Hot of the press, the State of Massachusetts has made some changes to the Massachusetts RRP Lead Safe Renovation Contractor application.
On Monday at the contractor forum Shawn McCadden and I set up with the Division of Occupational Safety (DOS) we discovered that they had changed the application. The reason for the change was to simplify and make the process less confusing. The application is used for licensing sole proprietors, contractors with employees, landlords and deleaders. In addition contractors with employees must provide a written respirator and worker protection plan with their application to qualify for a Mass RRP Lead License.
Here is the new wording on the application that the DOS is hoping will clear up some of the confusion;
"IF APPLICANT HAS EMPLOYEESattach (A) and (B) listed below to this completed application:
(A) A list of employees in applicant’s present workforce and a list of employees who have worked for the applicant for any period of time during the preceding 12 months.
(B) A respiratory protection AND worker health and safety program evidencing compliance with 29 CFR 1910.134 and OSHA medical monitoring requirements. If the applicant does not have a written program, model program templates for respirator and worker protection/medical monitoring programs can be downloaded from the DOS webpage at: www.mass.gov/dos. Click on "Lead Program" link, then on "Lead Documents" link. See "Model Written Respirator" and "Model Written Medical Monitoring and Worker Protection Program" links.
IF APPLICANT HAS NO EMPLOYEES, do not attach (A) or (B) above. Instead, attach a NOTARIZED STATEMENT which clearly states, "(Applicant or Business name) has no employees." Applicant must sign and date the statement and statement must be notarized. Note that if the business acquires an employee(s) at a future date, it must have a respiratory protection and worker health and safety protection program as noted in 5B above."
The application confusion has caused a challenge for the DOS. There are currently 4100 EPA Certified Firms in Massachusetts listed on the EPA website. However there are only 1,000 listed on the Mass DOS site with 200 applications under review. I suggested to the DOS on several occasions that the application should be changed for each group that is required to become RRP certified in Massachusetts. I suggested at the DOS meeting on Monday that there would be less confusion if there were applications for the following groups;
- Sole Proprietors
- Contractors with employees
- Landlords, Non Profits, State and Federal Munincipalities
They said they would look into making some changes.
Stay tuned for more information from our contractor forum meeting on Monday. There was indications that there will be additional changes to the Mass RRP regulation. As soon as receive new facts we will let you know.
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