full_ppe-resized-600Hey Pete, my guys won’t wear that damn stuff. Do I really have to make them wear those tyvek suits and respirators? I welcomed the interruption from Brian, a former remodeling client, as I was trying to peddle that stationary bike – another of my least liked activities my better half “suggests” I do. When someones suggests you do something – do you? All the time?

Recently I spoke with an OSHA compliant officer asking if they really were interested in lead when fall protection training seems to be the hotspot. First we focus on fall protection issues without a doubt was his answer. Then we check ladders and scaffolds for any issues. Then respirators and lead issues. Thanks Tim – I honestly felt lead was on the bottom of your list.

For Brian and many of you who wonder if these items are “suggestions” or actual regulations – this blog’s for you. I can hear my favorite musician, Neil Young singing this – well with a little twist. Okay lets dig in on this. Trust me on this guys – this one is worth reading.

I want to show you what the laws dictate regarding your crew’s requirements to wear any PPE (Personal Protection Equipment) versus the steps you might decide to take to keep them safe without any of this added inconvenience. Here are 3 steps to being a smarter contractor when it comes to PPE and lead.

First – lets clear up the reasons PPE requirements exist and what they are intended to provide.

Respirators – Remember you heard in your RRP class, you must inhale or ingest lead dust we encounter at our typical jobsites to become poisoned. Yes other types of lead can seek other paths to poison us but the type we get exposed to needs us to breathe or eat it. The obvious protection is to cover these two holes of ours that can get us sick. Shut your mouth and don’t breathe – problem solved.

Suits, gloves, booties – These have very little to do with you getting sick. They are designed to keep the poisonous dust that gets on our hands, boots and clothing on the job site where it belongs. Not in our trucks or our homes where we could bring this poison to our families or the folks at the convenience store we stop at on our way home to pick up a loaf of bread. Ever think of what you reach over when you pay the cashier at most of these places?

Is this the only way to solve the problem? No but the fact is most contractors lack the ability, equipment or desire to de-contaminate at the site. When’s the last time you saw a decontamination station or change station at your sites? The truthful answer is IF you changed your habits and decontaminated your tools and yourself all the time, you wouldn’t have to be told what to do later on. OUCH – who does that sound like?

You have just completed my 20 second lesson about What PPE is trying to achieve when lead is present.Now let’s look at what the laws say.

SECOND  – What are the various regulations we need to understand?

RRP, OSHA and HUD. Read below what they say ( I have paraphrased  these answers – go to the link provided for the actual regulation language):

RRP & PPE  EPA does not require they suggest.  EPA hasrecommended 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. Folks when you hearrecommend, are you still reading or have you moved on? EPA is speaking to the smallest of jobsites when they take this position. The project where only the owner is working with no employees or any sub-contractors. I wish I had a dime every time a student says “I work alone” and within 10 minutes remembers those occasions when they needed help – just for one day of course. OSHA has no authority here (unless they come across that “one” time you needed a hand). HUD is usually not present on such small scales of work. RRP felt it should recommend to these situations that the owner think of protecting him/herself and their family. But basically if you truly work alone and own the company — be my guest and enjoy the poisoning. After all it is a free country. Just don’t get anyone else sick.

HUD & PPE HUD cites OSHA’s lead in construction law (1926.62). The assumption is employees will be involved on a HUD project. HUD’s law strictly addresses many other issues you really need to read such as occupant relocation, site protection, types of lead testing permitted, types of clearance allowed, the cleaning frequency as well as air monitoring. We are only addressing PPE here in this blog. HUD also cites that these must happen when the air exposure exceeds OSHA’s PEL. The line in the sand – cross it and follow these laws.

OHSA & PPE 1926.62(g) Here is the granddaddy of all regulations. This law is lengthy and very detailed. It begins with mentioning EXPOSURE levels your crew are realizing performing the tasks and how you must protect them when they are exposed OVER the PEL (permissible exposure limit) of 50 ug/m3. Almost all our activities on a job site create an exposure miles above this limit WHEN WE WORK THE WAY WE USED TO – before we taught you in class a few tricks that could greatly reduce your exposure levels. If you follow the working wet philosophy, use HEPA vacuums and use negative air machines you could very well be below these levels. (SURPRISE!– there is a level of 30 ug/m3 called the ACTION LEVEL that throws a small curve into the mix.) But can you prove what level you are at?

THIRD – Here is the reason you made it all the way through this blog!!!

IF you don’t want to wear a respirator, suit, gloves – STAY BELOW THE PEL at all times on your jobsites.

IF you don’t want to have to monitor the exposure levels – STAY BELOW THE ACTION LEVEL at all times on your jobsites.

In the old days, miners would carry a parakeet in a cage to the area they worked. As long as the bird lived, they worked. When the bird died, they ran. You can’t approach your sites this way any longer. You must protect your workers at a level of 10 times the PEL until you can prove the exposure level they are experiencing (10 x 50 = 500 ug protection).

YOU MUST PROTECT UNTIL YOU CAN PROVE YOU ARE BELOW THE PEL.

Get below the PEL, learn how to prove it and go to work the way you used to but this time do it safely. Identify any tasks that wearing a respirator might have to happen – or when you no longer have to. This type of thinking is not for everyone.

  • • Not everyone will invest in a negative air machine (around $700 – 1200).
  • • Not everyone will become a qualified person to collect personal air samples and maintain their records which prove their results.
  • • Sadly, Not everyone will be able to work without the use of respirators and suits.

FOR THOSE WHO ARE A BIT DIFFERENT.  Those who do want to protect their crews and families without paying for or punishing themselves by wearing all this stuff –

  • Invest in your company with a negative air machine. Learn how to make it work for you.
  • Learn how to prove your crew is safe because THEY AREN’T BEING EXPOSED TO DANGEROUS LEVELS OF LEAD.

We offer RRP…part 2. You have just read why this course is probably the best 4 hour course you will ever attend. Not because it’s mandatory (it’s not) not because you can’t teach yourself (you can) because it will show you how to reduce your operational costs and give you the quickest return on your money any other avenue can produce.

Ask yourself this, if prior to reading this you thought your only option was to buy respirators and suits – how long before you take the time to read all the regulations, figure out your procedures and get back to work? You just took the first step by reading this article. We can get you there in four more hours.