My crew is going to be dry-scraping and heat-gunning old paint on a commercial building that tested positive for lead.

OSHA’s Lead in Construction Standard (29 CFR 1926.62) applies strictly to your crew. EPA RRP rules (40 CFR 745) cover the building/occupant; OSHA covers your employees. You must comply with both.

Immediate Requirements (Trigger Tasks): Dry scraping and heat gunning are "trigger tasks" presumed >50 µg/m³ (1926.62(d)(2)). Until you have personal air monitoring proving otherwise, you must provide:

1. Respiratory Protection: Minimum half-mask air-purifying respirator with P100 filters (1926.62(f)(1)(i)).
2. Protective Work Clothing: Full-body coveralls, gloves, head/foot coverings (1926.62(g)(1)).
3. Change Areas: Clean change area, separate storage for street/clothes, showers (if feasible) (1926.62(i)).
4. Hand/Face Washing: Facilities at exit (1926.62(j)).
5. Training: Lead hazard training per 1926.62(l) before start.
6. Blood Lead Monitoring: Initial blood test (BLL/ZPP) for each worker (1926.62(j)(1)(i)).

Exposure Assessment: You must conduct personal air monitoring during this work to determine actual 8-hr TWA (1926.62(d)(2)). If results exceed PEL (50 µg/m³), you need:

• Engineering Controls: HEPA vacuums, local exhaust ventilation, wet methods (heat gunning makes wet methods tricky; use HEPA shrouds).
• Respirator Upgrade: Full-face PAPR or supplied-air if >500 µg/m³ (1926.62(f)(1)(ii)).
• Medical Surveillance: Continued BLL monitoring per 1926.62(j)(1)(ii).
• Hygiene: Mandatory showers (1926.62(i)(4)).

Written Compliance Plan: Required before job start per 1926.62(e)(2).

Critical: Heat guns >1100°F create lead fume (highly inhalable). OSHA strongly discourages open-flame/heat gun removal. Use infrared paint strippers or chemical strippers instead. If heat guns are used, keep temp <700°F and use HEPA local exhaust at the tip.

Bottom line: You cannot start this work tomorrow without the respirators, coveralls, hygiene setup, training records, and initial blood draws scheduled.

OSHA’s Lead in Construction Standard (29 CFR 1926.62) applies directly to your scenario. Here’s what you must do for workers, beyond EPA’s Renovation, Repair and Painting (RRP) Rule:

1. Exposure Assessment - Conduct initial monitoring to determine 8-hour TWA (time-weighted average) airborne lead levels (1926.62(d)). - If exposure is ≥ Action Level (30 µg/m³) but < PEL (50 µg/m³), implement controls and periodic monitoring. - If ≥ PEL (50 µg/m³), you must implement engineering controls, work practices, and respiratory protection to reduce exposure to or below the PEL.

1. Engineering Controls & Work Practices - Use local exhaust ventilation (HEPA-filtered) on power tools (e.g., sanders, grinders) — dry scraping and heat guns generate respirable lead dust/fumes. - Prohibit dry sweeping or compressed air for cleanup (1926.62(h)(2)). Use HEPA vacuums or wet methods. - Heat guns can vaporize lead — ensure adequate ventilation and consider respiratory protection even if air levels seem low, as fume exposure is acute and hazardous.

1. Respiratory Protection - Provide respirators when engineering controls don’t reduce exposure below PEL (1926.62(f)). - For lead dust/fumes: minimum N100, R100, or P100 filtering facepiece (or half-mask with P100 cartridges). - If heat guns create significant fumes, consider supplied-air respirators (SARs) or PAPRs if concentrations are unknown or high.

1. Hygiene Facilities - Provide hand-washing stations (1926.62(i)). - Prohibit eating, drinking, smoking, or applying cosmetics in work areas (1926.62(i)(2)). - Provide clean change rooms if exposure exceeds PEL (1926.62(i)(3)).

1. Medical Surveillance - Required if workers are exposed ≥ Action Level for ≥30 days/year (1926.62(j)). Includes blood lead level (BLL) testing, zinc protoporphyrin, and medical exams.

1. Training - Train workers before assignment and annually on lead hazards, controls, hygiene, respirator use, and medical surveillance (1926.62(l)).

1. Signage & Labeling - Post warning signs at approaches to lead work areas (1926.62(m)).

Note: EPA’s RRP Rule applies to renovations in pre-1978 housing and child-occupied facilities — but OSHA 1926.62 applies to all construction work involving lead, including commercial buildings. OSHA is enforceable by federal/state OSHA agencies; violations carry fines and stop-work orders.

Bottom line: You must assess exposure, control dust/fumes, provide respirators and hygiene, train workers, and