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Your Interactive Resource for EPA RRP Information

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RRPedia has been created by Shawn McCadden to help remodelers and others affected by the New EPA Renovation Repair and Painting Rule. 

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Double Trouble for RRP Renovators: OSHA and EPA to Work Together

Posted by Shawn McCadden on Tue, Feb 07, 2012 @ 02:55 PM

Double Trouble for RRP Renovators: OSHA and EPA to Work Together

I just became aware of a recent Memorandum of Understanding between OSHA and EPA that outlines how the two separate government agencies will work together in Region One (the northeast).  The memorandum clearly explains that the purpose of working together will be to “improve and optimize the combined efforts of the parties to achieve protection of workers, the public, and/or the environment at facilities subject to EPA and/or OSHA jurisdiction”.   The memorandum was not dated, and although it had place holders for the date in the signature area, neither agency’s Regional Administrator signing the memorandum dated their signature.

EPA and OSHA working together, joint inspections

The memorandum further explains the process and framework for notification, training, consultation, and coordination between them to more effectively support the two agencies’ enforcement programs.  It specifically lists two special enforcement initiatives:

  • OSHA’s Lead in Construction standard
  • EPA’s Lead-Based Paint Renovation, Repair and Painting Rule

I found out about this memorandum at the Contractor Coaching Partnership Blog titled “Region 1 EPA and OSHA to work together on RRP/OSHA enforcement”.  In the blog Mark Paskell highlights from the memorandum some of the ways OSHA and EPA will work together.  Here is one highlight renovators will be sure to find sobering:

“EPA and OSHA may conduct joint inspections as appropriate to carry out the purposes of their respective statutory authorities. Such inspections may be coordinated in advance but may also be scheduled on an ad-hoc basis.”

RRP Violations, OSHA violations, OSHA and RRP violationsWith spring only a short time away, contractors will soon be working outdoors again in the northeast.  This will make the work they do and the work practices they use much more visible to OSHA and EPA.  Consider yourself warned and get ready.  In additional to the work practices required under RRP rules, there are plenty of OSHA regulations and requirements as well.  If you don’t have written safety plans for the work your business performs, or if you have not provided the required safety training and equipment for your workers, you might become an easy target. 

Whether guilty or not, know your rights as a business if you are visited.  As a business, if written up by a government agency, you will be considered guilty until you prove your innocence, at your own expense.   How you handle the visit can make a big difference.  See this previous RRPedia post for guidance on how to handle a request for information should either OSHA or EPA drop by to collect information or send a request your way.

Topics: OSHA Considerations, Enforcement and Inspections, OSHA - EPA Challenges, EPA Announcements

What to do if EPA Sends You a Request for RRP Information

Posted by Shawn McCadden on Sun, Feb 05, 2012 @ 06:00 AM

What to do if EPA Sends You a Request for Information

Recently I found an article written by Anne E. Viner, a principle attorney at the Chicago law firm of Much Shelist, P.C.  In her article Anne offers several practical tips for responding to governmental requests for information.  I thought her article was well written, straight forward and easy for a contractor to understand.   I got her permission to share some highlights here on RRPedia.

Anne E. Viner, Much Shelist, P.C.Anne points out that EPA Administrator Lisa was quoted to say “EPA is back on the job" and that EPA has received the largest enforcement budget in its history, making it more likely that your business will be subject to some type of investigation.
Below are some practical tips from Anne to keep in mind when your business receives a request for information from any government agency, not just from EPA regarding the RRP Rule.  (I have summarized quite a bit, click here to see her full article.)  This information should not be construed as legal advice or a legal opinion on any specific facts or circumstances.

  • Don’t respond to verbal requests:  It is important to get all requests in writing, so that all parties clearly understand the scope of the information sought and the time period covered by the request.  Without a written request, you risk being accused of failing to fully comply with a verbal request that you may have simply misunderstood. Asking the government to put its inquiry in writing is within your rights.

  • Determine if the government has authority to seek the information requested: Help with RRP Although a written request for information should specify the statutory authority for the request, don't assume that the agency actually has the cited authority.   Knowing the source of the government's authority for the request, as well as determining the applicability of the request to your business, is imperative in both limiting the scope of your response and protecting your business interests with customers and other parties that may be affected by the request.

  • Voluntary compliance versus litigation:  Your business should be aware of the pros and cons of voluntary compliance versus requiring the government to follow more formal procedures such as issuing a subpoena or filing a lawsuit. Generally, cooperation is the better course at the early stages of an investigation. On the flip side, refusing to voluntarily comply with a governmental request may subject you to higher scrutiny and or administrative penalties.  Of course, cooperation is not always an option, so understanding the risks of fighting with the government is essential at the outset.

  • Assume your company is a target and involve counsel early in the process:  Regardless of the apparent target of the government's inquiry, assume that your business is, in fact, under investigation and may be subject to fines, penalties or otherwise embroiled in a civil or criminal enforcement action.  An experienced environmental attorney can help advise your business concerning its rights and responsibilities.

  • Be honest:  As we all learned in childhood, honesty is the best policy.  Handling the request in an inappropriate manner could result in claims of obstruction of justice, interfering with investigations, or other types of administrative and civil violations.

Topics: Compliance Options, Enforcement and Inspections, Legal Considerations, OSHA - EPA Challenges

Opportunity to Discuss RRP Rule with MA and EPA Officials

Posted by Shawn McCadden on Sun, May 08, 2011 @ 06:00 AM

Opportunity to Discuss RRP Rule with MA and EPA Officials

The RRP Rule has certainly changed the game for remodelers and remodeling consumers.   I have met with EPA officials in the past to discuss challenges within the rule itself and the challenges created by EPA for those business that are abiding by the rule due to the lack of any serious enforcement to date against violators.  So far, trying to work with EPA has been very frustrating.   Little has been accomplished.  As a result, the underground economy in remodeling has grown, making it difficult for legitimate businesses to compete against it.  This is also in effect poisoning more children as home owners choose to hire non-certified workers who are not using lead-safe practices and or are doing the work themselves without the use of lead-safe practices

MA DLS SealOn the other hand, since taking over the RRP Rule in MA, working with MA state officials has been much more productive. The Massachusetts Department of Labor Standards (DLS), formally called the Massachusetts Division of Occupational Safety, under the leadership of the department's Director Heather Rowe, has been very receptive to meeting with concerned stakeholders, hearing and recognizing stakeholder's concerns, and working with stakeholders to address their concerns.  Currently, in addition to working on amendments to the RRP regulations in MA to address concerns, the DLS is also finalizing their plans to step up enforcement and compliance actions this spring as the home improvement season begins.  Is it happening as fast as we all might like, no.   However, based on budget and resource realities, I think DLS is doing a good job listening and prioritizing their efforts.

LEHA LogoAs one way to continue their efforts and interact with stakeholders, the Massachusetts Department of Labor Standards is looking for additional input from contractors and lead industry practitioners in anticipation of making amendments to the MA RRP regulations. An official from this agency will be participating in a May 18 workshop on the RRP Rule being held in Marlborough, MA sponsored by the Lead and Environmental Hazards Association (LEHA) and will be discussing the Department’s plans for revising the RRP regulations as well as the Department's enforcement efforts.

Also participating in the workshop will be a representative from the MA Department of Health's CLPPP office who will discuss the differences between deleading authorization/licensing and RRP certification, as well as a representative from the EPA Office of Pollution Prevention and Toxics - the agency responsible for EPA’s implementation of the RRP Rule. 

Joining the MA and EPA officials will be industry specialists, including myself and public agency representatives from CT, MA, RI and VT who will address:

 -  How the Prescribed Work Practices are stifling innovation, lead by Shawn McCadden  (Read this for more on this topic)
 -  Variations between RRP, Federal/State Work Practices, OSHA Worker Safety Rules
 -  Promotion and Enforcement Strategies, Including the Use of Building Permits 
 -  Delegation of the RRP Rule by New England States

If you are interested in attending the one-day workshop, go to www.rrprule.com for complete agenda, location and registration details.  I hope I will see you there.

Topics: Enforcement and Inspections, MA RRP Lead Rules, Authorized States, OSHA - EPA Challenges, Effects of the RRP Rule

What You Don’t Know About Respirators and Probably Would Rather Not Know

Posted by Shawn McCadden on Thu, Dec 16, 2010 @ 06:00 AM

What You Don’t Know About Respirators and Probably Would Rather Not Know

On December 2nd I attended an RRP/OSHA Respiratory and Worker Protection Workshop put on by The Contractor Coaching Partnership and Safety Trainers.   The workshop was really helpful for me.  It helped me tie together some of my open questions and concerns regarding OSHA requirements and compliance as they relate to RRP related work activities for employees.

Respirators for RRP workWhile at the workshop I found one thing the main instructor Darcy Cook of Safety Trainers said to be very important for contractors to be aware of.   Under the OSHA Lead in Construction Standard, contractors must assume their employees will be exposed to lead above OSHA’s established action level requiring the use of respirators until they actually conduct air monitoring testing to prove otherwise.

This means that respirators must be worn while doing RRP work until the testing is done and a written respirator plan is put in place that details when a respirator is required and when it is not.   Engineering controls can be used to limit the creation and or spread of lead dust while work is performed.  The requirement to wear the respirator or not all depends on the kind of work being done as well as how the work is performed. 

For example; the sanding of painted surfaces.  If dry hand sanding is done, a respirator will definitely be required.   If wet sanding is done a respirator may not be required.  If the sanding is being done using a sander attached to a functioning HEPA Vac that captures all sanding dust, a respirator is probably not required.   The previous sentence is qualified with “may” and “probably not” on purpose.  The only way to know if a respirator is required or not is to monitor the air for lead dust while the work is actually being performed.

The chart below is from the EPA Certified Renovator Manual.  The chart shows exposure levels of airborne leaded dust for some common renovation activities.   OSHA’s permissible exposure limit (PEL) for workers is 50 Micrograms per centimeter squared (50 µg/m3).   If exposed over the PEL, workers must wear respirators.  All three activities in the chart exceed the PEL.

 

Airborne leaded dust, OSHA PEL   

Respirator fit testing and OSHA Respirator Fit Testing RequirementsSo, under OSHA requirements, before allowing them to do RRP related work or even enter a contained work area, employees must first be sent to a physician to be sure they are healthy enough to wear a respirator. Then they must be fit tested by a professional and provided with a properly fitted respirator that protects them from worst case lead exposure scenarios based on the kind of work they do. They must also be trained how to select, use, clean and store a respirator.   And, they must wear the respirator until the air monitoring testing is done to identify when a respirator is required and when it is not depending on how the work is performed and what engineering controls are being used.

Although these OSHA requirements are not new, the majority of residential contractors are not aware of them.  Unfortunately, ignorance of the requirements will not be an excuse if OSHA inspects one of your projects and or one of your employees is poisoned by lead.   Perhaps it would have been helpful if EPA had included the above information in the required eight hour certified renovator training when showing the chart above.

 

Click here for more information about Personal Protection Equipment (PPE) required for RRP work

Click here for more about what you need to know about Respirators when doing EPA RRP work

Click here for OSHA standards for cleaning a respirator

Topics: Worker Training, OSHA Considerations, Personal Protection, Compliance Options, Work Practices, Tools and Supplies, Health Effects of Lead, OSHA - EPA Challenges, Info for Trainers

Blatant Violation of RRP Rule in Maine displayed on YouTube

Posted by Shawn McCadden on Mon, Oct 18, 2010 @ 11:43 AM

RRP Violations in Maine Captured on Video:

Blatant and Dangerous Violation of RRP Rule in Rockland Maine displayed on YouTube

The following Video was posted to YouTube on October 11th, 2010 by “reallyrural”.   The video shows RRP violations in ME at a jobsite.  It’s probably only a matter of time before we see more of these videos.  

 

 

The following information was posted to YouTube along with the video above.


83 Park Street, Rockland Maine, October 11 2010
Project started within the last week.
No EPA or HUD Lead Safe Practices slowing these guys down.
Section 8 Housing, Children under 6
There are strollers and children’s toys in the backyard covered in Lead Dust,
No steps were taken to contain the chips or dust that extends out onto the public sidewalk that is a favorite place to walk with strollers and toddlers...

No attempts of any sort of cleanup at the end of the day.

Once the Tenants start testing positive for lead poisoning this should get interesting...

RRP Violations and EPA RRP InspectionOSHA RRP Violations

Update: This is a Landlord project using his handymen.
OSHA and the Maine EPA have visited and the project is in cleanup mode. Maine EPA used emergency powers to get this going in the right direction.

They are now cleaning up using a HEPA vac.

 

-

Topics: Personal Protection, Enforcement and Inspections, Violation Reports, OSHA - EPA Challenges, Videos

RRP and OSHA Requirements; What's Wrong With This Picture?

Posted by Shawn McCadden on Sat, Oct 02, 2010 @ 08:00 AM

RRP and OSHA Requirements; What's Wrong With This Picture?

The picture below was published in a small Massachusetts news service.   I am purposely leaving out the name of the news service and this contractor.  There was no story with the picture, only a caption that gave this person's name, business name and discussed that he was "removing layers of paint from an 1800s historic house on Main Street in preparation for a fresh coat of paint".  The picture was e-mailed around between several association leaders and employees of OSHA as well as the MA Department of Occupational Safety.  The guy in the picture probably thought he had stumbled upon some free advertising....

 

There are a whole host of OSHA violations and RRP violations in this picture.  I am throwing it out there so you can use the comment section below to tell us what you see.   I am betting together we can find at least 30 seperate violations.  

 

What's wrong with this picture

If you are looking for forms and signage to help you with comply with the EPA RRP rule, I recommend you check out what The Lead Paint Forms Store has to offer.

Topics: EPA RRP for Dummies, Personal Protection, Enforcement and Inspections, Work Practices, Health Effects of Lead, OSHA - EPA Challenges

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

Posted by Shawn McCadden on Sun, Sep 26, 2010 @ 01:42 PM

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

MA SealOn 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.

RRP Instructor ManualIf 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.
  • Fall protection kitCurrent 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?    
  • Utility knife on baseboardFor 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.

 

 

Topics: Worker Training, OSHA Considerations, Enforcement and Inspections, MA RRP Updates, Health Effects of Lead, OSHA - EPA Challenges

EPA RRP Renovators May Be Blind-Sided by OSHA Requirements

Posted by Shawn McCadden on Tue, Aug 03, 2010 @ 12:39 PM

Frustrated Contractor

Renovators Intending to Comply With EPA RRP Rule May Be Blind-Sided by OSHA Requirements

The following article, written by Dick Hughes of Excellence In Safety, was forwarded to me last week by a colleague.   Dick credits his sources at the end of the article.  I also verified the accuracy of the information through one of my contacts at the Massachusetts DOS. 

 

OSHA Logo

The article lists a variety of OSHA considerations that may likely blind-side well intentioned renovators as they attempt to comply with the new EPA RRP Rule.   The RRP Rule and OSHA requirements are in conflict with each other in many ways.  One EPA contact shared with me that EPA and OSHA did not collaborate on the rule while it was being written.   This one consideration alone should raise serious doubt and concern for business owners about business liabilities and potential fines. 

OSHA and RRP ConfusionIf an EPA enforcement employee and and OSHA Field inspector show up at one of your jobsites, at the same time, there is no way you will be able to satisfy both.  I suggest this is another example of shortsighted leadership within both organizations.  It also points out the lack of knowledge and awareness our political leaders in Congress have as it relates to understanding the construction industry and overseeing the creation of regulations that affect businesses of all sizes.

The Article:
Big Compliance Problems Ahead for Worker Safety

On April 22, 2010, the Environmental Protection Agency (EPA) implemented a rule that requires contractors that are hired to perform renovation, repair and painting (RRP) projects in homes, child care facilities, and schools built before 1978 that disturb lead-based paint to be certified and follow specific work practices to prevent lead contamination. This rule is expected to impact hundreds of thousands of employers and millions of employees.

EPA is already proposing an expansion of this rule into pre-1978 commercial facilities. That change will significantly expand the scope of employers and building owners covered by this new regulation. Failure to comply with this new regulation can result in fines as high as $65,000 per violation, including a potential prison term. The EPA will enforce violations of the new regulation starting on Oct. 1, 2010.

The new EPA rule includes the following requirements:

• The new EPA regulations require “firms” that disturb more than 6 square feet of paint per room (or more that 20 square feet on the exterior) in these pre-1978 buildings to become certified with the EPA and employ certified renovators who would train workers and oversee these projects.

• Firms include contractors who are hired to perform renovation, repair and painting work where paint is disturbed in the targeted housing.

• Building owners whose maintenance staff also disturb painted surfaces in targeted housing must also be certified and use certified renovators.

• Certified firms must send a supervisor or “renovator” to an 8-hour class where they become certified to oversee work covered by the RRP rule.

Here’s the rub: The 8-hour class only covers the EPA requirements and completely ignores OSHA worker protection rules. Therefore, safety professionals might find that “Certified Firms” are violating OSHA lead regulations because they were not taught about OSHA requirements for worker protection. This is going to be a huge issue for employers whose employees are exposed to lead hazards during work covered by the new EPA RRP rule.

EPA Rule Doesn’t Fulfill OSHA Requirements
Employers and building owners should be alert to the fact that OSHA rules differ significantly from the EPA RRP regulations. OSHA lead regulations apply to any work where employees come into contact with any level of lead or lead bearing coatings. They should also note the following worker protection and/or OSHA omissions in the new EPA lead-based paint rule:

• Lead-based paint. The EPA RRP rule defines lead-based paint as containing more than 0.5 percent lead by weight. Lead coatings below this threshold are exempt from any special EPA certification, training or work practices. However, OSHA regulates lead in any amount. Therefore, many employers will believe that lead-coated surfaces below the EPA standards of 0.5 percent by weight are not regulated when in fact they may still be regulated by OSHA.

• Regulated areas.OSHA mandates under 1926.62 that employers establish “regulated areas” when lead or lead-coated surfaces are disturbed. A regulated area requires specific OSHA signage. The EPA signs required by their new RRP rule do not meet OSHA requirements for a regulated area.

• Written compliance program. OSHA regulations require a detailed compliance program listing specific requirements for employers to document. The EPA RRP rule does not have any requirements or discussion of a written compliance plan.

• Mandatory respirator use. OSHA lead regulations require monitoring for employees exposed to lead dust or fumes during work. OSHA has established three work class tasks for which certain exposures above the permissible exposure limit (PEL) must be assumed when employers fail to perform exposure monitoring. All of the work practices covered by the EPA RRP rule require employee respiratory protection under OSHA. However, the EPA required training only discusses respirator use as optional. The EPA training does not discuss OSHA regulations for a written respirator program, medical clearance, respirator training and fit testing for employees who are required to wear respirators.

• Protective clothing. OSHA lead regulations require protective clothing when work tasks disturb lead coatings (without a negative exposure assessment). OSHA requires either disposable clothing or employer laundering. The EPA RRP rule lists disposable clothing as optional and trains workers to use HEPA vacuums to clean clothing before going home. OSHA also requires employers to notify other employees or employers who would launder the contaminated clothing. The EPA RRP rules do not provide any awareness for employees who launder their own contaminated work clothing.

• Annual training. OSHA regulations require annual training when airborne levels of lead dust or fumes exceed their action level. EPA’s new RRP rule only requires training every 5 years.

• Hygiene facilities. OSHA regulations require a separate area to change from work clothing to street clothing as well as providing for hand/face washing facilities. The EPA does not address change facilities and suggests that workers wash their hands and face prior to leaving the work place.

• Medical surveillance and biological monitoring. OSHA mandates biological monitoring for employees exposed above the action level for airborne lead dust and fumes. The EPA RRP rule briefly mentions that the only way to detect lead in your blood is with a blood test and does not inform the workers of the OSHA requirement for biological monitoring.

The new EPA RRP lead-based paint rule is an important regulation for reducing the unacceptable levels of elevated lead in children’s blood in certain areas of the country. However, this huge piece of legislation has done a disservice to the millions of workers who will be impacted by lead during common renovation, repair, and painting activities in residential and child occupied facilities by ignoring mandatory worker protection requirements mandated by OSHA. Contractors and building owners must take extra steps to ensure that their workers or employees of contractors disturbing lead bearing substances in their facilities are thoroughly trained and protected in all applicable regulations; specifically OSHA worker protection rules for lead.

Thanks to:

Jeffery C. Camplin, MS, CSP is president of Camplin Environmental Services Inc., a safety and environmental consulting firm based in Rosemont, Ill. He is a licensed lead risk assessor and accredited EPA lead-based paint instructor for abatement courses and the new RRP rule training.

Useful links related to this article:
• July 21 Virtual Audioconference: EPA’s New Lead Paint Regulations Will Get You in Trouble with OSHA http://www.workplacetrainingcenter.com/Prod-2067.aspx

• EPA information on the new RRP rule for lead-based paint can be found at http://www.epa.gov/lead/pubs/toolkits.htm

• HUD information on lead safe work practices for renovation work can be found at http://www.hud.gov/offices/lead/training/rrp/rrp.cfm

• OSHA information on worker protection for employees exposed to lead-bearing substances can be found at http://www.osha.gov/SLTC/lead/construction.html


About the author:
Dick Hughes
Excellence In Safety
24 Spring Bars Road Falmouth, MA 02540
Web: www.excel-in-safety.com
capesafetyguy@aol.com
1-508-548-0866
cell: 1-617-653-4950

This article was originally published at Work Place Magazine

Topics: EPA RRP Lead Rules, Production Considerations, Worker Training, OSHA Considerations, Personal Protection, Compliance Options, Enforcement and Inspections, Legal Considerations, Work Practices, OSHA - EPA Challenges