My firm removes and replaces windows from the exterior of a building or residence. To contain dust in the work area, we cover the entire interior surface of the window with impermeable plastic sheeting and affix the sheeting to the surrounding interior wall. This creates a pocket, accessible only from the exterior, from which the window is removed and replaced. All removal and replacement work is performed from the exterior, and we still apply the exterior containment measures as provided in the Rule. Does the interior containment method described meet the requirements under the Rule?
No. Although EPA encourages your firm to continue to use this method of supplemental containment, the minimum requirements of the RRP rule must still be met. Specifically, the floor surface must be covered with taped down plastic sheeting or other impermeable material 6 feet the perimeter of the work surface, or a distance sufficient to contain the dust, whichever is greater. Alternatively, your firm can install vertical containment measures as described more fully in FQ 23002-23786.