Lead Paint & Silica Safety

Lead paint: EPA's RRP rule

EPA's Renovation, Repair and Painting (RRP) rule requires anyone paid to do work that disturbs painted surfaces in homes, child care facilities, and preschools built before 1978 to be EPA-certified and to use lead-safe work practices (EPA: Lead Renovation, Repair and Painting Program).

• Abrasive blasting is restricted. On painted surfaces, the rule prohibits machines that remove paint through high-speed operation, explicitly including abrasive blasting and sandblasting, unless they have shrouds or containment systems with a HEPA vacuum attachment that collects dust and debris at the point of generation. No visible dust or air may escape the shroud or containment (40 CFR 745.85 (RRP work practice standards)).
• Exterior containment. For exterior RRP jobs, the rule requires closing doors and windows within 20 feet and covering the ground with impermeable sheeting extending 10 feet beyond the work (or farther, as needed to catch debris) (40 CFR 745.85 (RRP work practice standards)).
• Small jobs. The rule's minor repair and maintenance exemption covers disturbing 6 sq ft or less per room inside or 20 sq ft or less outside. It does not apply when prohibited practices like uncontrolled blasting are used.
• Who certifies in Michigan: Michigan is not one of the states that runs its own RRP program, so firms working here need EPA certification (EPA: How does my firm become RRP-certified?). Lead abatement (permanent hazard elimination) is a separate certification run by the Michigan Department of Health and Human Services (MiLeadSafe (MDHHS): lead professional certification).

Practical takeaway: If your house was built before 1978, assume painted surfaces may contain lead until a test shows otherwise. Ask any blaster whether the paint will be tested, whether their firm is EPA RRP-certified, and how they'll contain and dispose of debris. Many will recommend chemical stripping or other methods instead of open blasting.

Lead: worker protection (OSHA / MIOSHA)

For construction work, OSHA's lead standard (29 CFR 1926.62 (lead in construction)) and Michigan's equivalent, MIOSHA Part 603, set an action level of 30 µg/m³ and a permissible exposure limit of 50 µg/m³ (8-hour averages). Abrasive blasting where lead-containing coatings are present is one of the highest-exposure "trigger tasks." Until monitoring shows otherwise, employers must treat blasters as exposed above 2,500 µg/m³ (50× the PEL) and provide interim protection: respirators, protective clothing, hygiene facilities, biological monitoring, and training (MIOSHA fact sheet: Part 603, Lead Exposure in Construction).

Silica: why "sandblasting" with sand is a problem

• Breathing respirable crystalline silica can cause silicosis, lung cancer, and COPD. OSHA's silica standard names abrasive blasting as a major exposure source (29 CFR 1926.1153 (respirable crystalline silica, construction)).
• NIOSH has recommended since 1974 that silica sand (and other materials with more than 1% crystalline silica) be prohibited as an abrasive blasting material. NIOSH also notes that Great Britain prohibited silica for blast cleaning under its Factories Act 1949 (NIOSH, “Prevention of Silicosis Deaths”).
• Federal OSHA's silica standards, and Michigan's MIOSHA Part 690 (construction) and Part 590 (general industry), set a permissible exposure limit of 50 µg/m³ and an action level of 25 µg/m³ as 8-hour averages (MIOSHA Construction Standard Part 690, Silica in Construction).
• Silica dust doesn't only come from the media. Blasting concrete, brick, stone, and mortar releases silica from the surface itself.
• Substitute media aren't automatically harmless. OSHA notes that coal slag, garnet, copper and nickel slag, and glass may also cause lung damage, and slags can contain trace arsenic, beryllium, or cadmium (OSHA, “Protecting Workers from the Hazards of Abrasive Blasting Materials” (OSHA 3697)). Ask for the media's safety data sheet.

Protecting your household and neighbors

• Keep children, pets, and people without protection away from the work area.
• Close windows and turn off air intakes near the work.
• Agree in writing on containment, daily cleanup, and disposal of spent media and paint debris.
• Don't DIY-blast old paint. Rented equipment and a dust mask aren't adequate protection from lead or silica.

Sources: EPA: Lead Renovation, Repair and Painting Program; 40 CFR 745.85 (RRP work practice standards); EPA: How does my firm become RRP-certified?; MiLeadSafe (MDHHS): lead professional certification; 29 CFR 1926.62 (lead in construction); MIOSHA fact sheet: Part 603, Lead Exposure in Construction; 29 CFR 1926.1153 (respirable crystalline silica, construction); MIOSHA Construction Standard Part 690, Silica in Construction; NIOSH, “Prevention of Silicosis Deaths”; OSHA, “Protecting Workers from the Hazards of Abrasive Blasting Materials” (OSHA 3697).