Work Practice Standards

• Occupant Protection

  1. Does the rule to close and seal doors and windows within 20 feet apply in a high-rise building?

  2. Is the work of replacing windows in a condominium considered work in a common area?

• Containing the Work Area

  1. At what point is the wind too strong to allow work to continue?

  2. Can I reuse the plastic sheeting on the same day after I mist and HEPA vacuum the plastic sheeting?

  3. Can landscaping fabric or a similar material be used during exterior power washing?

  4. Can my firm fold up the plastic sheeting used for containment at night and re-use it the next day?

  5. Can’t I just clean the floor at the end of the job?

  6. Do I need to cover a closet door with plastic?

  7. Does only damaged area need to be contained when fixing the lumber under roof?

  8. Does the door need to be covered if it is outside the work area but used by workers?

  9. Does the RRP rule require people working on a renovation to wear personal protective equipments?

  10. How can I use plastic sheeting in exterior renovations without creating a safety hazard?

  11. If I paint without disturbing the surface of the existing paint, can I use a tarp instead of six mil plastic?

  12. Is both interior and exterior containment required for an exterior window removal?

  13. Is the plant, however large, need to be covered during exterior containment?

  14. Is the plant, however large, need to be covered during exterior containment?

  15. Must the plastic be "sealed" to the floor on all edges or just "secured or held" to the floor?

  16. My firm removes and replaces windows from the exterior of a building or residence. To contain dust in the work area, we cover the entire interior surface of the window with impermeable plastic sheeting and affix the sheeting to the surrounding interior wall. This creates a pocket, accessible only from the exterior, from which the window is removed and replaced. All removal and replacement work is performed from the exterior, and we still apply the exterior containment measures as provided in the Rule. Does the interior containment method described meet the requirements under the Rule?

  17. My firm replaces windows. Various obstacles make it difficult to set up the ten-foot exterior ground containment in a way that would enable our renovators to perform the work and still effectively contain dust. In these cases, we lay the ground containment, but also use vertical containment measures to completely enclose the area in which we work. Is this a permissible method of exterior containment? If the vertical containment is set up at a distance of less than ten feet from the work surface, must we still extend the ground containment beyond the vertical barrier to meet the ten-foot requirement?

  18. What are the requirements for covering doorways used to access the work area?

  19. What if any additional liabilities exist if a owner independently removes the protective barriers?

  20. What is the “work area?”

  21. What mil plastic is considered impermeable?

  22. What to do if it begins to rain during work and what do we do with the water on plastic?

  23. When I replace windows, I set up interior vertical containment barriers that extend from floor to ceiling and completely enclose the interior area in which I physically work. If these barriers are set up at a distance less than six feet from the perimeter of the work surface, must I still extend the containment on the floor beyond the vertical barrier to meet the six-foot requirement?

  24. When must scaffolding and vertical shrouding be used on an exterior renovation?

  25. When replacing window in a 90-year old home, should I install plastic on the roof under the windows?

• Restricted Practices

  1. How do RRP requirements apply to pressure washing? What preparations are required?

  2. Is drilling holes in sheet rock to dry it out a prohibited practice?

• Renovation Waste

  1. Can non-certified workers transport debris off site under the RRP Rule?

  2. How should lead-containing wastes from RRP renovations be handled and disposed?

  3. Under the RRP Rule, how should I dispose of contaminated water used in two-bucket mopping?

  4. What type of container is adequate for on-site storage of debris? Where it should be placed?

  5. Why are gloves, which are exposed to large amounts of lead dust, not required to be disposed?

  6. Why are gloves, which are exposed to large amounts of lead dust, not required to be disposed?

• Work Area Cleaning

  1. Are components removed from the home to be cleaned up subject to the waste handling requirements?

  2. Can uncertified workers do the balance of the project after successful cleaning verification?

  3. For cleaning the work area, is the interior floor of a garage considered interior or exterior?

  4. How should I proceed to replace the window in pre-1978 home containing lead based paint?

  5. How should the waste removed from the work area be stored?

  6. Under the RRP Rule,do paint chips and debris need to be removed from protective sheeting?

  7. What should I look for when purchasing a HEPA vacuum?

  8. Who is responsible for controlling dust once the truck used to transport the waste leaves the site?

• Cleaning Verification

  1. Under the RRP Rule, is composite sampling acceptable for clearance in lieu of cleaning verification?