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EPA RRP New Vertical Containment Requirement

  
  
  
  

The EPA just released the new RRP curriculum. In this slide they are showing the new Vertical Containment required when working on a wall within 10 feet of a property line. This picture shows a one story home. Two and three story homes will be much more challenging, especially due to the new focus on fall protection from OSHA. OSHA mandates that contractors use guard rails, safety nets and or fall arrest systems when 6 feet above lower levels. It will be interesting to see how contractors handle higher elevations. Painters using ladders may need to consider using pipe staging or pumps.

The subscript with the slide is below the picture.

Vertical Containment 10.11

What is vertical containment?

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.

Is vertical containment required for interior jobs?

No, the use of vertical containment is not required for interior jobs, but you can minimize the amount of floor containment needed by making use of vertical containment for interior projects.  Floor containment measures may stop at the edge of the vertical barrier when using a vertical containment system consisting of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls.

Is vertical containment required for exterior jobs?

Yes, vertical containment, or an equivalent system of containing the work area, is required for exterior jobs where the property line is within 10 feet of the area of paint disturbance. In addition, vertical containment can also be used to minimize the amount of ground containment needed for a project.  Ground containment measures may stop at the edge of the vertical barrier when using a vertical containment system.

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Comments

Mark, 
 
Do you have a link to the actual EPA requirement/memo?
Posted @ Monday, October 10, 2011 10:13 PM by Brad Rodgers
Here is a link to the federal register: http://www.gpo.gov/fdsys/pkg/FR-2011-08-05/pdf/2011-19417.pdf 
 
 
 
Sincerely, 
 
Andrea 
 
Andrea Goldman, Esq. 
Law Office of Andrea Goldman 
305 Walnut Street 
Newton, MA 02460 
T: 617-467-3072 
F: 617-467-3074 
 
www.andreagoldmanlaw.com 
 
“Massachusetts Builders Blog”www.buildingconfidence-llc.blogspot.com 
"Home Contractor vs. Homeowner Blog" www.andreagoldmanlaw.blogspot.com 
 
Helping parties manage their businesses and resolve disputes in construction  
and other industries through litigation, arbitration and mediation. 
Posted @ Monday, October 17, 2011 8:51 AM by Andrea Goldman
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