Aluminum siding and RRP

[dgbldr]

How do you guys interpret RRP when it comes to aluminum siding?

Let's say you have to remove all the aluminum siding from a building. It's all original with factory paint and hasn't been painted over. As far as I can see, no paint would be disturbed unless it was already flaking off. You're not sanding, scraping or anything that would get paint off the aluminum.

[Randy Bush]

Re: Aluminum siding and RRP

I would think that the bigger question should be is it pre-78. If so then the RRP rule come into play. Although I have never knowen aluminum or steel siding to have have been painted with lead paint unless it was after being installed. I submitted a question to EPA over a month ago concerning installing new steel siding over a house where you are not distrubing it and they have as of yet responded back.Personally I would think it can be removered ok , but then I am not the one you would have to answer to neither. Hopefully as time goes on these questions will become more clearer.

Randy

[dgbldr]

Re: Aluminum siding and RRP

Of course it's pre-1978, otherwise I wouldn't ask the question

How do you know aluminum and steel siding was never painted at the factory with lead paint? Where did you get that info?

[Happy Home]

Re: Aluminum siding and RRP

How about scoring into it with a utility knife / razor scraper and test it with a swab kit ?

[dgbldr]

Re: Aluminum siding and RRP

Steve, I know how to test. For reasons we discussed many times, we choose not to test and assume it contains lead.

Question is: does removal of aluminum siding boards disturb the paint? In either case (yes or no), what is the reasoning and what, if any, is EPA's position?

[rpuglisi]

Re: Aluminum siding and RRP

removing the siding would be demo unless you are going to put it back on,demo is a no no!! If your putting it back on its a grey area,i would argue that you are not disturbing the paint,but its not me doing the enforcement ...........good luck!

[Randy Bush]

Re: Aluminum siding and RRP

[QUOTE=dgbldr;543311How do you know aluminum and steel siding was never painted at the factory with lead paint? Where did you get that info?[/QUOTE]

This information would be found on the manufactures product spec sheet. And if you know the manufacture of the siding you can always contact them for the information.

Randy

In looking though EPA web site I found this

Question
Does the RRP Rule apply to factory-applied finishes, specifically furnaces? When removing a furnace with a factory-applied finish, does the renovator have to test or assume lead and use lead-safe work practices? Most furnaces exceed six square feet.
Answer
The RRP Rule applies to modifications of an existing structure, or portion of a structure, that results in the disturbance of painted surfaces. If the surface coating of the furnace is not disturbed when the furnace is removed, the RRP Rule does not apply.
Though it is not talking about siding it is talking about a factory finish.

[dgbldr]

Re: Aluminum siding and RRP

Thanks Randy, that's pretty much what I thought. If you remove something altogether, you're not disturbing the paint, so I don't see RRP applying.

rpuglisi, not sure what you mean by demo. I'm removing aluminum siding to replace it with Hardie siding. No different than replacing windows or doors or anything else.

[tom dickey]

Re: Aluminum siding and RRP

If you are putting on hardi is there no other siding than the aluminum? otherwise it may be disturbed and rrp would prevail.

[dgbldr]

Re: Aluminum siding and RRP

Yes. There is aluminum siding and no other siding. Well, actually part of the house is unpainted brick. The aluminum siding is original to this 60s house and in very good shape.

[Dean CRCNA]

Re: Aluminum siding and RRP

I think you are disturbing a painted surface and it falls under RRP, unless you can prove (inspection) that the paint doesn't have any lead.

[dgbldr]

Re: Aluminum siding and RRP

Why do you think I'm disturbing it?

[TSJHD1]

Re: Aluminum siding and RRP

If you remove something altogether, you're not disturbing the paint, so I don't see RRP applying.

I also believe you're disturbing the paint.

I'm picturing when removing the siding, that it will get bent, scratched, maybe chipped, etc. Any of that could very well result in paint flaking off the surface, which to me, is then being "disturbed."

Problem is, it's all just a bunch of opinions though. Although I'd want to err on the side of compliance, if you're bidding against someone who isn't, then they cost the job out cheaper than you, and then get the job, then what do you have? Especially if they have no issues with EPA as they are doing the job. Would make you wish you never even tried to comply in the first place!

I haven't taken the course, but I've been following a lot of the threads here, because it may affect me at some point, thus my input and interest.

Seems to me the EPA has been pretty short-sighted in many ways, one of which is by not supplying a list of words and their respective definitions. Like the word "Disturb" for example. If they simply and clearly defined the critical words, it would alleviate most of these types of questions, wouldn't it?

Tom

[Randy Bush]

Re: Aluminum siding and RRP

If the aluminum siding is in really good sharp why are they wanting to replacing it with Hardie? Personally I think that is a step backwards.Thats a whole different subject, was this siding put on like a lot of it was back in it's day with no J channel and just caulked . and are you leaving the org windows in or replacing them? I know you don't want to test , but would not this be a lot easier to do in this situation seeing how if in fact it is a factory finish it would in all likely hood test negative. If this was my job I would get the home owner to give me written permission to test. Just my thoughts right or wrong.

Randy

[Dean CRCNA]

Re: Aluminum siding and RRP

Why do you think I'm disturbing it?

1. Under the definition of "renovation", it includes "the removal of a painted surface".
2. If a renovation activity removes or otherwise disrupts a painted component in a way that destroys or ruins the component, the activity is a demolition. I think you would have a hard time removing aluminum siding, with damaging it in any way.
3. Since most likely the siding will be "modified" (bent, scratched, chipped ... etc) when removing it ... this would be another reason.

I do agree that this is a gray/vague area. I personally also err on the side of compliance when it comes to gray/vague.

On a situation like this, I too, would try to get the ok for a test swab. Only reason a owner wouldn't want this (in my opinion), is because they are worried about it showing lead.