Kitchen Work with a Pregnant Tenant and a Toddler
A 1972 house is occupied by a pregnant tenant and her 2-year-old. The tenant wants to remain in the living room while a contractor removes lower kitchen cabinets and sands the cabinet doors with an orbital sander. The contractor also plans to strip paint from the kitchen trim with a heat gun. The kitchen window will stay open for ventilation; no plastic sheeting will be used on the floor or countertops. Workers will eat lunch at the kitchen table and use a standard shop vacuum for cleanup. No warning sign is posted, and the tenant has not received the Renovate Right pamphlet. The contractor says the job is small and the open window will carry dust outside. The certified renovator will visit only at the end to do a walk-through. The contractor is a certified firm, but the assigned renovator is not on site.
1. Identify at least five deficiencies in the planned work practices and state the correct practice for each.
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Deficiencies and corrections:
- No containment: the kitchen must be isolated with plastic sheeting on floors and countertops, and doorways and openings must be sealed to keep dust in the work area.
- Open window and uncontrolled HVAC: the window should not be used as a substitute for containment. HVAC should be shut off or isolated, and vents in the work area should be sealed.
- No warning sign: signs must be posted at entrances to the work area to keep occupants out.
- No pamphlet or acknowledgment: the tenant must receive the Renovate Right pamphlet and the firm must obtain acknowledgment, subject to the timing rules.
- Eating in the work area: workers must not eat, drink, or smoke in the work area; food and utensils must be removed or protected.
- Shop vacuum cleanup: a standard shop vacuum is not adequate; the firm must use a HEPA vacuum and wet cleaning methods.
- Dry sanding with an orbital sander: sanding must be done with a HEPA-equipped sander or wet methods, not dry sanding that spreads dust.
- Heat gun use: a heat gun may be used only below 1,100 degrees Fahrenheit and without charring or burning paint; open-flame torching is prohibited.
- Cleaning verification: the certified renovator must perform cleaning verification, not just a walk-through.
2. What must happen before the first cabinet is removed to protect the occupants and satisfy pre-renovation education?
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Before work begins, the firm must provide the Renovate Right pamphlet to the tenant. The pamphlet must be delivered no more than 60 days before the renovation and no later than 7 days before, unless the firm documents an unsuccessful attempt and follows the alternative timing rule. The firm must obtain the tenant's acknowledgment or document why it could not.
The firm must also post warning signs at the entrances to the work area, seal the kitchen from the living room, shut off or isolate HVAC, cover floors and surfaces, remove or cover food and utensils, and instruct the tenant that she and the child must stay out of the work area. The tenant may remain in the home, but she must not enter the contained kitchen. The pregnant tenant's status does not create a separate RRP relocation requirement, but it reinforces the need to prevent dust migration. Workers must be trained on the work practices before they begin.
3. The contractor says the open window makes containment unnecessary and that the heat gun is faster than a chemical stripper. Evaluate both claims under the RRP work-practice standards.
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Both claims are wrong or incomplete.
An open window does not contain dust; it can draw dust out of the work area or spread it into other rooms, depending on air movement. Containment with plastic sheeting and sealed openings is required to keep dust from migrating. Ventilation is not a substitute for containment, and the work area should not be open to the rest of the home.
A heat gun is not automatically prohibited, but it must be used below 1,100 degrees Fahrenheit and must not char or burn the paint. Open-flame burning or torching is prohibited. Chemical strippers containing methylene chloride are also prohibited. If the heat gun cannot safely strip the paint without burning it, the firm should use a permitted alternative such as wet scraping or a HEPA-equipped sander. Either way, the work area must be contained, workers must avoid spreading dust, and the certified renovator must perform cleaning verification before the kitchen is returned to the tenant.