The 1950s Porch Repaint That Became RRP Work

Why this matters

The work order said "porch: light scrape, prime, two coats, one day." The house was built in 1952. Nobody had tested the paint, and by the time the crew lead pulled up, the apprentice had already been dry scraping a column for ten minutes, with chips on the porch floor and in the shrub bed. This case is about the order of operations when a routine job turns out to be regulated work: stop the disturbance, contain and clean what was already done, test, then rebuild the plan and the price with the homeowner standing there. Each of those steps has a version that makes it worse.

First: stop the disturbance

The lead's first act was not a test. It was telling the apprentice to put the scraper down. Any pre-1978 home is presumed to carry lead paint until an EPA-recognized test kit or a certified renovator's sample says otherwise, so until a test said otherwise, those chips were lead chips. Ten minutes of dry scraping on one column base had produced:

• chips on the porch floor around the column,
• chips in the mulch of the shrub bed below the porch edge,
• dust on the apprentice's clothes and hands.

Contain what already happened. The lead roped off the front walk with warning tape and asked the homeowner to use the side door. The porch floor around the column was misted with a pump sprayer, and the chips were picked up by hand and with a HEPA vacuum and bagged. The mulch was picked over by hand, misted and its surface HEPA vacuumed. The apprentice washed his hands and face at the truck and changed into clean clothes before getting into the cab, because lead dust on work clothes goes home to whoever does the laundry.

What that cleanup could not promise. Chips on a hard porch floor can be picked up completely. Chips that fell into mulch cannot be proven gone by looking, and some had worked down between the shreds. The lead told the homeowner that plainly, picked and vacuumed the surface, and had the crew lay the ground plastic over that bed first so nothing further landed in it. Soil testing, if she wanted it, is a lead-hazard question for a certified risk assessor, not something a painting crew answers.

The worker side. OSHA's lead in construction standard, 29 CFR 1926.62, treats manual scraping of lead paint as a task presumed to expose workers above the permissible exposure limit until an exposure assessment says otherwise, in substance; check the current text. The apprentice had done it with no respirator. The lead wrote down what he had done and for how long, and the shop's lead program handled the follow-up. From that point nobody scraped without the interim protection the standard calls for.

Then: test

The lead is a certified renovator and works for a certified firm. He used an EPA-recognized test kit on three components: a railing cap, a column and the porch ceiling bead board.

• Railing cap: positive.
• Column: positive.
• Porch ceiling: positive.

A test result applies to the component tested. Had the ceiling not been tested, it would have stayed presumed lead, not cleared by the railing's result in either direction. A negative from the kit on one component would only have released that component, and only when the test was done by a certified renovator using a recognized kit.

The conversation

The homeowner had come out when she saw the warning tape.

HOMEOWNER: It was supposed to be a quick scrape. Why
  the tape and the plastic?
LEAD: The house is from 1952. Paint from before 1978
  can have lead in it, and I tested three spots on the
  porch. All three came back positive.
HOMEOWNER: It's been fine for seventy years.
LEAD: It's fine on the wall. Scraping turns it into
  chips and dust, and that's what kids and pets pick
  up. The way we scrape it is a federal rule.
HOMEOWNER: Can I just sign something and you skip it?
LEAD: No. That option was taken out of the rule
  years ago. It applies to us whatever you sign.
HOMEOWNER: So what changes?
LEAD: Plastic on the ground out ten feet past the
  porch. Front door and windows on this side stay
  shut while we work. We keep everything wet and
  scrape by hand, clean up every evening, and I
  check it all before the plastic comes up.
HOMEOWNER: How long?
LEAD: Prep goes from one day to a bit over two.
  I'll write up the change before we touch anything.

Before any further work, the homeowner received the EPA Renovate Right pamphlet and signed the acknowledgment. The pamphlet has to be delivered before the renovation begins, and the ten minutes of scraping before anyone thought of it is the reason it is now handed over at the bid in this shop, not at the porch.

Is it over the line?

Under the EPA RRP rule (40 CFR 745 Subpart E), the minor-repair exemption covers an exterior job disturbing 20 square feet or less of painted surface, and not when a prohibited practice is used. The lead measured what would actually be disturbed, not the whole porch:

• Railing caps: 24 feet of cap at about 6 inches wide, 24 times 0.5, is 12 square feet.
• Column bases: three columns peeling to about 3 feet up, each about 2 feet around, 3 times 3 times 2, is 18 square feet.
• Porch ceiling: peeling patches the lead outlined and estimated at about 10 square feet.

That is 12 plus 18 plus 10, 40 square feet, double the 20-square-foot threshold. RRP work, with containment and a post-renovation check. A state that runs its own EPA-authorized program would apply its own rule, which may be stricter.

The plan, rebuilt

Containment. Plastic on the porch floor, and on the ground 10 feet out from the porch in every direction or to the property line, taped to the foundation and the porch skirting, edges weighted. Front door and the two windows within 20 feet closed. Warning signs at the edge. Containment design and the full verification steps follow 'RRP Containment and Cleaning Verification'.

Method. Wet scraping by hand on the caps and columns, misting before each pass. Feather sanding wet with sponges. The ceiling patches scraped wet from a stepladder set on the plastic, with chips falling onto the covered floor. No heat gun, no power sander without HEPA exhaust at the shroud, nothing with a flame. The step-by-step belongs to 'How to Scrape and Feather Sand Peeling Trim on a Pre-1978 House'.

Crew protection. Respirators within the shop's respirator program, disposable coveralls, a wash station at the truck, no eating, drinking or smoking on the plastic.

Daily cleanup. Chips misted and picked up, HEPA vacuuming, waste bagged and sealed at the work area, plastic secured overnight.

The hours. The original bid carried 8 hours of prep and 8 hours of painting, 16 in all. The revised prep was containment 3 hours, wet scraping 8, feather sanding 3, daily cleanup 1 hour on each of 2 days, and the final cleanup and inspection 2, for 3 plus 8 plus 3 plus 2 plus 2, 18 hours. Painting was unchanged at 8. The job went from 16 hours to 26, and the prep alone from 8 hours to 18, a bit more than double. The change order showed those lines and was signed before the plastic went down.

What the final check found

After the last day of scraping and sanding, the lead did the post-renovation check. On an exterior job that is a visual inspection for dust, debris and residue, not the cloth-and-card verification used inside. The porch floor plastic and the ground covering were clean. The top of the porch light fixture, which hangs from the ceiling and had not been covered, carried a gray film of dust and two paint chips from the ceiling scraping directly above it.

It had been missed because the containment was planned from the ground up: the ceiling work put debris onto everything below it, including the fixture and the top rail of the screen door frame. Both were wet wiped, the wipes bagged, and the lead looked again before calling it clean. Only then was the plastic misted, folded dirty side in, bagged and removed, and the ground under it inspected. The ceiling patches, caps and columns were primed and painted after that.

The records went into the job file: the pamphlet acknowledgment, the test results by component, the renovator's checklist and the photos of the containment. The rule requires them kept for three years.

What changed in the shop

• The estimator tests or flags. Any pre-1978 house gets either a test by a certified renovator at the bid, or the bid is written as RRP work. "Light scrape" on a 1952 porch is no longer a scope line.
• The pamphlet goes out at the bid, so it is delivered before any disturbance, not after one.
• Nobody scrapes before the lead arrives on a pre-1978 house. The apprentice was doing what the work order said; the work order was what failed.
• Overhead work gets its own containment line: fixtures, door frames and anything else under a ceiling being scraped are covered or listed for wiping.

What would have changed the call

• All three tests negative, by a certified renovator with a recognized kit. Those three components would be released from RRP, and an ordinary scrape with a drop cloth would have been allowed on them. Any untested painted component would still be presumed lead.
• Only the railing caps peeling. Twelve square feet is under the exterior minor-repair threshold, so the RRP containment and verification requirements would not apply if no prohibited practice were used, though the OSHA lead standard still covers the worker scraping it.
• A house built in 1981. No presumption. The crew would still clean up chips, but none of this would be regulated.

References

• 40 CFR 745 Subpart E, EPA Renovation, Repair and Painting rule, including the pre-renovation education requirements and work practice standards
• OSHA 29 CFR 1926.62, Lead in construction
• See related: How to Scrape and Feather Sand Peeling Trim on a Pre-1978 House
• See related: RRP Containment and Cleaning Verification
• See related: Lead Paint RRP Protocol Reference