My school district will be performing asbestos abatement in a kindergarten classroom that was built before 1978. Do the asbestos abatement workers also need to comply with the Renovation, Repair, and Painting (RRP) Rule?
Yes, if the asbestos abatement disrupts over 6 square feet of painted surface per room in an interior, or over 20 square feet of painted surface on an exterior, or involves window replacement or demolition of painted surfaces. If so, the asbestos abatement will need to be performed by a firm certified under the RRP rule. The firm will be required to assign an RRP-certified renovator to the project, and workers will need to have been trained by a certified renovator. Of course, the asbestos abatement must be designed and conducted by persons accredited in accordance with the Model Accreditation Plan.
In addition, the asbestos abatement will need to meet the RRP Rule work practice standards as well as the standards for asbestos abatement. For each element of the job, the contractor will need to determine which standards are more stringent and comply with those standards. Typically, the asbestos abatement containment and waste handling requirements are more stringent than the RRP Rule provisions, so compliance with the asbestos requirements will also serve as compliance with the RRP requirements. However, both the asbestos air clearance and the RRP cleanup and verification requirements must be performed. Because the air clearance process is performed with the critical barriers still in place, it must be performed before RRP cleanup and verification.