There are a multitude of questions surrounding RRP. The training course EPA mandates is eight hours, which lacks the time for proper training of PPE and other optional methods to consider in the field. Peter Lawton, president of leadSMART Training Solutions Inc., South Berwick, Maine, addresses some of the most common complaints he has heard from contractors.
Complaint: Working in hot humid conditions, wearing Tyvek suits and respirators is intolerable.
Response: Consider using a negative air machine at your next jobsite. Negative air machines are designed to filter air and can be used when following lead-safe work practices. They can also be used to set negative or positive pressure isolation rooms, useful for containing airborne contaminants like dirt, dust, drywall dust, sawdust, molds and other hazardous materials.
Complaint: Rubber gloves often fail.
Response: Wear canvas gloves over the rubber gloves.
Complaint: Respirators are difficult to work in.
Response: Find a respirator that is comfortable for you. Although testing shows the N100 to be useful, any abatement contractor would steer you away from these. There are many choices, such as 3M’s 6500 line, which is lightweight, easy to fit and reusable (with proper care). These respirators cost around $50 and you should easily get a year’s use before wear and tear take their toll. The replacement cartridges cost approximately $15, and you would most likely get three to five days use out of them during a heavy demolition. Most of the time, the proper use of a negative air machine along with engineering control systems, such as use of water, minimizes if not eliminates the need for respirator use.
Complaint: Non-permeable suits are difficult to wear.
Response: It is a myth you must wear non-permeable suits when performing RRP work. Wearing of suits has nothing to do with preventing lead poisoning to the typical remodeler working in a residential property. The wearing of suits is one method to prevent the worker from taking lead dust home and exposing others to the lead dust. Here are some options you have to prevent carrying lead dust with you off of a jobsite:
- Provide non-permeable (Tyvek or others) suits to your employees. You must thoroughly provide detailed training about fitting techniques and decontamination procedures, as well as look for warnings of workers’ hydration levels, etc. You must follow all of OSHA's requirements for worker safety when you issue any sort of PPE. This means you must have washing stations, for example. In addition, you must think about the following: What are you doing at the end of the day with your work boots if they were not covered? Are you healthy enough to work in these suits? Does your doctor agree?
- Provide washable clothing for a worker to change into daily at the site. You must have a changing station and retain laundering receipts to prove you are providing the required laundering. You also must have washing stations.
- Consider using engineering controls, like working wet, or mechanical engineering controls, such as negative air machines. Become competent in air monitoring and maintain your own crew database to be able to prove that by working smart your methods produce a working environment that results in lead exposures below 30 mg/m3 (the OSHA action level). Therefore, you are able to safely work in your regular work clothes. You must train your crew about how to successfully decontaminate before getting into their trucks and going home.
The most important point is to avoid lead from entering your nose or mouth. The type of lead we encounter in homes can only poison us when it enters our body through these two orifices. Anything above that deals with transferring the lead dust out of the contaminated zone into others, such as your truck, home or any other place you go. It is against the law to wear any "hot" PPE outside of the work zone; you become a walking toxic distribution center. The third option is the least invasive and most effective. It only seems like a lot to do upfront. However, if you truly take all the steps in any option listed above, this third option will prove to be the most effective while being compliant and letting your crew work as it is accustomed.
- Lead In Construction: OSHA 1926.62
- Respiratory Protection: OSHA 1910.134
- Air Monitoring OSHA Technical Manual (OTM) Section II Chapter 1
- Proper Use of PPE OSHA 1910.132
Complaint: Plastic bags rip and don’t hold the contents from demolition.
Response: Use typical demo bags used for asbestos and other hazardous material jobs.
Do you have questions you’d like answered that weren’t addressed in your RRP certification training class? Email them to firstname.lastname@example.org and we’ll address them in an upcoming newsletter.