Here we go again! Remember 2010 when you were told to get RRP trained or face an EPA fine of $37,500 per violation per day?
Now that 2010 certification is about to expire in Mass. The state is sending out reminders to get retrained and renew the license. I spoke with the DLS last week and they tell me they are not extending the date to July like the EPA is doing in other states. So looks it is time to get your RRP renewal training. If you let it lapse you are not suppose to work on pre-1978 housing.
Numerous Changes To The RRP Law Since 2010; Especially in Massachusetts
A lot has changed since 2010 in Massachusetts and with the main RRP Law. For starters the State of Massachusetts applied to the EPA to administer and enforce the law locally. On 7/9/2010 Mass officially was given delegated authority by the EPA to take over the RRP Law. In true Mass fashion the state, instead of just adopting the law straight up, decided to make it much more stringent than the EPA regulation. Mass changed RRP defintions and more.
In fact the Mass RRP Law is the toughest in the United States of America. The biggest reason is they added the
OSHA Lead in Construction, OSHA Respiratory and Medical Monitoring requirements in the general statute. Contractors with employees are required to comply with these OSHA standards and protect their workers.
In addition the EPA has had several amendments adding to the regulation. In recent refresher trainings most students were not aware of these numerous changes. Things like pulmonary function testing before you wear a respirator, base line blood lead testing, medical and respiratory written plans, respiratory fit testing and all the OSHA record keeping that goes with it...whew!
When is the last time you looked at your RRP Manual?
In recent RRP Refresher classes I asked students when is the last time you referred to your EPA RRP Manual...the answers were from a private training done for a large company and from some of our open enrollment sessions...
Here are some of the answers....
- What manual?
- I haven't looked at it since the class 5 years ago
- I through it away when I left the class
- It is still collecting dust in my office
- I burnt it
- I can't remember
- I read it when I got visited by the RRP police
- My last pre-1978 job
- I let my kid use it for a coloring book
- Last week...I review every time I have a pre-1978 job
