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2011 RRP Changes, Vertical Containment

By on August 3, 2011 in Lead Paint with 1 Comment

In July 2011, the EPA notified us that certain changes will be made to the Renovation, Repair and Painting (RRP) Rule.  One of these changes has to do with vertical containment.  The actual law wording will read like this …

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.

What they are trying to say is, that if the neighbor’s property line is within 10 feet of where you’re disturbing paint … you will need to put up vertical containment.

One of the first questions a painting contractor may ask themselves is; what is vertical containment?  The EPA has decided to also include the definition of vertical containment in the rule.

Vertical containment means a vertical barrier consisting of plastic sheeting or other impermeable material over scaffolding or a rigid frame, or an equivalent system of containing the work area.  Vertical containment is required for some exterior renovations but it may be used on any renovation.  

EPA estimated that approximately 2% of exterior jobs would use exterior containment, and the incremental cost of vertical containment varies from $330 per wall to $1,640 per wall, depending on the size of the job.

Painters I’ve talked to, think the 2% is a low figure.

The vertical containment system can be as simple as building a lean-to out of 2x4s and plastic sheeting stapled to the wood and lean it up against the gutters or roof edge on many single story family residences.  However, when you get multi-story homes or apartments, scaffolding or more complicated systems will be required.

The “equivalent system” in the language, is EPA’s way of saying that not always will putting up scaffolding be the most practical solution.  An example would be an apartment building that is basically a skyscraper.  Equivalent system will be accepted and supposedly, even encouraged.

Who knows, maybe a painter will come up with a solution and become the next Zip Wall idea.

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Dean Lovvorn
Dean Lovvorn is a Lead Based Paint Specialist working in the Dallas-Fort Worth, Texas area. He is a licensed lead inspector, EPA certified renovator and a RRP Instructor. Dean also administers a private discussion group comprised of RRP Instructors, EPA-HUD-CDC professionals, Lead Inspectors & Assessors, City-County-State Health Departments, Universities and lead organizations.
Dean Lovvorn

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  1. Jason says:

    This is such BS… Their making it harder for people to repaint their old homes. Any home within 5ft of the boundry line will never be contaminated enough to bother anyone or anything let alone 10ft… The EPA is another government corporation enforcing unrealistic laws… Same goes with the FDA, CIA, TSA… Hmmm there seems to be a common denominator to all these corporations… Your money in their pocket.

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