Respirators: Recommendation or Requirement? has presented a couple of stories over the last few weeks detailing the relationship between HUD, OSHA and EPA in the RRP debate, and the jurisdiction of OSHA in the use of Lead Safe Practices.

To recap ... the procedures for Lead-Safe practices were developed by HUD to protect the residents of buildings containing lead-based paint, and OSHA developed the rules governing the protection of employees exposed to toxic substances in the workplace. EPA developed the training and certification procedures to bring HUD procedures, through qualified and trained workers, to the renovation, repair and painting segment of contracting. Thus RRP.

While being trained, all renovators go through the task of putting on the booties, gloves, suit, mask, cap and other gear – all in the name of personal protection. In fact the training manual and class, in Module 5, there is a section called “Protect Yourself”, and it covers what protective gear EPA recommends workers should wear, and the personal hygiene they should practice to clean off lead dust, etc. At the end, mention is made of OSHA perhaps requiring more stringent rules for protection.

This has raised the question – What is the EPA’s position on personal protective equipment versus OSHA’s?

Referencing question (23002-15698) of the EPA’s FAQ’s:

Q: Does the RRP rule require people working on a renovation to wear respirators, Tyvek(R) suits or other
personal protective equipment (PPE)?

A: The EPA would like to clarify the requirements for personal protective equipment:  The Occupational Safety and Health Administration (OSHA) has requirements for personal protective equipment, EPA does not.  For many years, EPA has recommended the use of personal protective equipment as a way to protect workers and to help ensure that leaded dust and debris does not leave renovation or abatement work sites.  EPA recommends that renovators make use of the minimum respiratory protection recommended by the National Institute of Occupational Safety and Health (NIOSH) for environments where lead is present, but respiratory protection is not required by the EPA regulations.  In addition, disposable clothing, if removed and disposed of before the workers leave the work site, can provide additional protection for workers' families by ensuring that no leaded dust or debris is carried home on worker clothing.  However, EPA does not require this and allows renovators to use other methods to ensure that dust and debris does not leave the work area, including the HEPA vacuuming of clothing, tools, and other items before they leave the work area."

There’s an informative booklet from HUD that offers great information on personal protection gear. Respiratory protection is vital, because it helps prevent workers from breathing harmful amounts of lead and other substances, touching their mouths with dusty hands, or inhaling paint dust.

Employers must meet the requirements of the OSHA Lead in Construction Standard (29 CFR 1926.62). These requirements include respiratory protection when work creates lead dust in air that exceeds the “permissible lead exposure limit” (PEL) of 50 µg/m3.

Respirators may be required for activities that generate high levels of dust such as: demolishing painted surfaces, opening up wall and ceiling cavities, using power tools on painted surfaces, dry scraping large painted areas, or replacing windows and doors.

For any of this type of work, OSHA requirements include the following:
• Training workers on how to properly use and maintain respirators.
• Making sure proper respirators are always available and that workers have been fit tested. Where respirator use is required, workers must be part of a written respiratory protection program that meets OSHA standards (29 CFR 1910.134).

Many types of respirators can be used. Disposable respirators can be used if they are rated by NIOSH as N100 (or HEPA). This information can be found on the respirator’s package or the respirator itself.  You can use non-disposable respirators, also rated by NIOSH as N100, and they often have replaceable cartridges and require regular maintenance.

OSHA Requires Worker Training
Training must be provided to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary. This training should include at a minimum:

  • Why the respirator is necessary and how improper fit, use, or maintenance can compromise its protective effect
  • Limitations and capabilities of the respirator
  • Effective use in emergency situations
  • How to inspect, put on and remove, use and check the seals
  • Maintenance and storage
  • Recognition of medical signs and symptoms that may limit or prevent effective use
  • General requirements of OSHA's respirator standard, 29 CFR 1910.134

All respiratory protection must meet NIOSH Testing standards (National Institute for Occupational Health). They will be marked with NIOSH designations like P100, N95 or the like.