OSHA & the RRP - the diffrences

[SLS-Construction]

Ok, everyone has heard it - there may be additional requirements required if you work in HUD homes or by OSHA.

Well not so fast - if you happen to live in any of these states - the OSHA regs do not apply to you, your State's OSHA program does (which can be stricter than OSHA's)

Alaska, Arizona, California, Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada,New Mexico, North Carolina, Oregon, Puerto Rico, South Carolina, Tennessee, Utah, Vermont, Virgin Islands, Virginia, Washington, Wyoming

Connecticut, New Jersey, New York also have a similar program but it applies only to public employees

The differences (Please note that some info on the EPA / HUD side is incorrect - esp. on the Initial Testing) --- info from http://www.osha.gov/dea/lookback/lead-construction-review.html

http://www.sls-construction.com/images/upload/osha1.jpg

http://www.sls-construction.com/images/upload/osha2.jpg

[JasonW]

I think one of my biggest concerns with OSHA Regs and the RRP Rule is the need to now have a Respiratory Program.

Employee's need to be checked by a doctor and employers should keep evidence that the employee is healthy enough to wear them. We'll need to have fit tests done, regular cleaning and maintenance should be documented as well. All these records need to be kept for 30 years after employment.

MEDICAL APPROVAL

Only those individuals who are medically capable to wear respiratory protective equipment shall be issued a respirator. Initially, before being issued one, an employee will receive pertinent tests to evaluate medical and physical conditions, and annually thereafter. Medical tests to be conducted by a physician often include: pulmonary function tests, a chest x-ray (if a physician deems it necessary), electrocardiogram, and any other tests needed for proper evaluation by a physician. A medical history in the form of a questionnaire is collected as well for each individual. Other factors to be considered by a physician may include: emphysema, asthma, chronic bronchitis, heart disease, anemia, hemophilia, poor eyesight, poor hearing, hernia, lack of finger or hand usage, epileptic seizures, and other factors which might inhibit the ability of an employee to wear respiratory equipment
.
EMPLOYER TRAINING PROGRAM

Each employee designated to wear a respirator must receive adequate training. The training session (initial and periodic training) should be conducted by a qualified individual to ensure that employees understand the limitations, use, and maintenance of respiratory equipment. EHSO can provide this training for you. Call us at 770-645-0788!

RESPIRATOR FITTING

One of the most important elements of an effective respirator program is fit. The OSHA Asbestos Standards (29 CFR 1910.1001/ 1926. 1 , 10 4 and the OSHA respirator standard (29 CFR 1910.134) require that the fit of respirators be determined when the respirator is issued and every six months thereafter for all negative pressure respirators. Procedures for fit-testing should be addressed in the written respirator program. A discussion of fit-testing is included elsewhere in this section.

More here: http://www.ehso.com/respprotection02.htm

These rules reference Asbestos standards frequently, but they apply to any situation where an employee is required or requests to where respirators.

[SLS-Construction]

Anyone care to say - ChaChing

7.6.2 Residential Painters - Compliance with the standard is estimated to add between $300 and $400 to any work on a pre-1978 housing unit to cover the cost of initial monitoring. If lead dust is present above the action level, but below the PEL, compliance is estimated to cost an additional $100 to $900 per job. If exposures are above the PEL, compliance cost per jobs would increase from $500 to $1,800. Costs will vary with the number of LBP jobs done and the length of the job. Costs would be lower for small jobs and higher for those that require more surface preparation.


Jason - OSHA 10 Hour Training covers the 2nd one

If you know lead is present, make sure you stay below the action limits, it won't help you on the first day when you have to wear them for the initial monitoring, but it can afterwords

Not sure but you might make the physical mandatory before hiring anyone, I have gone through a few of those before for other jobs (2 of the employers paid for it - special facility that does nothing but pre-employment physicals, 1 didn't - regular doctor with specific form required), every year afterwords or existing would be on you to pay.

[Leo G]

I guess the government is really stimulating the economy with this. Oh, except for us, they are sucking out wallets dry with it.