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.
The Contractor Coaching Partnership Blog
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.
The recent Massachusetts takeover (7/9/2010) of the EPA RRP Lead Law is causing widespread headaches and confusion among contractors in the state. We have spoke with many lumberyards and building officials who are not aware of the changes. Many still believe that the EPA Memo of 6/18/2010, delaying enforcement of fines, is still in effect in Massachusetts. This is not the case. When Mass Department of Safety took over the law this nullified the EPA extension in the state. Currently any contractor who works on pre-1978 properties, who is not certified, is non-compliant. This change has caught many with their pants down and exposed to fines and work stoppages if they are caught. I spoke with a lumberyard today and they were under the impression that contractors have until 12/31/2010 to obtain the training. The fact is in Mass contractors must be trained now.
Today we spoke with the Mass Department of Safety (DOS) and learned that they will be providing a flier for contractors on The Mass RRP Law for all building departments in the state. These fliers are being made and laminated for distribution and placement at building permit counters. They will be displayed prominently and building departments will be asked to share this information with contractors who come in.