Chem Scope Inc. has been offering the EPA’s version of lead training, The Renovation Repair and Painting (RRP) class, since October of 2009 and has taught RRP to around 4,000 unique students. For the majority of our RRP students it’s often apparent that the class is their first formal introduction to any regulation with regards to lead. The rough translation….. most of our RRP students have not previously taken OSHA’s Lead Awareness training and hence have little idea what OSHA’s Lead in Construction Standard (29 CFR 1926.62) requires. Both OSHA and the EPA require training for workers. There is some overlap of content between the trainings but it’s minimal. The OSHA training is less time consuming (3-4 hours vs. 8-9 hours) and proportionally less expensive and yet at Chem Scope the RRP students are outpacing Lead Awareness students by almost 50-1 over the last 4 years.
The EPA’s primary focus under the RRP regulation is to protect the occupants of the residence and more specifically to reduce or eliminate childhood lead poisoning. RRP students are given information as to the health effects from lead exposure and the EPA dutifully recommends the workers protect
themselves through the use of respirators, protective clothing and washing stations ect. OSHA goes beyond recommending – they require. Employee protection is what they do. The OSHA Lead in Construction standard is very encompassing but the intention here is not to pull out every detail of the OSHA regulation. Instead we’re going to highlight just a few items that, when mentioned to past RRP classes, seem to wake students up to the fact that they are not as close to OSHA compliance as they thought.
OSHA 1926.62 (Lead)applies to all construction work where an employee may be occupationally exposed to lead (not just lead in paints). Construction work is defined as work for construction, alteration and/or repair, including painting and decorating. Note that OSHA does not differentiate between lead-based paint and lead-containing paint though other agencies do.
Among other things under 1926.62, OSHA requires the employer to conduct air sampling on employees who are disturbing lead containing paints so that personal exposure levels can be established. All employees with potential exposure to lead need to be trained before that exposure to:
1. The possible health effects related to contact with lead and
2. Safe handling and use, including the correct personal protective equipment and proper hygiene practices
OSHA requires respirators to be worn during the initial exposure monitoring. The type of respirator is dependent on the work methods. As a side note to respirator use, medical permission, fit testing and training are annual requirements for those employees whose job requires them to wear a respirator. Once exposure levels to lead are established the numbers are compared to two different airborne concentrations in the OSHA standard, the Action Level (AL) and the Permissible Exposure Level (PEL). The AL is described as a yellow light and the PEL as a red light. The Action Level is set at 30 micrograms of lead per cubic meter of air (ug/m3); the Permissible Exposure Level is 50 ug/m3.
If the sampling determines that employee exposures will be at or above the AL, and this is exposure without regard to using a respirator, the employer needs to provide:
· Training to the contents of 1926.62 and its appendices
· Respirators are to be made available upon employee request
· Biological monitoring made available in the form of blood sampling and analysis for lead
If lead exposures are shown to be at or above the PEL then respirator use shifts from an employee option to mandatory use. Further requirements also kick in at the PEL including additional air monitoring and enforcement of proper protective clothing, signage, housekeeping, and washing facilities.
The final item to touch on here is what OSHA calls Methods of Compliance (1926.62(e)). The primary means for reducing employee exposure to the permissible limit is supposed to be through engineering and work practice controls. The use of respirators is only meant as a secondary means. To this end OSHA writes, and I’m paraphrasing below starting from 1926.62(e)(2)(i):
[ Prior to commencement of the job each employer shall establish and implement a written compliance program to achieve compliance with the permissible exposure limit. Written plans for these compliance programs shall include at least the following: A description of each activity in which lead is emitted; e.g. equipment used, material involved, controls in place, and a description of the specific means that will be employed to achieve compliance. ]
Broadly stated, RRP training can be summed up as this is how we set-up a work area to keep lead-dust in (and non-workers out), and this is how we properly clean the area at the end of the job. For OSHA, the summary is simply to keep the workers working by keeping the lead out of the worker. The irony of the situation is that the class the students haven’t been taking, OSHA’s Lead Awareness, is the one that’s designed to protect them as workers. The threat of heavy fines under the RRP rule has brought a lot of contractors into the classroom for an education on lead. Education is a good thing and maybe it will lead more workers to balance the RRP training out with Lead Awareness training, the training designed to protect the worker.
Brian Santos, Chem Scope Inc.