INTERIOR/EXTERIOR BETTER DEFINED BY EPA
On September 28, the EPA finally responded to a key question that our joint DASMA-IDA Lead Paint Task Force had submitted on May 28. The response came from Marc Edmonds, our key contact at EPA.
Our Question: For purposes of cleaning the work area following a renovation, is the interior floor of a garage considered interior or exterior space?
EPA’s 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.”
This response has also been publicly posted at the Question/Answer section of the EPA’s Web site. Go to http://toxics.custhelp.com, enter “garage” as your search term. This Q&A is the third result; the EPA’s response is “Answer ID 7205.”
February 26, 2011 at 4:07 PM
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