On 10/20/2010 our RRP Contractor Workshop team will be joined by OSHA expert Darcy Cook, President of Safety Trainers. The new Massachusetts Lead RRP Law requires contractors to be compliant with the OSHA Lead Standard. This includes respiratory programs, fit testing, medical monitoring and worker protection programs. Darcy will be working with The Contractor Coaching Partnership to help Massachusetts contractors with OSHA/RRP compliance.
The Contractor Coaching Partnership Blog
Five months have passed since the EPA RRP Lead Law went into effect on April 22nd, 2010. To date almost 500,000 contractors have been trained to become Certified Renovators. The 6/18/2010 extension has come and ended.
We are constantly hearing complaints from contractors about RRP and losing work to the underground economy. Unfortunately, some would rather just complain and not do anything about it. We all know that government has a history of passing regulations without enough resources for enforcement. This is clearly evident with RRP. This year we have witnessed the lack of awareness by contractors and consumers due to a sub-par advertising campaign. The EPA has acknowledged that they need to improve their efforts in this area and I know personnally that they are doing more now in New England than earlier in the year. I agree it is not enough, however whether we like it or not, it is what it is. They need help to create a level playing field.
RRP Implementation Workshops For Contractors
This afternoon the MASS DOS posted, Comparison of EPA and DOS RRP Rule Requirements. This post itemizes many of the differences between the EPA RRP Rule and the Mass Lead Rule. One huge difference is the Mass requirement that contractors (with employees)must document that a medical monitoring/respirator protection program is in place. Patricia Sutliffe of the DOS said that this is an OSHA program that has alway been required but has not been widely enforced. She added that bringing this OSHA requirement to the forefront, will aid employers in their efforts to comply with both RRP and OSHA practices and protect the health of employees.
As we begin to understand the full impact of the Mass RRP Lead law contractors will soon be faced with the decision to develop and implement Worker Protection and Medical Monitoring Requirements. In section 22.09 of the Mass RRP Law 454 CMR 22.00, OSHA standards are described. This clause calls for the medical monitoring for employees on lead projects that generate 50 micrograms of lead dust exposure over an eight hour period. Other clauses describe the need for respirator fitting, medical examinations to determine lung capacity, blood testing, air monitoring, protective clothing and more.
The new Mass RRP Lead Law effective on 7/9/2010, requires adherence to OSHA rules when performing RRP lead safe practices. The EPA RRP training program touches upon the neccessity to follow OSHA rules regarding RRP work but fails to cover these practices in sufficient detail to protect workers. RRP training covers the lead safe practices in great detail yet leaves contractors wondering what are the required OSHA practices to comply with both.
Today we received a call from a Massachusetts painting contractor in Rockport Mass., about a site visit from the Department of Occupational Safety (DOS). On 7/9/2010 the Mass DOS became the enforcer for the RRP Lead Law in the state.
RRP Training in Massachusetts is heating up again. We have had many calls from contractors after they had site visits from the DOS (Department of Safety). The DOS is out enforcing the law. They are giving warnings and letting contractors know that as of 7/9/2010 contractors must be registered with the State of Mass and trained to work on pre-1978 properties.
On Thursday the EPA announced that Hybrivet's Lead Check test kit will retain it's current recognition indefinitely. This EPA approved test kit is used in the EPA RRP training course for contractors. The EPA reviewed several test kits and deemed Lead Check was suitable for their needs. Many industry experts were anxious to see if the EPA would change the recommended kits leading to the potential that contractors would need to be retrained on a new testing product. This development should for the short term allay these fears.