The ABCs of the RRP: Overview of EPA’s New Lead Rule and Best Cleaning Practices

The ABCs of the RRPOverview of EPA’s New Lead Rule and

Best Cleaning Practices2011

Nilfisk Industrial Vacuums

Presented by Corry Luckenbach, Product Manager, Nilfisk-CFM

www.NilfiskIndustrialVacuums.com

General Info about the RRP Rule- Purpose & Target Areas of RRP Standard- Deadline Extension

Lead-Based Paint (LBP)- What is LBP?- Dangers of Exposure to LBP

Overview of EPA-certified, RRP Training Program- Quick Facts- Highlights from the RRP Training Course

“HEPA Vacs 101”- Definitions and FAQs- How to Choose a HEPA Vacuum- Recommended Nilfisk RRP Vacs

Presentation Topics


General Info about the Lead RRP Rule

The ABC’s of the RRP


• First published on April 22, 2008 under authority of Toxic Substance Control Act section 402(c)(3)

• RRP final ruling is being enforced by the Environmental Protection Agency (EPA)

• Purpose is to focus attention on activities that disturb LBP in target housing and child-occupied facilities.

Target Housing - Home or residential unit built on or before Dec 31, 1977 (some exceptions)

Child-Occupied Facilities - A pre-1978 building that meets all 3 of the following criteria: - Visited regularly by same child under 6 years old - Visits last min. of 3 hrs. each, twice per week

- Weekly visit total 6 hrs. min., annual total 60 hrs. min.


General Info about the RRP Rule

General Info about the RRP Rule

• Renovators and dust sampling technicians must be

trained and certified• Renovation Firms must be certified• Training providers must be accredited• Lead-safe work practices used during renovations• Non-certified workers must work under and be trained

on-the-job by a Certified Renovator• Renovators must educate owners/occupants

RRP Ruling Requirements:


General Info about the RRP initiative

Some Exceptions to the RRP Rule:

• Painting only (not disturbing paint surface)• Disturbing less than 6 ft2 (inside) of paint surface or

less than 30 ft2 (outside) within a 30 day period• You as the home owner complete all work yourself• Your home was built after December 31, 1977• RRP work is being donated (charity work)• Emergency renovations (cleaning is still required

at the end of project)


General Info about the RRP initiative

• Initial enforcement date was April 22, 2010

• EPA extended deadline to October 1, 2010

RRP Deadline Extension:

taken directly from EPA memo dated June 18, 2010……..

Lead-Based Paint

The ABCs of the RRP


Lead-Based Paint (LBP)

What is LBP?

Why was lead used in paint?

• Any paint or surface coatings that contain lead equal to

or in excess of 1.0 mg/cm2 or more than 0.5% by weight 1

• Paint having lead concentrations higher than 5000ppm 2

1 Lead Safety for Renovation, Repair and Painting Student Manual, EPA-740-R-09-0022 Residential Lead-Based Paint Hazard Reduction Act 1992

• pigment (yellow, white)• reduced drying time• improved flexibility and durability• enhanced appearance and shine• improved moisture resistance



Dangers of exposure to LBP

• Especially damaging to children under the age of 6 as their bodies are still developing• Lead causes nervous system damage, stunted growth and delayed development• It can cause kidney damage and can affect every organ system of the body• Lead is also dangerous to adults and can cause reproductive problems for both men and women• Lead can be tempting for children to ingest because of its sweet taste



How are painted surfaces tested?

• Swab tests• X-Ray Fluorescence (XRF) Analyzer• Paint chip sampling, followed by analysis by an

accredited laboratory


Overview of EPA-certified RRP training program

The ABC’s of the RRP


Overview of EPA-certified, RRP training program

• Approx. cost $195.00• 1 day, 8 hour session• Combination of classroom

and “hands-on” exercises• Short test at the end• Training manual (at right)

is yours to keep• Find local training

locations near you at

www.epaleadtraining.com

Quick Facts:



The RRP course will teach you:

• Why lead based paint is a problem during renovations• What the EPA / HUD regulations require of Certified

Firms and Certified Renovators• How to determine if lead-based paint affects work• How to begin work• How to set up the work area to contain dust• How to work in a lead-safe manner• How to clean the work area and verify cleanliness• How to dispose of waste safely• How to document your work



“Hands-on” highlights:

• Learn how to test paint surface using Lead Check swab

(new EPA-approved D-Lead test swab for plaster,

drywall, metal and wood, see www.esca-tech.com)• Learn how to setup work area (limit access, signage)• Practice masking techniques on doors, furniture,

windows, vents and floors• Practice cleanup and proper waste disposal technique• Perform a final wipe down to verify cleanliness• Establish containment area for exterior work



Certificate: “EPA-certified Lead Renovator”

Certificationvalid for 5 years



What the RRP training course is NOT:

• The course is not an abatement course

• It does not satisfy OSHA training requirements

• May not satisfy state, local or tribal training

requirements


HEPA Vacuums 101

The ABCs of the RRP


HEPA Vacs 101

• Minimum efficiency for a HEPA filter as defined in

MIL-STD-282 is 99.97% capture of particles down to

and including 0.3 microns

• 1 micron = “one millionth of an inch” (0.000001 inches)

• A human hair is generally between 80-100 microns

• “Certified” HEPA filters are tested (usually by the

manufacturer) to prove they meet the minimum efficiency

“HEPA” = High Efficiency Particulate Air


A laser photometer (particle scanner) is used to measure the amount of penetration

A “challenge aerosol” made up of 0.3 micron sized particles is drawn into

the filter

HEPA

HEPA Vacs 101


HEPA Vacs 101


HEPA Vacs 101

FAQs

Q: If I purchase a HEPA vacuum, is the entire vacuum certified or just the filter?

A: In most cases, only the filter is certified. As of today there are no standards in the US that require the entire vacuum cleaner to the certified. For special applications, some manufacturers will perform testing on the entire vacuum.


HEPA Vacs 101

FAQs

Q: Does the EPA certify vacuums for RRP use?

Q: Why isn’t the entire vacuum tested for HEPA efficiency?

A: The only way to verify HEPA efficiency is to test and retest. A vacuum that passes successfully one day may not pass the next (i.e. vacuum or filter could be damaged during use). Testing requires special equipment and can be very costly to perform. Without an “enforceable” standard in place, manufacturers have been slow to adopt machine testing.

A: No, the EPA does not provide certifications for vacuums.


HEPA Vacs 101

FAQs

Q: Can I add an optional HEPA filter to my existing vacuum and use it for RRP work?

Q: What other tools will I need with my HEPA vacuum to perform RRP work?

A: Low-cost, general-purpose, vacuums that have optional HEPA filters are not being recommended for RRP work. Only vacuums equipped with a HEPA filter as standard that are designed to collect toxic materials are being recommended.

A: Any carpets/rugs in the area of RRP work will have to be cleaned using a floor tool with a “beater bar.”


HEPA Vacs 101

Power Nozzle Kit• Motor-driven beater bar• Higher performance & price

Beater Bar Options

Turbo Nozzle• Air-driven beater bar (air from vac drives bar)• Lower performance & price


HEPA vacs 101

How to choose a HEPA vacuum

Start with the HEPA filter. Ask the manufacturer iffilter testing documentation is provided with the vacuum/filter or if it is available upon request?


HEPA vacs 101


What kinds of materials will you be collecting?

Different filters may be needed to collect the following:• Fine, dry powders/dust• Heavy soil• Liquids• Dry, chunky debris• Wet and dry materials at the same time• Toxic materials (lead, asbestos, mold, etc.)


HEPA vacs 101


What environment(s) are you working in?

• Residential home (want low noise level, 100% dust capture)• Outdoor jobsite (portability, long cord, big wheels, rugged)• Commercial building/factory (large areas, improved surfaces)• Hospital/Laboratory (low noise level, EMI suppression, conductive tools, HEPA filter mounted after motor)

What is the air quality in the work area (dusty, humid)?

• Choose a vacuum based on how it’s motor is cooledo “Through-flow” cooled motors are better for dry, dusty areaso “Bypass” cooled motors are better for wet collection


HEPA vacs 101


Where is the HEPA filter mounted on the vac?

Before the motor (Upstream)• Filter out hazardous materials before they enter the motor• Safer when repairing and maintaining the vac• Easier to maintain seal of HEPA while under vacuum• Most popular method used in “abatement” vacuums

After the motor (Downstream)• Most commonly used in cleanroom/pharmaceutical areas• Captures all carbon brush and motor residue• Tends to be more expensive


HEPA vacs 101


What quantity of material will you be collecting?

• Choose the right size/capacity of vacuum for the job

• Bigger is not always better (keep in mind portability, available storage space, noise level of vacuum, etc.)


HEPA vacs 101

Recommended RRP Vac: Model GD930

Lid

UpstreamHEPA

Dust Bag

Power Nozzle Outlet

. .


HEPA vacs 101

Recommended RRP Vac: Model GD10 Back

Dust bag fits inside of sack filter

UpstreamHEPA


HEPA vacs 101

Recommended RRP Vac: Eliminator models I/II

UpstreamHEPA

Synthetic DustBags available

FloatChamber(for conversionto wet collection)

Wet/DrySack Filter

Eliminator I

Eliminator II


HEPA vacs 101

Other popular Nilfisk RRP HEPA Vacs

UZ964 “Hip Vac”Dry Only

UZ934Dry Only

GWD120 Wet/DryGWD220 Wet/Dry

GWD255 Wet/DryDrum Top Vac


Questions?Email: [email protected]

Phone: 800-645-3475

The ABCs of the RRP


mailto:[email protected]

Date post:	17-Jan-2015
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The ABCs of the RRP: Overview of EPA’s New Lead Rule and Best Cleaning Practices

Technology