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POSTED 09/07/2011

In a recent RRP certification class Jeff had a question I needed to research and would like to share with all of you.

1. Can a Sawzall, without a HEPA vac attachment (not possible), be used to remove metal sash windows? YES, especially under the new rule clarification just out in 8/5/11. The official Register now says “The use of machines designed to remove paint through high speed operation such as sanding, grinding, power planning, needle gun, abrasive blasting, or sanding blasting, is prohibited on painted surfaces unless such machines have shrouds or containment systems and are equipped with a HEPA vacuum attachment to collect dust and debris at the point of generation. Machines must be operated so that no visible dust or release of air occurs outside the shroud or containment system.”
2. What if you have over 220lbs of components (windows and french doors), does it fall under toxic waste? NO, not if it’s residential. YES, If commercial and it falls under the child occupied dwelling designation.

The PDCA continues to be the standard and information bearer of the coatings industry. And I am glad to be of assistance with any RRP questions. Let us know how we can serve. Hope to see you at the next local Chapter meeting www.pdcaz.org .

Renovate well!

Randy Fornoff
EPA LRRP Training Manager PDCA Central AZ Chapter #1