Is Low Level Exposure To Lead A Big Deal? Here is Your Answer…
Before you decide to use the RRP Opt Out if/when it comes back, consider the information below. Will you, your clients, their kids and your employees be at risk if you do not use lead-safe work practices?
While the toxicity associated with exposure to high levels of lead was recognized by the ancient Greeks and Romans, the adverse health effects associated with low-level lead exposure only became widely recognized in the second half of the 20th century. Over the past 40 years, epidemiological studies, particularly in children, continue to provide evidence of health effects at lower and lower blood lead levels.
The National Toxicology Program (NTP) concludes that there is sufficientevidence for adverse health effects in children and adults at blood Pb levels below 10μg/dL and below 5μg/dL as well. The table below provides a summary of effect by life stage at which the effect is identified.
Note: This information was found in a document published by NTP titled:
RRP Training Refresher: Defining Work Area Containment
It’s probably been a while since you took your RRP Certified Renovator Training Class. This blog post is offered as a refresher topic to help you keep important details about the RRP rule top of mind when selling, estimating or performing RRP renovations.
Refresher: Defining Work Area Containment
What is Containment?
“Containment” is what is required under the RRP Rule to prevent dust and debris from spreading beyond the work area to non-work areas. In general, there are many degrees of containment, ranging from simple plastic sheeting on the floor surrounding a small work area to a fully enclosed space. Some types of containment are more effective than other types.
Why is Containment Required?
Containment is required by the RRP Rule because it reduces the risk to you and residents. Following the work area setup requirements will protect you, your co-workers and residents by confining lead-contained dust and debris to a defined and demarcated area. Confining the lead is an important consideration in avoiding exposure. Reducing the risk to you and co-workers is also dependent upon use of personal protective equipment. Requirements for the personal protection of workers are established by OSHA and can be found in the OSHA document titled “Lead in Construction”
Proper containment also facilitates efficient cleaning of the work area. The pre-work setup process is essential to keeping lead-contaminated dust confined to the work area where it can be easily cleaned. Proper containment of the work area helps to limit the area you need to clean after the job is complete. Knowing exactly where to clean is an important factor in saving time (and money) spent on cleanup.
Controlling dust and debris may require more extensive containment than is specified in the rule if the job is particularly dusty. For example, small areas of ceiling work can spread dust over the entire room and are very difficult to control.
Containing the Work Area Includes:
Removing objects and furniture from the work area, or covering them with plastic sheeting.
Covering floors (or the ground) with plastic sheeting a minimum distance beyond the surfaces being renovated (6 feet for interior jobs and 10 feet for exterior jobs).
Vertical containment is required for any exterior renovation within 10 feet of the property line.
Larger areas of disposable plastic sheeting may also be necessary to prevent the spread of dust.
Smaller areas of containment may be used if additional precautions such as vertical containment are used to stop the spread of dust and minimize the area of cleanup.
Closing windows and doors, and using plastic sheeting to seal doors and air ducts in the work area.
Covering doors used to enter the work area with plastic sheeting in a manner that allows workers to pass through but contains dust and debris within the work area.
Guest Blogger: Peter Lawton had his first lead safe training in 1997 while operating his design/build remodeling firm designPLUS in the greater Boston area. Today he is the founder and senior principle trainer for LeadSMART Training Solutions which trains contractors in areas of lead remodeling and OSHA safety standards. His classes are held throughout New England as well as occasionally on the west coast as well. Peter can be reached at firstname.lastname@example.org or visit his training schedule at www.leadsmarttraining.com .
Opt Out..... Weighing In
Both sides of this issue have valid points to consider. Before we make rash decisions have we looked at the entire picture? We can do better than our politicians, but we must think before we act.
Isn't it a bit odd that months before an election some politician comes out of the woodwork and puts forth this bill? Where was this senator a year ago? How much research and thought went into addressing the bigger picture? Are we being used again as pawns by tapping our emotions and not our intelligence for votes? Do you really feel this is all that stands between you and having enough work?
Here are a few questions/comments I believe this bill ignores:
Whether the Opt Out comes back or not, what about the employees of the firms who intend on using this option? Did anyone ask those who are actually doing the work how they feel about their health risks? Will they have a voice without retaliation?
Is OSHA going to come up with a "you must protect your workers’ health UNLESS the customer gave you permission to work unprotected" clause? My bet is OSHA will stand firm on 1926.62 (Lead in Construction). In fact, if you have employees, EPA is irrelevant with whatever they decide to do.
How about extending the OPT OUT to state that the homeowner releases his or her civil right to sue the contractor should anything go wrong?
For those of you who think this is all BS, how about signing a waiver that says my tax dollars won’t be used to pay for related health care for you, your family, your workers or your clients who might get sick due to the work you perform?
If any of you perform HUD work, do you really feel they will buckle from their standards?
Anything that can improve our economy is worth looking at. I am not sure this is the answer everyone has been looking for – can’t we come up with a better solution than Bill #S 2148?
I believe this law can create marketing and positioning opportunities to those who see it this way and in the process, keeps everyone safe – and for those who see it differently, it’s obviously a never ending source of complaints which has divided our industry at a time when we need each others’ back more than ever.
Peter Lawton, President, LeadSMART Training Solutions
Guest Blog: RRP Demolition and Asbestos Removal Share Similar Risks and Work Practices
Guest Blogger: Rachel Gilner is an Outreach Coordinator for Asbestos.com. She specializes in asbestos awareness, education, and safety issues within the online community. You can follow the organization on Facebook and Twitter for the latest asbestos and mesothelioma updates.
RRP Demolition and Asbestos Removal Share Similar Risks and Work Practices
In 2008 the EPA began forcing contractors to abide by the RRP Rule regarding lead and its health hazard. As noted in the rule, certification is required when working with homes built prior to 1978, which is also the same time period asbestos was commonly used in building homes. Like lead, asbestos is an extreme health risk for contractors and homeowners. Since asbestos removal is not required by law it often goes unnoticed by contractors. Asbestos is the leading cause of mesothelioma, a rare cancer in the lining of the lungs.
If There’s Lead, There’s Probably Asbestos
The EPA created the RRP Rule because lead is found in many products in homes. Asbestos was also used frequently in homes in similar products such as paint, floor tiles, roofing tiles, and water pipes. It is safe to assume that where lead is present, asbestos is also near. Asbestos is only a serious health hazard when it is disturbed, which means during renovations the fibers may be set airborne and inhaled by workers.
Best Practices for Asbestos are Similar to Lead
According to the RRP Rule workers are required to remain up-to-date on training and lead-safe work practices. Although the only current laws regarding asbestos removal are for abatement companies and not contractors, safe handling is still important all around. Here are some good rules of thumb:
Assume asbestos is present if you are working with an older home if it has not been tested by the owners
Post warning signs around the area containing asbestos
Wear a HEPA certified protective face mask to avoid inhaling asbestos dust fibers
Wet down asbestos particles you may see to avoid them from becoming airborne
Change your clothes before returning home and keep work clothes away from family members
Protecting Your Workers
Although asbestos is not included in the RRP Rule, companies should still be concerned about the health and well-being of their workers. Workers are protected under OSHA, and have the right to a safe workplace. The law requires employers to provide their employees with safe working conditions. It would be in the best interest of employers to be aware of lead or asbestos on the premises. If a proper test has not been performed you should always assume lead or asbestos is present until it is proven otherwise
For additional information on Asbestos visit Asbestos.com. If you think you may have been exposed to asbestos and would like to speak with someone directly our advocates can be reached directly at 800-815-7924.
On Sunday April 24, 2011 I read an article in the Boston Sunday Globe by Erica Noonan titled Back to the Garden. The article was about the Victory Gardens in Belmont MA. Noonan did a great job describing the history of gardens, who uses them, how people decorate them and what people are growing in them ranging from flowers to food. What caught my eye was a picture of an old wooden window sash used to decorate one of the gardens. I instantly suspected the sash could contain lead paint and if so, could cause serious health concerns. On Monday afternoon I stopped by the Gardens to check it out. The video below tells the story.
As you can see from the video gardeners are definitely bringing lead paint into the gardens. As the paint breaks down due to age and exposure to the elements the lead dust and chips are falling and/or are being washed by the rain onto the ground contaminating the soil being used by the gardeners. In addition to window sashes I also found and tested several gates, boards and doors that also contained lead paint.
I suggest gardeners everywhere need to be aware of the risks they take on when using old painted materials in their gardens. Of course it is best to not bring items containing lead or lead paint into your garden, but unfortunately someone else may have already done so in the past. Also, if you plant a garden next to the walls of an older home, it is best to assume the soil is contaminated with lead. Years of peeling, scraping, sanding and repainting of the siding on a home can drop lead chips and dust onto the soils around your home. Without testing you will never know if the soil has been contaminated.
On a web site by the name of BelmontPatch.com one of the gardeners, Marilyn Decource, commented about the gardens: It's wonderful, she said, to have the community garden plot so close to her home where she can come a few hours to tend her plants every other day. "It's good to be able to eat something organic. You really can't get vegetables this good at a grocery store." Perhaps part of her success in the plot is that she doesn't use pesticides or fertilizer but does sprinkle a layer of compost over the entire garden, Decourcey said. This year, she added a layer of manure to the soil.
Marilyn might want to do a little research about gardening in lead contaminated soils before assuming her vegetables are safe to eat. Click here to learn about the signs of lead poisoning.
To be safe, gardeners should do their own research if they suspect their garden may contain lead. Here is some information I found at the Cornell University website about gardening in lead contaminated soils: When gardening in lead contaminated soils, safety measures should be taken.
Wear gloves, or wash hands thoroughly after gardening and especially before eating, and be sure small children do not eat garden soil. Gardeners can bring lead-contaminated soil into the house on shoes and clothes, increasing levels of lead soil and dust in the home. This is especially a concern for crawling toddlers and infants. Remember that children tend to be at a greater risk of lead exposure from soils when the soil is directly taken into the body.
Plants may absorb some of the lead present in soil through their roots. Any lead that is absorbed tends to concentrate in leaves and the outer part of roots, so peel root crops such as beets, carrots, turnips, and radishes before eating.
Grow vegetables that produce edible fruits such as tomato, peppers, cucumber, squash, etc. Lead absorption into plants does not concentrate in the fruits.
If your soil has a lead contamination problem, grow fewer edible fruits and vegetables and more flowers, trees and shrubs.
Like construction workers who are exposed to lead in the course of their work, Gardeners should also consider that their skin and their clothes may become contaminated. Always wash your hands immediately after gardening and definitely before eating, drinking or smoking to avoid ingesting lead dust. To reduce the risk of bringing lead contaminated soil into the home, rinse and launder gardening clothing promptly. Being educated about the dangers of lead and ways to protect yourself as well as your family can help make sure you’re not growing a lead problem in your garden.
If you would like more information about the Belmont Victory Gardens click here, or contact Conservation Commission Agent Mary Trudeau in the Office of Community Development at 617-993-2667 or email@example.com
While 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.
So, 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.
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...
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.
As like many of you, I have definitely exposed my body to lead over the last 30 plus years I have been involved in remodeling. As I learn more about lead poisoning and the symptoms of lead poisoning, I flash back to my younger years working for my dad’s remodeling business. Back then there was little awareness or thought given to the way we worked when disturbing lead paint. One summer I remember complaining of stomach aches, muscle pains and constantly feeling tired even after having the weekend off. My parents took me to the doctor but the doctor couldn’t find any reason for these symptoms. He gave me a terrible tasting medication to take daily and asked me to report back on how I was doing. The symptoms would seem to come and go all summer long, but then went away when I went back to college after the summer was over. This same scenario played over again the following summer.
Later I found out from my parents that the doctor had told them my symptoms were psychosomatic. He made this decision because the medication he gave me was only a placebo but I was reporting improved health. Looking back what was actually happening was that I was moving in and out of exposure to lead as I was moved from one project to the next. If I gutted a kitchen and remodeled it I would get sick and the symptoms would appear. After completing that project I might move to an addition or attic renovation project where I would have little or no exposure to lead. My symptoms would come and go as I moved from project to project and as my body had time to adjust.
Fortunately for me, in the early days of owning my remodeling business, I learned a lot about lead and lead safe work practices through the NARI/HUD Lead Safe Remodeler training program that came out in the mid 1990’s. The current Certified Renovator training is only one day and really only teaches attendees how to contain the dust and debris. Different than the current class, the NARI/HUD class was two days long and actually thought us lead-safe work practices that eliminated or significantly reduced the creation of lead dust and debris. Attending that class was definitely worth the investment of time and money. Both I and my employees changed the way we thought about the work we did and the methods we used going forward.
Lead poisoning is a serious concern, often confused with other illnesses:
Workers can be exposed to lead by breathing in lead dust or fumes from work activities, by eating, drinking or smoking in work areas, or by handling contaminated objects - and accidentally swallowing lead dust. Workers in many workplaces have so much lead in their bodies that they are slowly being poisoned. The symptoms may hardly be noticeable at first. But over time, lead can damage the brain, blood, nerves, kidneys and reproductive organs. This damage can cause serious disability: memory loss, extreme tiredness, emotional problems, even kidney failure, coma or death.
Lead poisoning can occur when people are exposed to large or small amounts of lead over time. Lead builds up in the body and may cause temporary or permanent damage. A blood lead test can show whether your body has absorbed a dangerous amount of lead. A high blood lead level is an indication that lead is building up in the body faster than it can be eliminated.
There are many symptoms or signs that suggest a problem with lead, but they can also be symptoms of other illnesses. It is also possible to have lead poisoning without noticing any symptoms. If you work around lead you should regularly see your doctor, whether or not you are experiencing the following symptoms:
Early Signs and Symptoms of Lead Poisoning:
Irritability or nervousness
Later Signs and Symptoms:
Aches or pains in stomach
Muscle and joint pains
Weak wrists or ankles
Note: The Photo above shows wrist-drop in adult with lead poisoning and renal failure.
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.
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.
Delegated States Likely Better Prepared To Enforce EPA RRP Rule
Several states around the country have assumed administration and enforcement of the EPA RRP rule and others are also thinking of doing the same. EPA actually offers money for the states to use to investigate the practicality of doing so. As this happens each state must create its own rule which is at least as strict as the EPA rule in order to get approval to do so from the EPA. This will lead to confusion for many renovators.
Variances in the rule requirements, from the EPA RRP rule and also from state to state, will make it difficult for renovators to understand the differences and keep up with amendments made by each entity. Renovators working in more than one state many have to become certified firms in each state they operate in and or also with the EPA. Are renovators better off if their states write a better thought out rule? Would renovators be better served if there was just one well written rule for everyone to follow? I predict that confusion may likely contribute to violations and fines for these renovators.
In July of this year Massachusetts took over administration and enforcement of the RRP rule. The Massachusetts Regulations, written by the Massachusetts Department of Occupational Safety (DOS), include many of the OSHA related considerations left out of the EPA RRP rule and the EPA required certified renovator training. As a result, Massachusetts contractors are quickly becoming aware of the already existing OSHA considerations related to working with lead. For example, the Massachusetts firm licensing application includes a requirement that a written respiratory protection and worker health and safety program evidencing compliance with the Massachusetts RRP rule and OSHA medical monitoring requirements be submitted with the application. This will force businesses to have such a program in place before they can be licensed to do RRP work. The requirement will also serve to dictate what the business must have in place should they be inspected by either the DOS or OSHA. I predict the need for OSHA related training will increase dramatically as contractors become aware of violations and fines levied against their peers.
The MA DOS has also started conducting on-site inspections. Though most inspections are triggered by citizens reporting suspected violations, the DOS is also out in the field and is stopping by renovation projects as they come across them. In one of his recent blogs, RRP certification training provider and business coach, Mark Paskell of The Contractor Coaching Partnership, shares a real life story of a painter who was visited by DOS after a neighbor next door to one of his projects called the DOS with concerns about soil contamination. The contractor was in compliance and made out fine, but the DOS left him with a message and asked that he would share it with others. "Tell every contractor you know we're out there enforcing. Tell your friends, your neighbors, other contractors you know, suppliers and trades. We are here and we will enforce the new law"
NOTE: EPA has authorized nine states to administer their own RRP programs: Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah and Wisconsin.
I just wanted to say thank you for your efforts to keep us informed.
"Thank you again for the hundreth time for keeping a vigil on this business nightmare. Your site is one of the best resources we have to stay on level ground"
"I am quite impressed with all the confusion out there at Shawn McCadden’s clear and concise voice that continues to help contractors and those involved in this industry truly understand the rule. His efforts should be applauded."
Christopher Wagner, LBPFiles
"RRPedia is an accurate and contractor friendly interpretation of the very complex and confusing EPA RRP rule"
"Thanks for taking the time to write the blog. It's about the only place one can go to get some serious info on this dreadful subject"
"I would like to begin by thanking Shawn for all of his postings and education that he has been sharing with the remodeling industry. He has personally been extremely helpful in guiding me through various interpretations of the RRP rule, his advice and knowledge are priceless."
Michael A. Mahoney
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"Hi Shawn, Nice RRP write up on the website. I've already forwarded a link to it to a number of local builder types."
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