NSPCA REGULATORY UPDATE
OCTOBER 2025
AMPP Updating Key QP Standards
If you are QP certified contractor, you should keep an eye on the current revisions being made to QP1 and QP Base. QP Base: Evaluating General Qualifications of Contractors Seeking QP Accreditation was originally passed in 2023. It is intended to provide a single document covering the common elements of QP certification and is then amended to specific requirements by the applicable QP standard.
QP1, Standard Procedure for Evaluating the Qualifications of Coating and Lining Inspection Companies (2019) is currently being updated to link to QP Base and includes several changes in its requirement such as:
· Quality Control Supervisor – Eliminates grandfathering of QCS to 2008 standard and eliminates the 2-day QCS course.
· EHS Manager – Requires 3 years of safety experience and increases training from 40 to 80 hours to SSPC/AMPP Guide 17, Guide to Developing a Safety Program for Industrial Coating and Lining Companies or 1 years safety experience and formal safety certification.
· Environmental Compliance – Refers to base and SSPC/AMMP QP2 but does not consider or address hazardous waste and other regulations applicable to field coating application.
· Appendix A -Craft Worker Requirements (Mandatory)
– seems to eliminate references to IUPAT/union training
- Adds crew requirements that immediate supervisor must be ACS-1 Level II at a 1 to 10 ratio
If you are interested in seeing the documents or joining the committee as a voting member or observer, please contact AMPP or go to ampp.org.
OSHA Proposed Regulations
On July 1, 2025, OSHA published intent to revise multiple standards affecting the construction industry.
Respiratory Protection - The summary for a proposed revision for respiratory standard states “OSHA is proposing to remove some medical evaluation requirements in the Respiratory Protection Rule for certain types of respirators. This proposed change would only impact filtering facepiece respirators and loose-fitting powered air-purifying respirators.
Lead, Cadmium, and Arsenic – the Advanced Notice of Proposed Rulemaking / requests for comments, OSHAs summary for the changes stated “This proposed rule revises some substance-specific respirator requirements to allow different types of respirators to be used under OSHA’s …. standards and better aligns the standards with OSHA’s Respiratory Protection standard.” Using the lead standard as an example:
Revise and republish paragraphs (f)(1) and (f)(3)(i).
Remove paragraphs (f)(1)(i)–(iv) and (f)(3)(i)(A)–(C).
Remove and reserve paragraph (l)(2)(iii).
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CURRENT (Text in red to be deleted) |
PROPOSED |
RESP PROT STD |
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1926.62(f)(1) General. For employees who use respirators required by this section, the employer must provide each employee an appropriate respirator that complies with the requirements of this paragraph. Respirators must be used during: 1926.62(f)(1)(i) Periods when an employee's exposure to lead exceeds the PEL. 1926.62(f)(1)(ii) Work operations for which engineering and work-practice controls are not sufficient to reduce employee exposures to or below the PEL. 1926.62(f)(1)(iii) Periods when an employee requests a respirator. 1926.62(f)(1)(iv) Periods when respirators are required to provide interim protection of employees while they perform the operations specified in paragraph (d)(2) of this section. |
(f) * * * (1) General. For employees who use respirators required by this section, the employer must provide each employee an appropriate respirator that complies with the requirements of this paragraph. Respirators must be used when the employer determines that they are necessary to protect the health of an employee as required under 29 CFR 1910.134(a)(2) and during periods when an employee requests a respirator. |
1910.134(a)(2) A respirator shall be provided to each employee when such equipment is necessary to protect the health of such employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program, which shall include the requirements outlined in paragraph (c) of this section. The program shall cover each employee required by this section to use a respirator. In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer shall establish and implement a written respiratory protection program with worksite-specific procedures. The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use. The employer shall include in the program the following provisions of this section, as applicable…. |
Elimination of (f)(1)(i-iv) seems to strip respirators and the use of HEPA / P100 filters:
· as part of interim protection during trigger tasks
· when above PEL
· where engineering controls can’t reduce worker exposures to below PEL
Similar language has been used on the arsenic and cadmium standards.
Construction Illumination – Proposed rule would eliminate minimum lighting standards for general construction.
Hexavalent Chromium – Request for information on the burden of conducting worker exposure monitoring, notifying workers of their chromium exposures, implementing medical surveillance of workers, providing examining physicians with specific information, implementing a respiratory protection program, notifying laundry personnel of chromium hazards, and maintaining workers’ exposure monitoring and medical surveillance records for specific periods.
Noise – Similar to the above, OSHA is questioning the value of noise monitoring vs. cost.
OSHA has extended the comment period on these regulations until November 1, 2025. The proposed regulations can be viewed and commented upon at Regulations.gov.
Status of the Advanced Notice of Proposed Rulemaking (ANPR) to the OSHA Lead Standards
The ANPR for Lead issued July 2, 2022 under the Biden administration which signaled major changes to the OSHA Lead in Construction and General Industry Standards such as reduced worker blood lead levels for medical removal, reduction of the airborne PEL, and other practices is for all extensive purposes is dead.