 CFR 745.85(a)(2)(ii)(C)

6d. Containment within 10 feet of property line 

• If the renovation will affect surfaces within 10 feet of the property line, the renovation firm must erect vertical containment or equivalent extra precautions in containing the work area to ensure that dust and debris from the renovation does not contaminate adjacent buildings or migrate to adjacent properties. 

• Vertical containment or equivalent extra precautions in containing the work area may also be necessary in other situations in order to prevent contamination of other buildings, other areas of the property, or adjacent buildings or properties. see 40 CFR 745.85(a)(2)(ii)(D)

7. Photo Documentation 

• Photo documentation of all LSW work locations shall be included in the client file. This documentation must include photos of the containment systems prior to com­mencement of work per WPN 17‐ 7. 

8. Check before exiting containment 

• Use precautions to ensure that all personnel, tools, and other items, including the exteriors of containers of waste, are free of dust and debris before leaving the work area. see 40 CFR 745.85(a)(2)(i)(E)

9. Waste from RRP work 

• All RRP waste materials shall be placed in 6 mil or better plastic bags that are goose-neck seal with tape. All RRP waste will be transported off site and disposed of as household waste. This material is not a hazardous mate­rial. 

10. Cleaning the work area 

• After the renovation has been completed, the firm must clean the work area until no dust, debris or residue remains. 

11. Collect all paint chips and debris 

• Collect all paint chips and debris without dispersing any of it, seal this material in a heavy-duty bag. 

12. Remove the protective sheeting. 

• Mist the sheeting before folding it, fold the dirty side inward, and either tape shut to seal or seal in heavy-duty bags. Sheeting used to isolate contaminated rooms from non-contaminated rooms must remain in place until after the cleaning and removal of other sheeting. Dispose of the sheeting as waste. 

13. Additional cleaning 

• The firm must clean all objects and surfaces in the work area and within 2 feet of the work area in the following manner, cleaning from higher to lower

14. Walls

• Clean walls starting at the ceiling and working down to the floor by either vacuuming with a HEPA vacuum or wiping with a damp cloth. 

15. Vacuum surfaces. 

• Thoroughly vacuum all remaining surfaces and objects in the work area, including furniture and fixtures, with a HEPA vacuum. 

• The HEPA vacuum must be equipped with a beater bar when vacuuming carpets and rugs. 

16. Remaining surfaces 

• Wipe all remaining surfaces and objects in the work area, except for carpeted or upholstered surfaces, with a damp cloth. 

• Mop uncarpeted floors thoroughly, using a mopping method that keeps the wash water separate from the rinse water, such as the 2-bucket mopping method, or using a wet mopping system. 

17. Post-renovation cleaning verification 

• A certified renovator must perform a visual inspection to determine whether dust, debris or residue is still present. 

• If dust, debris or residue is present, these conditions must be removed by re-cleaning and another visual inspection must be performed 

18. Verify that each windowsill in the work area has been adequately cleaned 

• (1) Wipe the windowsill with a wet disposable cleaning cloth that is damp to the touch. If the cloth matches or is lighter than the cleaning verification card, the windowsill has been adequately cleaned.

• (2) If the cloth does not match and is darker than the cleaning verification card, re-clean the windowsill as directed in paragraphs (a)(5)(ii)(B) and (a)(5)(ii)(C) of this section, then either use a new cloth or fold the used cloth in such a way that an unused surface is exposed, and wipe the surface again. If the cloth matches or is lighter than the cleaning verification card, that windowsill has been adequately cleaned.

• (3) If the cloth does not match and is darker than the cleaning verification card, wait for 1 hour or until the surface has dried completely, whichever is longer.

• (4)After waiting for the windowsill to dry, wipe the windowsill with a dry disposable cleaning cloth. After this wipe, the windowsill has been adequately cleaned. 

19. Verify that uncarpeted floors and countertops in the work area have been adequately cleaned 

• (B) Wipe uncarpeted floors and countertops within the work area with a wet disposable cleaning cloth. Floors must be wiped using an application device with a long handle and a head to which the cloth is attached. The cloth must remain damp at all times while it is being used to wipe the surface for post-renovation cleaning verification. If the surface within the work area is greater than 40 square feet, the surface within the work area must be divided into roughly equal sections that are each less than 40 square feet. Wipe each such section separately with a new wet disposable cleaning cloth. If the cloth used to wipe each section of the surface within the work area matches the cleaning verification card, the surface has been adequately cleaned.

• (1) If the cloth used to wipe a particular surface section does not match the cleaning verification card, re-clean that section of the surface as directed in paragraphs (a)(5)(ii)(B) and (a)(5)(ii)(C) of this section, then use a new wet disposable cleaning cloth to wipe that section again. If the cloth matches the cleaning verification card, that section of the surface has been adequately cleaned.

• (2) If the cloth used to wipe a particular surface section does not match the cleaning verification card after the surface has been re-cleaned, wait for 1 hour or until the entire surface within the work area has dried completely, whichever is longer.

• (3) After waiting for the entire surface within the work area to dry, wipe each section of the surface that has not yet achieved post-renovation cleaning verification with a dry disposable cleaning cloth. After this wipe, that section of the surface has been adequately cleaned. 

20. Remove warning signs 

• When the work area passes the post-renovation cleaning verification, remove the warning signs. 

21. These 6 activities are prohibited when conducting RRP work 

• NEVER ‐ reuse material used as protective containment Sheeting

• NEVER – dry sweep using brooms.

• NEVER – use a conventional shop vacuum with HEPA fil­ters – only HEPA designed vacuums are acceptable for RRP.

• NEVER ‐ turn leaded paint into leaded dust by dry scrap­ing or sanding.

• NEVER – use machine/power sanders, grinders, abrasive blasting, or sandblasting without HEPA vacuum attach­ments (shroud).

• NEVER ‐ use an open flame torch or heat gun (above 1100°F) to remove paint or window glazing. 

22. Documentation 

• Documentation will be done using Attachment #28 LSW Declaration. This documentation must also include a copy of the certified renovator's licence.