Comment by Ed Mahoney 5 hours ago

Delete Comment

 

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....

Views: 23

Reply to This

Replies to This Discussion

I got this from the EPA's FAQs:

Question (6725)
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?
Answer
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.
Question (6739)
If I use a hammer to make a hole is a wall that is two feet on each side, does the RRP Rule apply?
Answer
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.

RSS

Videos

  • Add Videos
  • View All

Twitter

Latest Activity

Dan Antonioli replied to Dan Antonioli's discussion Net Zero Energy Hot Water
"For my particular application the heat pump heater would be integral to the tank and thus be…"
1 hour ago
Dennis Heidner replied to Dan Antonioli's discussion Net Zero Energy Hot Water
"What climate zone are you in?  Where would the hot water heater be set?  Northern…"
2 hours ago
Larry Weingarten replied to Dan Antonioli's discussion Net Zero Energy Hot Water
"Hello:  Looking for solid numbers,you might want to search "Martin Holladay solar thermal…"
2 hours ago
Profile IconGabriel Lieb, Beth Neri and Aaron Beck joined Home Energy Pros
3 hours ago
Kim Tanner posted a discussion

Game of Homes

Have you seen the new online game by EnergyLogic, Game of Homes? If not you should check it out!…See More
5 hours ago
Beth Neri liked John Gillis's discussion Tamarack Technologies Introduces First Intelligent Whole House Fan
5 hours ago
Steven Lefler replied to Dan Antonioli's discussion Net Zero Energy Hot Water
"Dan, I build "Net Zero" modular homes. I was given this company as a possible solution…"
5 hours ago
Edward Ryan replied to Quinn Korzeniecki's discussion 20-City Proof is Possible Tour Coming to a City Near You!
"The Proof is Possible Tour is fast approaching. Don't forget to visit www.proofispossible.com…"
23 hours ago

© 2016   Created by Lawrence Berkeley National Laboratory.   Powered by

Badges  |  Report an Issue  |  Terms of Service