A renovation project involves scraping paint from interior walls of a house built in 1968. The contractor estimates 850 square feet of painted surface will be disturbed. What lead-safe work practice requirements apply?
Correct Answer
A) Both EPA RRP Rule and OSHA lead standard requirements
For pre-1978 housing with more than 6 square feet of painted surface disturbance, both EPA's Renovation, Repair, and Painting (RRP) Rule and OSHA's lead standard apply. The large area (850 sq ft) triggers comprehensive lead-safe work practices.
Why This Is the Correct Answer
Since the house was built in 1968 (pre-1978) and the project disturbs 850 square feet of painted surface (well above the 6 sq ft threshold), both federal regulations apply. The EPA RRP Rule requires certified renovators and specific work practices for pre-1978 housing when more than 6 sq ft of painted surface is disturbed. OSHA's lead standard also applies to protect workers when lead exposure is reasonably expected, which is the case with extensive paint disturbance in pre-1978 housing.
Why the Other Options Are Wrong
Option C: OSHA lead standard requirements only
While OSHA lead standard requirements do apply for worker protection, EPA RRP Rule requirements also apply since this involves renovation work in pre-1978 housing with paint disturbance exceeding 6 sq ft.
Option D: No special requirements needed
Special requirements are definitely needed because this involves a pre-1978 house with extensive paint disturbance (850 sq ft), which far exceeds regulatory thresholds and creates significant lead exposure risk.
Memory Technique
Use '1978 + 6 = BOTH' - if the building is pre-1978 AND more than 6 sq ft of paint is disturbed, BOTH EPA RRP and OSHA lead standards apply.
Reference Hint
Florida Building Code Chapter 1, Section 105 - Permits Required, and EPA RRP Rule documentation in environmental safety sections
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