EPA Lead Renovation, Repair & Painting (RRP)
EPA Lead Renovation, Repair & Painting Rule (RRP)
In the construction industry, lead exposure is a serious issue that many workers face every day. Exposure to lead can occur during a variety of job activities. Lead is common in a wide range of materials including paints and other coatings, lead mortars, and base metals, which may be welded on or abrasive blasted. Lead presents a potentially serious occupational health hazard when the lead-containing particles become airborne.
Common jobs on a construction site that might expose a worker to lead include:
- Renovating or demolishing structures that have lead-painted surfaces.
- Removing lead-based paint or spray painting with lead-based paint.
- Sandblasting steel structures that are painted with lead.
- Grinding, cutting, or torching metal surfaces that are painted with lead.
- Welding, cutting, or removing pipes, joints, or ductwork that contain lead or are painted with lead.
- Lead soldering.
- Cutting or stripping lead-sheathed cable.
- Cleaning up sites where there is lead dust.
Exposure to lead occurs through breathing of lead dust, fumes, or mist and by ingestion of lead dust on cigarettes, chewing tobacco, make-up, or food.
How can worker exposure to lead be minimized?
Employers of job sites that might contain lead are required by Cal/OSHA to recognize the potential hazard. For example, painted surfaces must be presumed to contain lead until all layers of the paint are sampled and analyzed. The detection of any amount of lead in the paint will trigger numerous requirements, even for common tasks such as drywall demolition, manual paint scraping, and manual paint sanding. The employer is required to conduct air sampling to determine the exposure to lead during these tasks and during other tasks that could result in lead exposure. Until actual exposures are determined, workers are required to wear respirators that are appropriate to the task. Detailed requirements are published in the Cal-OSHA standard for lead in construction.
All workers who may be exposed to lead must be trained in the hazards of lead.
The results of air sampling are used to determine if workers are exposed to lead above the action level (AL) of 30 micrograms per cubic meter of air or above the permissible exposure limit (PEL) of 50 micrograms of lead per cubic meter of air, averaged over an 8-hour shift. Exposures above the AL or PEL will trigger additional requirements including engineering controls, proper housekeeping, washing facilities for hand and face washing, additional worker training, respiratory protection, medical monitoring, and additional air sampling. The employer must have a written compliance plan.
There are many precautions that workers can take to avoid getting overexposed:
- Use safe work practices such as wetting down paints and coatings to keep dust out of the air.
- Change clothes and wash up before eating, drinking, or smoking. Eat, drink, and smoke only in clean areas.
- Use personal protective equipment like gloves, special clothing, and a respirator.
- Make sure the respirator fits and is worn and maintained properly.
- Change clothes and wash up before going home. Lead dust on clothes or in the car could expose the family to lead.
- Children are more susceptible to lead than adults.
Lead may negatively affect the blood system, nervous system, kidneys, and reproductive organs. A worker who is exposed to lead above the action level must have a blood test to determine the amount of lead in the blood. If the blood test results indicate that the worker has been overexposed to lead, then the worker must be removed from working with lead. The employer must maintain the worker’s earnings, seniority, and benefits during medical removal.
The above evaluations and/or recommendations are for general guidance only and should not be relied upon for legal compliance purposes. They are based solely on the information provided to us and relate only to those conditions specifically discussed. We do not make any warranty, expressed or implied, that your workplace is safe or healthful or that it complies with all laws, regulations or standards.
Photo: “Hazmat” by Clement123. via Flickr. CC BY-NC-ND 2.0. https://goo.gl/CO2NtS
EPA Lead Renovation, Repair & Painting (RRP) Refresher
- Who needs EPA Lead RRP certification?
- Firms that perform renovation activities on pre-1978 homes
- Individuals that perform renovation activities
- Currently certified Lead Abatement Supervisors and Workers
- Renewals are every 5 years
Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children.
To protect against this risk, on April 22, 2008, EPA issued a rule requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning. Under the rule contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination.
With fines established at $37,500 it is important to get trained.
Non-Member Registration $395.00
SBE Member Registration $295.00
EPA Lead Renovation, Repair & Painting Rule (RRP) Refresher