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Steps to Safe Renovation and Repair Activities

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This section highlights precautionary measures and best work practices to follow when conducting a repair or renovation in older buildings where PCB-containing building material could be encountered or where you assume PCBs are present, but do not have an abatement planned. A building owner or contractor may be required to utilize additional safety measures based on individual building conditions.

Are you working on a renovation or repair project of a school or other building?

If so, you need to know how to work safely with potentially contaminated building materials. This section is designed to help contractors and building owners plan for renovation and repair projects that could disturb caulking and other building materials potentially contaminated with PCBs. Following the work practices discussed in this section will help reduce the exposure risk to workers and building occupants to PCBs. The suggested work practices will assist you in:

Safety Considerations: Employ Protective Measures (Interior and Exterior)

Depending on the type of building, scope of the project, and the potential volume of dust generated by the corresponding work methods, you should consider employing various protective measures. Protective measures should provide for direct personal protection of workers, protection of building users, and third parties (e.g., students, teachers, and passers-by), as well as safeguard against spreading PCB dust to other surrounding areas of the renovation project.

Comply with Occupational Protective Regulations

The Occupational Safety and Health Administration (OSHA) regulations at 29 CFR 1926.28(a) state that, "The employer is responsible for requiring the wearing of appropriate personal protective equipment in all operations where there is an exposure to hazardous conditions." Therefore, you should use suitable personal protective equipment (PPE) for dust-generating work methods.

The following generally applicable PPE should be considered:

These protective measures should be sufficient to prevent PCBs from entering your body through inhalation, oral ingestion, and/or dermal contact (absorption through exposed skin).

In addition, worker hygiene is an important protective measure. Eating, drinking, and smoking should be prohibited in the work site. For work involving significant dust generation, showers and separate changing cabins for work clothing and everyday clothing should be provided.

Communication with Building Occupants/Third Parties and Site Security

Notify Building Occupants of the Work to be Performed

When your renovation and repair project may disturb materials that are potentially hazardous, protective measures for building occupants and third parties are critical. Clear communication with all affected groups (e.g. building occupants, workers, building owners, and community members) is necessary to create a safe working environment. For example, you should continually inform the affected groups of:

photograph of do not enter sign

Keep a Secure Work Area

You should also use site security measures to prevent access of unauthorized persons to the work areas until after the final cleanup. Examples of security measures include:

Set up the Work Area to Prevent the Spread of Dust

At a minimum, consider separating work areas from non-work areas and select appropriate PPE and tools.

When working on a renovation or repair job with the potential for PCB-containing caulk and other building materials, appropriate controls should be put in place to minimize spreading dust during the renovation and/or repair activity. At a minimum, consider separating work areas from non-work areas and select appropriate PPE and tools.

Whenever potentially hazardous material is disturbed and could generate dust, the work area should be protected by constructing a containment area. Plastic sheeting can be applied to the floor, ground, or other applicable surfaces to prevent contamination of the building interior or exterior from dust generated by the work. Construct the containment area so that all dust or debris generated by the work remains within the area protected by the plastic. Placing the containment area under negative air pressure is also an effective tool. EPA also recommends the use of high-efficiency particulate air (HEPA) tools to minimize dust release. The size of the containment area and dust controls that will be used may vary depending on the size of the renovation or repair, the methods used, and the amount of dust and debris that will be generated as a result of the renovation or repair activities.

Inside the Building

The following techniques can be employed to prevent/minimize the spread of dust, which may contain PCBs, when working inside the building:

Outside the Building

When working outside the building, the following techniques can be employed to prevent/minimize the spread of dust and debris:

For locations where a containment area cannot be constructed, the following techniques should be used, as appropriate:

After you construct an effective containment area, make sure you control the spread of dust outside your work area:
photograph of work area

During the Renovation, Use Tools that Minimize the Generation of Dust and Heat

Select tools and work methods that generate the lowest possible dust volume.

Select tools and work methods that generate the lowest possible dust volume. Remember that as you scrape, drill, cut, grind, etc., you are creating dust. You can breathe in this dust while you are working, or as the dust settles, it can expose building occupants to contaminants.

If your tools or work methods produce high heat (temperatures exceeding 212°F), PCB gases may be released into the air. This increases the risk that workers or building occupants may breathe in PCB gases. More comprehensive protective measures are necessary for methods that generate moderate to heavy amounts of dust or heat.

Read additional information on tool selection and protective measures.

Leave the Work Area Clean

The work area should be left clean at the end of every day and especially at the end of the job. The area should be as free of dust and debris as possible. The following cleaning supplies, tools, and equipment you may need are available in hardware or garden supply stores:

Daily Activities

photograph of shop vacuum

On a daily basis, renovators should:

End of the Project Activities

When the job is complete, repair workers and/or renovators should:

Next page: How to Test for PCBs and Characterize Suspect Materials

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