OSHA Left Out Of RRP Rule Development; Just Getting Up To Speed

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OSHA Left Out Of RRP Rule Development, Just Getting Up To Speed. 

On Friday Mark Paskell and I attended a half day LEAD Hazard Awareness workshop sponsored by the MA Division of Occupational Safety and OSHA.  (Download the Power Point Presentations)  Mark and I agreed we learned quite a bit of new information related to OSHA requirements that apply to RRP related work at the workshop.  We have been working on developing training programs and workshops to help renovators become aware of and address OSHA rules.  Attending the workshop will definitely help us enhance our future offerings.

At the workshop it became obvious that OSHA and EPA didn’t collaborate on the RRP rule or the content of the required certified renovator training curriculum.  It also became obvious at the workshop on Friday that the OSHA reps in attendance were only just recently getting up to speed on the new RRP rule. When answering several attendee questions about OSHA requirements related to RRP work, I could tell the OSHA employees in the room lacked a true understanding of the required RRP work practices.  Although the RRP rule went into effect on April 22, 2010 these employees said they had only recently attended any training related to the rule.

If RRP instructors follow the EPA created instructor training manual when training renovators, they will be teaching students to do things that violate OSHA rules.  (Read more here) Will it be an adequate defense if fined by OSHA to defend what you did by referring to the content of the training manual?   It appears that the EPA attempted to cover its lack of clarity and understanding of OSHA rules in the training manual by adding this disclaimer where the manual covers the training of non-certified workers by certified renovators; “Note: OSHA rules may require employers to take further steps to protect the health of workers on the job” 

It’s always easy to find fault, but what we need is solutions.  So here are only but a few of my suggestions to EPA and OSHA:

• Rather than use fines and penalties to promote awareness and compliance, use education to help employers and employees identify and understand the health and safety risks of their professions and what laws and regulations they must comply with.  Knowing the why often makes the how easier to embrace.
• Rather than promote compliance with just mandatory reporting, paperwork and or fines, offer and require attendance at strategic training classes that not only explain what is required, but also why.  The classes could also include training on how to fill out the required reporting forms correctly.  Doing so would serve to help complying businesses who do the right things for their workers and customers, only to then get fined due to paperwork errors.
• Allow OSHA and EPA to keep the money collect in fines provided that use of this money is clearly targeted towards developing and supporting education that results in a better educated workforce, improved awareness of related health risks and reducing worker injuries and or illnesses. 
• Perhaps our industry could establish standard designations for workers who satisfactorily complete a predetermined curriculum of classes relevant to specific job duties and work environments.  This would increase the value employees bring to employers and give employers a simple and standard way to assess the knowledge and or experience of job candidates.
• Current OSHA and RRP related rules and training seems to concentrate on what not to do, without enough time and attention on the right way to do things.   With OSHA for example, fall protection rules require a business to put fall protection equipment in place and train workers when and how to use.  Great, but why not also complement it with training on methods for working safely and how to avoid putting yourself in a position to fall?    
• For RRP, the required training teaches how to contain dust and debris so it won’t spread outside the contained work area. Might renovators who follow these instructions only be increasing the health risks to workers by containing and concentrating the dust and debris in the confined work area? Wouldn’t it make sense to also train workers on lead-safe work practices that actually limit or prevent the creation of dust to begin with?  

If you have suggestions to add to this list please share them here.  If some day we have the opportunity to revise these rules and or the strategies used by our government to administer them, we will already have a collection of solutions to consider and offer.