At a recent safety workshop held in Waltham, Mass on 9/17/2010 it was learned that the EPA, DOS and OSHA are going to work together to insure companies comply with regulations of both RRP and OSHA. It was reported that if an EPA or DOS RRP inspector discovers OSHA violations that they would report it to the local OSHA office. Conversely OSHA will do the same reciprocally.

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.