Garage doors and RRP

Old Garage Door

I recently received my second request for clarifying the RRP rules. A Boise Idaho contractor who specializes in garage door replacement was unclear about the proper cleaning of a garage post deconstruction. Fortunately he was directed to me by a fellow NARI contractor who understands my ability to untangle these sorts of things.  Having gone to an RRP class that left him with more questions than answers he like many of us are going overboard to do proper dust protection. Within a few minutes it was clear that he was going above and beyond with vertical containment and vacuuming down studs. Not that any harm is done by that but to stay competitive, following the intent of the law is adequate. We all know however that every situation is a little different and we need guidance to make good decisions. I hope this helps clarify what is at best a difficult topic to digest.

Here is what I instructed him.

1. First do the proper paperwork and notifications, next put on PPE. Personal Protective Equipment and place proper signage.

2. Next he lays down heavy plastic that runs beneath the door and extends at least 5′ in either direction.

3. Then all he is doing is unbolting panels and removing the stops.

4. He then he wraps each individual piece in that wrap palatalized stuff is held together with.

5. After scoring the stops, he removes them and places them on the plastic.

6. Next he polices the area for paint chips that can be picked up from the area, a vacuum may help. (He is responsible for paint chips even though he did not create them) He places the chips on the plastic and wraps everything up. Viola he can remove his PPE’s and signage then install the new door with new stop.

I received confirmation from the EPA that this is the proper garage door technique and am passing on some additional helpful information from the EPA.

QUESTION: For purposes of cleaning the work area following a renovation, is the interior floor of a garage considered interior or exterior space?

The Old and the New

EPA Answer: In general, the interior floor of a garage is considered an interior space for purposes of post-renovation cleanup. EPA recognizes the fact that it may occasionally be impossible for firms to meet all of the cleaning and verification requirements under the Rule for garage floors such as those that are composed of dirt or gravel. In such a case, EPA recommends that a firm document and keep records of the specific circumstances surrounding the impossibility. A firm must also make their best effort to collect and remove all paint chips, dust, debris and residue. Furthermore, a firm must still comply with all feasible work practice standards and take precautions to ensure that the work area is properly contained

QUESTION: My firm replaces garage doors. We unbolt the door from its hardware and remove it without penetrating, scraping, or removing paint. Is this work subject to the RRP Rule?

EPA Answer: If unbolting and removing the door does not disturb a painted surface in the hinges, door, or frame, the RRP Rule does not apply.

QUESTION: My firm removes and replaces garage doors. The garage doors are typically made up of multiple panels, each of which has an exterior painted surface area of less than 20 square feet. Aggregated, the exterior painted surface area of all the panels exceeds 20 square feet. If we disturb the paint on just one of the door panels, is that activity subject to the RRP Rule?

EPA Answer: An activity that disturbs less than 20 square feet of exterior painted surface and otherwise meets the definition of minor repair and maintenance is not subject to the RRP Rule. However, the RRP Rule provides that when removing painted components, or portions of painted components, the entire surface area removed is the amount of painted surface disturbed. In this case, application of the RRP Rule is dependent on how much of the garage door your firm intends to remove and replace. If you disturb a painted surface on a single panel while removing and replacing the entire garage door (i.e., all the panels), you must aggregate the surface area of all the panels. Similarly, if you disturb a painted surface on a single panel while removing and replacing more than one panel, you must aggregate the surface area of those panels being removed to determine whether or not the RRP Rule applies. If, however, you disturb a painted surface on a single panel while removing and replacing only that panel, and the activity disturbs less than 20 square feet of exterior painted surface and otherwise meets the definition of minor repair and maintenance (e.g., not demolition or using prohibited practices), such an activity would be considered minor repair and maintenance, and therefore would not be subject to the RRP Rule.

Laurie Fay
US Environmental Protection Agency Region 10

If you enjoyed this post, please consider to leave a comment or subscribe to the feed and get future articles delivered to your feed reader.

Comments

No comments yet.

Leave a comment

(required)

(required)