Lead Safe Practices.

Lead Safe Practices

Lead Safe Practices Intro to Lead Safe Practices Certification
Renovations Training Lead Law Worker Protection Definitions Medical Examinations Low & Moderate Risk Work

Intro to Lead Safe Practices

Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is deleading? Deleading work is work conducted to achieve compliance with the Massachusetts Lead Law through the abatement of lead paint hazards

Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What does the Massachusetts’ lead law say? The Lead Law requires the removal or covering of lead paint hazards in homes built before where any children under six live.

Renovations

Lead Safe Practices Renovations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Deleading vs. Renovation, Repair and Painting: What's the Difference? While deleading activities conducted in residences and child-occupied facilities often involve work methods similar to those typically used in Lead Safe Renovation (LSR) activities, such as replacing windows, painting and installing vinyl siding, the two types of activities are distinct from each other in terms of purpose and effect.

Renovations What is renovation work?
Lead Safe Practices Renovations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is renovation work? Renovation work is work conducted for a fee that disturbs more than threshold amounts of painted surfaces in pre-1978 residences (target housing) and child-occupied facilities (kindergartens, daycares, etc.), where the purpose of the work is other than the abatement of lead paint hazards or the achievement of a Letter of Compliance. Renovation work is often carried out to repair, upgrade or beautify the property.

Renovations How does DLS define Renovation Project or Work?
Lead Safe Practices Renovations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How does DLS define Renovation Project or Work? The renovation of any unit of target housing or a child-occupied facility, or a portion thereof, which is conducted for compensation and which results in or may result in the disturbance of paint or paint debris, but which is distinguished from a deleading project as defined in 454 CMR 22.02: Renovation Project or Work or by one of the following conditions: (a) The work is carried out in or on a structure which is required to be deleaded by M.G.L. c. 111, § 197 but is unrelated to deleading compliance, both in terms of purpose and effect. (b) The work is carried out in or on a structure which is not required to be deleaded pursuant to M.G.L. c. 111, § 197, and the purpose of the work is other than the achievement of a Letter of Full Deleading Compliance pursuant to 105 CMR (D): Full Compliance.

Lead Safe Practices Renovations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations When must work be performed by a Lead Safe Renovator Contractor? If the renovation, repair or painting work disturbs more than six square feet of painted surface per room on the interiors or more than twenty square feet of painted surface (total) on the exteriors of target housing and child-occupied facilities -related operations, or any carpentry work, remodeling work, drywall work, electrical work, plumbing work, floor refinishing work, and many other commonly performed renovation, repair, painting and maintenance or any window replacement work or demolition work conducted in target housing and child-occupied facilities, regardless of the areas of painted surfaces disturbed by those operations, The work must be performed by either a licensed Lead Safe Renovator Contractor, or, in certain instances, by an entity which has obtained a ‘Contractor Licensing Waiver’.

Lead Safe Practices Renovations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Are there exceptions to the Lead Safe Renovator Contractor requirement? Except for contractors who were previously certified by EPA as “Certified Firms” prior to July 9, 2010, contractors who carry out RRP work/Lead- safe Renovation (LSR) in Massachusetts must be licensed as Lead-Safe Renovation Contractors pursuant to 454 CMR 22.04

Lead Law

Lead Law What is the purpose of Lead Law?
Lead Safe Practices Lead Law Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is the purpose of Lead Law? Minimum work standards to protect the health and safety of inspectors, deleaders, renovators and the general public. Standards of competency for persons or entities engaged in or performing deleading and renovation work that disturbs lead paint or lead paint debris.

Lead Law What is the purpose of Lead Law? Continued…
Lead Safe Practices Lead Law Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is the purpose of Lead Law? Continued… Minimum standards to be used by insurers in the inspection of risk, measurement of hazards and the determination of adequate and reasonable rates of insurance as prescribed by the provisions of M.G.L. c. 152, § 65J.

Lead Safe Practices Lead Law Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is the purpose of Lead Law? Continued… Standards for the licensure or certification of persons, firms, corporations or other entities who or which enter into, engage in or work at the business of deleading work.

Lead Safe Practices Lead Law Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is the purpose of Lead Law? Continued… Standards for the licensure or certification of persons, firms, corporations or other entities who or which enter into, engage in or work at the business of renovating residences and child- occupied facilities containing dangerous levels of lead.

Lead Safe Practices Lead Law Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is the purpose of Lead Law? Continued… Standards for the licensure of entities engaged in the business of training others, where such training is a condition of licensure or certification pursuant to 454 CMR

Lead Law What is the scope of Lead Law?
Lead Safe Practices Lead Law Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is the scope of Lead Law? Applies to the activities of employers, employees and others engaged in deleading of residences containing Dangerous Levels of Lead, except for the activities of: owners of residential premises and owners' agents who perform deleading work in accordance with regulations promulgated by the Director of the Childhood Lead Poisoning Prevention Program pursuant to M.G.L. c. 111, § 197(d); and contractors who, pursuant to 105 CMR , perform low- risk deleading activities in accordance with 105 CMR (A) or the activities set forth at 105 CMR (D) in or on short-term vacation or recreational rentals.

Lead Law What is the scope of Lead Law? Continued…
Lead Safe Practices Lead Law Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is the scope of Lead Law? Continued… Also applies to all renovation work conducted for compensation in Target Housing and Child- occupied Facilities.

Lead Law Are there exceptions to the lead law?
Lead Safe Practices Lead Law Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Are there exceptions to the lead law? The Commissioner of the Massachusetts Division of Occupational Safety may grant exceptions to 454 CMR in those instances where it is clearly evident that existing conditions prevent compliance, or where compliance will create an undue hardship but only in circumstances in which granting the exception will maintain the protection of the health and safety of workers and the general public.

Lead Safe Practices Lead Law Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Are there alternative methods for complying with the lead law? The Commissioner may allow the use of newly developed techniques, methods, or equipment that provide a level of protection for workers and the general public that equals or exceeds that specified by 454 CMR

Definitions

Definitions How do you define certification?
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define certification? The authorization to act as a lead-safe renovator- supervisor on renovation projects, which is conferred by the Division to persons who have successfully completed the initial training and refresher training for lead-safe renovation supervisors and who have not had such authorization suspended or revoked pursuant to 454 CMR

Definitions How do you define child-occupied facility?
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define child-occupied facility? A building or a portion of a building, constructed prior to 1978, and visited by the same child of less than six years of age on at least two different days within any week (Sunday through Saturday ), provided that each day's visit lasts at least three hours and the combined weekly visits last at least six hours, and the combined annual visits last at least 60 hours. Child-occupied facilities may be located in target housing or in public or commercial buildings.

Definitions How do you define child-occupied facility? Continued…
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define child-occupied facility? Continued… With respect to common areas in public or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses those common areas that are routinely used by children under the age of six.

Definitions How do you define child-occupied facility? Continued…
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define child-occupied facility? Continued… With respect to the exteriors of buildings that contain child-occupied facilities, the child-occupied facility encompasses only the exterior sides of the building that are immediately adjacent to the child- occupied facility.

Definitions How do you define Class 1 Deleading Project or Work?
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define Class 1 Deleading Project or Work? Deleading work which includes abatement activities other than those defined as low-risk deleading or moderate risk deleading in 454 CMR

Definitions What is the CLPPP?
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is the CLPPP? The Commonwealth of Massachusetts Department of Public Health, Childhood Lead Poisoning Prevention Program.

Definitions What is a Cleaning Verification Card?
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is a Cleaning Verification Card? A card developed and distributed, or otherwise approved by EPA for the purpose of determining, through comparison of wet and dry disposable cleaning cloths with the card, whether post- renovation cleaning has been adequately completed.

Definitions How do you define ‘Deleading Work or Project’?
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define ‘Deleading Work or Project’? The abatement or containment of materials containing dangerous levels of lead in residences by the removal, covering or encapsulation of lead paint or by replacement of whole building components in instances described by one or more of the following: (a) Where the owner of the property has received an Order to Correct Violations pursuant to M.G.L. c. 111, § 197; (b) Where the purpose of the work is to achieve a Letter of Compliance pursuant to 105 CMR (D) or a Letter of Interim Control pursuant to 105 CMR (D), or tax credit eligibility pursuant to 830 CMR ;

Definitions How do you define ‘Deleading Work or Project’? Continued…
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define ‘Deleading Work or Project’? Continued… (c) Where the owner of the property is required to delead pursuant to M.G.L. c. 111, § 197 and the effect of the work if performed would be to accomplish, or contribute to the accomplishment of, deleading compliance as specified by 105 CMR (D) or 105 CMR (D); or (d) Where the Director of the Childhood Lead Poisoning Prevention Program or other authority with competent jurisdiction has designated the work a deleading project.

Definitions How do you define ‘Deleading Work or Project’? Continued…
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define ‘Deleading Work or Project’? Continued… Deleading projects or work may include class I deleading work, moderate-risk deleading work and low-risk deleading work.

Definitions How do you define ‘Emergency Renovation’?
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define ‘Emergency Renovation’? Any unplanned renovation project that is necessary to protect or preserve life or property from imminent harm, damage or deterioration, as determined by the Commissioner.

Definitions How do you define ‘Encapsulant’?
Lead Safe Practices Definitions Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define ‘Encapsulant’? A coating product listed on the Register of Approved Encapsulants pursuant to 105 CMR which is formulated to contain lead hazards by providing a long-lasting and resilient barrier over painted surfaces and which is applied in liquid form, with or without a structural reinforcement.

Low & Moderate Risk Work

Lead Safe Practices Low & Moderate Risk Work Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define ‘Low and Moderate Rick Abatement and Containment’? Effective March 15, 1995, following inspection of a premises by a lead inspector, the following low-risk abatement and/or containment activities may be performed on the owner’s property by authorized persons: Applying encapsulants over suitable surfaces, pursuant to 105 CMR Removing doors, cabinet doors, windows on hinges (such as wooden storms) and shutters by disengaging hinge pins or removing hinges.

Lead Safe Practices Low & Moderate Risk Work Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How do you define ‘Engaging in Abatement’? For the purposes of 454 CMR 22.03(1), the phrase "engage in the business of lead abatement" includes, but is not limited to, advertising deleading services and submitting bids for work.

01 02 03 Low & Moderate Risk Work
Lead Safe Practices Low & Moderate Risk Work Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How are the levels of risk categorized? Owner’s property work 01 Low-risk Deleading Work 02 Moderate-risk Deleading Work 03

Lead Safe Practices Low & Moderate Risk Work Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Who can perform lead abatement work? A Deleading Contractor: Except as allowed by 454 CMR 22.03(1)(a) through (c), no person, firm, corporation or other entity shall enter into, engage in or work at the business of lead abatement unless such person, firm, corporation or other entity has been duly licensed as a Deleading Contractor, in accordance with 454 CMR

Lead Safe Practices Low & Moderate Risk Work Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What are the requirements for ‘Owner’s Property Work’? When working in or on the property of the owner, and in accordance with regulations, then: Persons need not be licensed as Deleading Contractors, provided that said persons are trained and have received a certificate of instruction.

Lead Safe Practices Low & Moderate Risk Work Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What are the requirements for ‘Moderate- risk Deleading Work’? Where the business or work includes only the conduct of Moderate-risk Deleading Work, the entity carrying out the work may be licensed as a Lead-safe Renovation Contractor pursuant to 454 CMR in lieu of being licensed as a Deleading Contractor.

Lead Safe Practices Low & Moderate Risk Work Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What are the requirements for ‘Low-risk Deleading Work’? Contractors and other entities who perform only Low-risk Deleading Work in or on the property of the Owner in accordance with regulations promulgated by the Director of CLPPP, pursuant to M.G.L. c. 111, § 197(d), need not be licensed as Deleading Contractors or Lead-safe Renovation Contractors, provided that said persons are trained pursuant to 105 CMR (D) and have received a certificate of instruction pursuant to 105 CMR (E).

Certification

Lead Safe Practices Certification Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What are the Dept. of Labor’s requirements for certification? The EPA and DLS RRP Rule applies to renovation, repair and painting (RRP) work conducted for a fee in pre-1978 target housing and child-occupied facilities where the work involves the disturbance of more than 6 ft2 of painted surfaces per room or more than 20 ft2 of paint on exteriors (total) occurs Exception: the quantity exemptions do not apply to any projects involving window replacement or demolition of structures.

Lead Safe Practices Certification Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What documentation and fees does the EPA require for certification? EPA: $300 for five years. Applicants must submit identifying information: list of professional certifications related to lead-based paint activity list of previous violations related to lead-based paint activity.

Lead Safe Practices Certification Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What documentation and fees does the DLS require for certification? DLS: $375 for five years. In addition to filling out identifying information on application form, applicant must show the following: Document that a person in a supervisory or management capacity has received the one-day Lead- Safe Renovator-Supervisor ("Certified Renovator") training. Document that a medical monitoring/respirator protection program is in place (entities with employees only). Program templates are on DLS's website. Submit information related to organization of the business or entity - corporate articles of organization, business certificate, etc., as applicable.

Lead Safe Practices Certification Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What documentation and fees does the DLS require for certification? Continued… In addition to filling out identifying information on application form, applicant must show the following: Continued… Submit lists of current and previous employees. Document workers compensation coverage (entities with employees). Affirm compliance with Massachusetts tax laws, including DOR, DUA, FSC. Submit lists of occupational health and safety-related violations, notices of noncompliance, enforcement actions, etc.

Certification What else does DLS want?
Lead Safe Practices Certification Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What else does DLS want? Mass Department of Labor Standards: Contractors trained on the Lead Safe Renovator Supervisor class must complete the 4 hour refresher course to renew their certifications within 5 years. The State of Mass Department of Labor Standards recommends that contractors obtain their training within a minimum of 60 days before their 5 year expiration date.

Certification What is a ‘Deleading Contractor’?
Lead Safe Practices Certification Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is a ‘Deleading Contractor’? Any person, firm, corporation or other entity who or which has a valid license issued by the Commonwealth for the purpose of entering into or engaging in Class I Deleading work.

Certification What is a ‘Deleader-supervisor’?
Lead Safe Practices Certification Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is a ‘Deleader-supervisor’? A deleader-supervisor is an individual or agent of a deleading contractor who is: duly licensed to perform class I deleading work determines the proper conduct of deleading operations exerts supervisory control over deleader- workers on deleading projects has received the initial deleader-supervisor training specified by 454 CMR 22.08(4)(c), after April 22, 2010, to exert supervisory control on renovation projects.

Certification What else should I know about supervisors?
Lead Safe Practices Certification Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What else should I know about supervisors? DLS requires the supervisor ("Lead-Safe Renovator Supervisor") to be on site at all times when RRP work is in progress.

Certification What else should I know about supervisors?
Lead Safe Practices Certification Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What else should I know about supervisors? All persons who perform the functions of Deleader- supervisors and Deleader-workers on Class I Deleading Projects shall be licensed pursuant to the procedures set forth at 454 CMR All persons who perform the functions of supervisors on Moderate Risk Deleading Projects shall be Licensed as Deleader-supervisors or Certified as Lead-safe Renovator-supervisors. All persons who carry out the functions of workers on Moderate Risk Deleading work sites shall be Licensed as Deleader-workers or Deleader- supervisors

Certification What is a ‘Deleader-worker’?
Lead Safe Practices Certification Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is a ‘Deleader-worker’? A person not acting as a deleading contractor or deleader-supervisor who is duly licensed pursuant to 454 CMR 22.03(2) and 454 CMR to perform class I deleading work as an employee, and who performs such work under the direction of another, with or without compensation.

Training

Training What training must be provided to supervisors?
Lead Safe Practices Training Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What training must be provided to supervisors? Lead-safe Renovator- supervisors who carry out supervisory functions on Moderate Risk must have: training in the subjects listed on the next slides be in possession of a current certificate which includes the designation "Lead-safe Renovator-supervisor Moderate Risk Deleading Option."

Training Which subjects require supervisor training?
Lead Safe Practices Training Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Which subjects require supervisor training? Roles and Responsibilities of a Lead-safe Renovator-supervisor on Moderate Risk Deleading Projects. Distinctions between various Deleading options and requirements and those pertaining to Renovation Work. Eligibility requirements for Moderate Risk Deleading Work. In-depth Workshop on Interpretation of Lead Inspection Reports. Pre-work inspection requirements. Restriction on use of Recognized Test Kits for Moderate Risk Deleading Projects.

Training Which subjects require supervisor training? Continued…
Lead Safe Practices Training Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Which subjects require supervisor training? Continued… Specialized Work Practices for Moderate Risk Deleading Work. Restrictions on occupancy during work. Project Cleanup and Clearance Requirements. Clean-up and disposal requirements and methods. Mandatory use of dust wipe clearance by Lead Inspector or Risk Assessor. Associated clearance standards. Recordkeeping Requirements for Deleading Work.

Training What are the requirements for training?
Lead Safe Practices Training Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What are the requirements for training? All persons requiring training as a prerequisite for licensure or certification pursuant to 454 CMR (1) through (4), or for participation in Renovation Projects in the capacity of workers, shall be trained pursuant to 454 CMR 22.08, in their own language.

Training What does DLS require?
Lead Safe Practices Training Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What does DLS require? DLS: DLS requires essentially the same one-day training course for certified "Lead-Safe Renovator- Supervisors" that EPA requires for "Certified Renovators" except that the DLS-required course includes respirator/personal protection training elements.

Training What does DLS require? Continued…
Lead Safe Practices Training Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What does DLS require? Continued… Where the training is given in Massachusetts, the course must be given by a Massachusetts-licensed training provider. As is the case with EPA, possession of the training certificate, which includes a digital image of the trainee constitutes the certification.

Lead Safe Practices Training Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What does DLS require? Continued… DLS also allows persons who have taken the deleader-supervisor and deleader-worker courses to take a one-half day upgrade/refresher course to upgrade to "Lead-Safe Renovator-Supervisor" status. Persons who possess this certificate do not have to apply to DLS directly. The training/certification is valid for five years, after which time the "Lead-Safe Renovator-Supervisor" must take a one-half day refresher course.

Lead Safe Practices Training Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What does DLS require? Continued… DLS also requires training providers to include "Lead-Safe Renovator-Supervisor" training elements in four-day training courses. This was required for "Deleader-Supervisors" given after July 9, 2010.

Lead Safe Practices Training Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What does DLS require? Continued… DLS will therefore allow "Deleader-Supervisors" to function as "Lead-Safe Renovator-Supervisors" on renovation worksites after they have completed this training.

Training Is there reciprocity between EPA and DLS?
Lead Safe Practices Training Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Is there reciprocity between EPA and DLS? EPA: Firms or entities that have been licensed as "Lead-Safe Renovation Contractors" by DLS in Massachusetts must become certified with EPA as "Certified Firms" in order to carry out RRP work in states where EPA is running the RRP program. EPA allows individuals who have been trained/certified as "Lead-Safe Renovator- Supervisors" in Massachusetts to act as supervisors and perform the functions of "Certified Renovators" on RRP projects in other states where EPA is running the program without needing to obtain separate EPA certification as "Certified Renovators."

Worker Protection

Worker Protection What are the worker protection requirements?
Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What are the worker protection requirements? The requirements of 454 CMR shall apply to the personal protection and medical monitoring of persons engaged in Deleading Work and Renovation Work except Owners and Owner's Agents who conduct Deleading Work in accordance with M.G.L. c. 111, § 197(d).

Worker Protection Are there guidelines for compliance?
Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Are there guidelines for compliance? 105 CMR: Department of Public Health The following are some guidelines for compliance Applicability General Respiratory Protection Requirements. Requirements for the Use of Protective Clothing and Equipment.

Worker Protection What do the guidelines say about applicability?
Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What do the guidelines say about applicability? The requirements of 29 CFR , and other applicable OSHA standards shall apply to the personal protection and medical monitoring of employees. EXCEPTIONS: Deleading Contractors shall maintain as records the results of all personal exposure monitoring, respirator fit testing, medical examinations and blood lead testing conducted pursuant to the requirements of 29 CFR (d).

Deleader-workers shall be governed by 454 CMR 22.09(5)(a
Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What do the guidelines say about applicability? Continued… EXCEPTIONS: Continued… The frequency of blood monitoring of employees licensed as Deleader-supervisors and Deleader-workers shall be governed by 454 CMR 22.09(5)(a

Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What do the guidelines say about applicability? Continued… EXCEPTIONS: Continued… The personal protection and medical monitoring of employees and other employees exempted from coverage by OSHA standards shall be governed by the provisions of 454 CMR

Worker Protection Are there respiratory requirements?
Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Are there respiratory requirements? Respiratory protection must meet the requirements of relevant OSHA regulations. Employers shall provide respirators and all necessary maintenance materials at no cost to employees and shall provide proper respirator fit testing prior to initial use and at least annually thereafter.

Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Are there protective clothing and equipment requirements? The Deleading Contractor, Lead-safe Renovation Contractor, or employer conducting Class I Deleading, Moderate-risk Deleading or Renovation Work shall ensure that employees, inspectors and other persons involved in said work are provided with protective clothing and other personal protective equipment.

Worker Protection Who pays for the PPE?
Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Who pays for the PPE? Employers shall provide employees with protective clothing and equipment without cost. Employer foots the bill.

Worker Protection What type of PPE does it need to be?
Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What type of PPE does it need to be? Protective clothing shall provide sufficient coverage and be sufficiently impermeable to lead dust, caustic paste, chemical solvents and other contaminants to prevent contamination of underlying garments or body surfaces.

Worker Protection Are there other PPE requirements?
Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Are there other PPE requirements? Where dust generating methods are used, the employer shall provide a minimum of two changes of protective clothing during an eight-hour day.

Worker Protection Are there other PPE requirements? Continued…
Lead Safe Practices Worker Protection Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Are there other PPE requirements? Continued… Where caustic paste is used to remove paint, the employer shall provide and ensure the use of: full- body overalls impervious to caustic substances; gloves impervious to caustic substances; glove extenders; appropriate boot or shoe covers; and face shields, where caustic paste is to be applied or removed at or above face level.

Medical Examinations

Medical Examinations What is the requirement for medical examinations?
Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What is the requirement for medical examinations? Deleading Contractor, Lead-safe Renovator Contractor, or other employer conducting Class I Deleading Work, Moderate-risk Deleading Work or Renovation Work shall ensure that employees are provided with medical examinations and consultations in accordance with 29 CFR (j)(1) and (3) and 454 CMR 22.09(4)(a) through (g).

Medical Examinations When should medical exams take place?
Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations When should medical exams take place? The medical examinations specified by 454 CMR (4) shall be provided: As soon as possible, upon notification by an employee either that he or she has developed signs or symptoms commonly associated with lead intoxication, that the employee desires medical advice concerning the effects of current or past exposure to lead on the employee's ability to procreate a healthy child, that the employee is pregnant, or that the employee has demonstrated difficulty in breathing during a respirator fitting test or during use; or Immediately following medical removal specified by 454 CMR 22.09(5)(b) or as medically appropriate, as determined by a physician.

Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What information should be provided to the medical examiner? The Deleading Contractor, Lead-safe Renovation Contractor or other employer shall provide to the physician conducting a medical examination or consultation under 454 CMR the following information: A copy of the following sections of the Department's regulations: a. 454 CMR 22.09: Worker Protection and Medical Monitoring Requirements b. 454 CMR 22.11: Work Practices and Other Requirements for Renovation Work; and c. 454 CMR 22.12: Work Practices and Other Requirements for Deleading Projects

Medical Examinations What other documents need to be provided?
Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What other documents need to be provided? A description of the employee's duties as they relate to exposure to lead or other harmful substances; The employee's exposure level or anticipated exposure level to lead and, where applicable, to any other toxic substance; A description of any personal protective equipment used or to be used; Prior blood lead determinations; and All prior written medical opinions in the employer's possession or control

Medical Examinations How frequently should workers get blood tests?
Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How frequently should workers get blood tests? Deleader-supervisors and Deleader-workers shall receive blood lead and zpp monitoring every two months during the first six months following licensure or certification and at least quarterly thereafter.

Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How frequently should workers get blood tests? Continued… Except as specified by 454 CMR 22.09(5)(a)3., Lead- safe Renovator-supervisors and Workers on Renovation Projects shall receive blood lead and zpp monitoring according to the schedule set forth at 29 CFR (j).

Medical Examinations What’s the ZPP test?
Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What’s the ZPP test? The zinc protoporphyrin test, unlike the blood lead determination, measures an adverse metabolic effect of lead and as such is a better indicator of lead toxicity than the level of blood lead itself. The level of ZPP reflects lead absorption over the preceding 3 to 4 months, and therefore is a better indicator of lead body burden. The ZPP requires more time than the blood lead to read significantly elevated levels; the return to normal after discontinuing lead exposure is also slower. Furthermore, the ZPP test is simpler, faster, and less expensive to perform and no contamination is possible. Many investigators believe it is the most reliable means of monitoring chronic lead absorption.

Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How frequently should workers get blood tests? Continued… Persons tested pursuant to 454 CMR 22.09(5)(a)1. or 2. whose last blood lead analysis indicates a lead level at or above 25 ug/dl of whole blood shall be tested at least every two months until two consecutive blood lead analyses indicate blood lead levels below 25 ug/dl of whole blood.

Medical Examinations Why are blood tests so important?
Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations Why are blood tests so important? The blood lead level at present remains the single most important test to monitor lead exposure and is the test used in the medical surveillance program under the lead standard to guide employee medical removal. The ZPP has several advantages over the blood lead level. Because of its relatively recent development and the lack of extensive data concerning its interpretation, the ZPP currently remains an ancillary test.

Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How frequently should workers get blood tests? Continued… Where a person is removed from Deleading or Renovation Work pursuant to 454 CMR 22.09(5)(b), said person shall receive blood lead and zpp testing at least monthly during the period of medical removal.

Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations What needs to happen when someone is removed from work? During the period of any form of special protection or removal, the employer must maintain the worker's earnings, seniority, and other employment rights and benefits (as though the worker had not been removed) for a period of up to 18 months.

Lead Safe Practices Medical Examinations Intro to Lead Safe Practices Renovations Lead Law Definitions Low & Moderate Risk Work Certification Training Worker Protection Medical Examinations How frequently should workers get blood tests? Continued… Upon being hired to perform Deleading Work for a new employer, and before engaging in such work, Deleader-supervisors and Deleader-workers shall receive blood lead and zpp monitoring in accordance with the schedule set forth at 454 CMR (5)(a) unless more frequent testing is indicated by 454 CMR 22.09(5)(a)3. or 4 zinc protoporphyrin (ZPP) test required as part of the biological monitoring requirements of the lead standards.

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