18 Lead, Asbestos, and Regulated Materials in Renovation
29 CFR 1926.62 (lead); 29 CFR 1926.1101 (asbestos); EPA RRP Rule, 40 CFR Part 745
Much of our renovation and adaptive-reuse work involves buildings that may contain lead-based paint (pre-1978) or asbestos-containing materials. Before disturbing existing finishes or materials:
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Pre-1978 residential and child-occupied buildings: renovations that disturb painted surfaces beyond de minimis amounts must follow the EPA Renovation, Repair and Painting (RRP) Rule — firm certification, a certified renovator on site, lead-safe work practices, containment, and cleaning verification
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Suspect asbestos-containing materials (pipe insulation, floor tile, mastics, plaster, roofing) are presumed positive until sampled by a licensed inspector; abatement is performed only by licensed abatement contractors under Illinois Department of Public Health requirements
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OSHA exposure assessments and protective measures per 1926.62 and 1926.1101 whenever employees may disturb lead or asbestos
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Mold, bird/rodent droppings, and other biological hazards evaluated before demolition or crawl-space work; PPE and controls assigned by the JHA
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Demolition work is planned under 29 CFR 1926 Subpart T, including a pre-demolition engineering survey