Conflicts between OSHA and EPA/HUD Lead Safety for Renovation, Repair, and Painting Training

This presentation will demonstrate the inadequacies of the new EPA/HUD lead safe work practices for achieving OSHA compliance for worker safety. These inadequacies result in OSHA violations and worker exposures when contractors disturb lead-based paint in residential and child occupied facilities.

The EPA/HUD Lead-based Paint Renovation, Repair, and Painting (RRP) Program is a federal regulatory program affecting contractors, property managers, and others who disturb lead-based paint in targeted housing and child occupied facilities. Targeting housing includes residential housing, apartments, and child-occupied facilities such as schools, day-care centers built prior to 1978 where children under 6 reside.

In April 22, 2010, firms that disturb lead-based paint in child occupied facilities must obtain certification and train their employees in lead safe work practices. Activities covered by this requirement include remodeling and repair/maintenance work, electrical work, plumbing, painting, carpentry and window replacement. The worker training must be conducted by a certified renovator who attends an 8-hour EPA/HUD training program.

The training is designed to teach lead safe work practices to those workers who disturb lead-based paint in pre-1978 residential and child occupied facilities. This training has been provided to several hundred thousand workers. Unfortunately, the EPA/HUD RRP certification training does not cover OSHA requirements that require mandatory work practices and use of PPE when lead painted surfaces are disturbed. OSHA has requirements for worker protection including exposure assessments on workers exposed to airborne lead dust/fumes and requirements for respirators and other personal protective equipment which are ignored in the EPA RRP training.