Over the past month we have been inundated with requests from contractors seeking information on the differences in the Mass RRP Law. Hundreds of contractors were trained on the EPA RRP Law before 7/9/2010 when Mass was delegated to enforce and administer the law.
Last April we asked our instructors to fore worn RRP students that Mass was taking over the law and there would be changes. Since July we have sent out numerous emails to keep our students up to date. However many contractors say they are unaware, forgot about it or ignored the information and now are scurrying to get their credentials in line for the spring. For example many were instructed that they would need to apply to certify their firm right away to become compliant. We are finding that only 1 out of 7 have done so. Now they must pay 375 for the Mass license. Many have still not purchased their hepa vac, haven't set up documentation and other required practices. Many who know about the changes have not put in place the mandated written safety and respirator plans needed to get the Mass lead license.
Adding to this challenge we are told that most contractors trained before 7/9/2010 do not even know that the DOS has taken over the law. They surely are not aware of the Mass differences.
We are mounting a campaign to bring all contractors up to date as soon as possible so they can avoid being fined by the DOS. The outreach from the DOS and training providers has not been sufficient to spread the word.
Here is a quick summary of additional Mass requirements for those who are not up to date or are unsure of the changes.
Program is managed by the Executive Office of Labor and Workforce Development's Division of Occupational Safety
- Entities working in their own facilities, with their own employees, may apply for a waiver so that they need not obtain a separate license as a Lead-Safe Renovation Contractor. Documentation is necessary. Waiver expires in 5 years
- Entities who were EPA-certified prior to 7/9/10 may apply for a waiver so that they do not have to pay the MA fee. MA fee must be paid when EPA certification expires
- De leading contractors need not receive a separate license as a Lead-Safe Renovation Contractor
- Must provide additional documentation about company, (e.g., list of employees, proof of workers comp insurance)
- Must affirm compliance with Mass tax laws, DOR, DUS and FSC.
- Must provide proof that a Medical Monitoring program is in place
- Must provide proof that a Respirator Protection program is in place
- Certified Firm fee: $375 for 5 years
- Mass Lead Safe Renovation License applied for after 7/9/2010 is only good in Massachusetts, not EPA regualted states.
- Training course covers basic respirator and personal protection training elements and Mass differences.
- Lead-Safe Renovator Supervisor must be on site the entire time that RRP work is in progress
- Must maintain a log outside the containment area and have all workers sign in and out each time they enter or leave the work area.
- Change in terms; Certified Firm is called Lead Safe Renovation Contractor, Certified Renovator is called Lead Safe Renovation Supervisor.
- May use tarpaulins to cover plants and ground on exterior projects
- Tarps must satisfy the requirements for covering plants and ground [454 CMR 22.11 (9)(e)2]
- Tarps may only be reused after thorough decontaminated using HEPA-vacuum or wet cleaning Tarps shall not subsequently used for interior renovation work in Target Housing or Child-Occupied Facilities
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