Comment by Ed Mahoney 5 hours ago
Does anyone know what EPA means by "Demolition"..... I am having a hard time with. If your going to demolish a wall area less than 6 sq ft, say to put in a wall sconce, would EPA say you need to be using Lead Safe work practices? I cannot find anyone willing to put that in writing, not even an email.....And I am a Certified Renovator and work for a certified firm..... Thanks....
I got this from the EPA's FAQs:
If a renovator removes less than 6 square feet of crown molding, is that considered demolition? Does it
matter whether the molding will be discarded, replaced with new molding, or reinstalled?
It depends on how the molding is removed. If a renovation activity removes or otherwise disrupts a
painted component in a way that destroys or ruins the component, the activity is a demolition.
If I use a hammer to make a hole is a wall that is two feet on each side, does the RRP Rule apply?
Yes. Although making the hole disrupts less than six square feet of painted surface, using a hammer to
make the hole is demolition of the surface, so the minor repair and maintenance exception does not
apply. Making the hole using a cut-out technique that does not destroy the section of the wall that is
removed is not demolition, and the minor repair and maintenance exception would apply.
Their Renovation Repair and Painting FAQs are available here.
From an article I did this last April on this whole mess: http://blog.sls-construction.com/2010/rrp-620-exemption-limits - the two main paragraphs that sum up the answer you are probably looking for...
As I have mentioned, in the prior article “25 Days to Go: RRP Work Practices – Clearing up some misconceptions” article, you cannot ignore the “or demolition” part. If you perform any demolition, you have just nullified the exemption. Unfortunately, the EPA did not define “demolition” anywhere in the regulation, so that also caused even more confusion. The 6/20 exclusion is basically confined to dismantling & reassembling the same components. Based on some of the EPA FAQ’s drilling holes or trimming wood you are fine. Now if you utilize a hammer to open up a hole, or remove crown molding so that is not reusable, you have tripped the demolition portion even if you fall under 6/20 portion....
Based on my reading, if the piece is being removed & you are reusing it, you are not doing demo work. However, if you toss it or are replacing it with something different – I would opt to be on the safe side and follow the RRP regulations. Is that 6’ piece of plastic worth $37,500 and a permanent black mark?
For more info on this, or other items concerning the RRP, I have a whole of articles located here - http://blog.sls-construction.com/rrp --- The one thing I will strongly urge everyone is to make sure you read the actual regulation & understand it.