EPA could make it a requirement of certification that the person meet OSHA requirements, and to obtain certification, one would have to demonstrate that he or she took an OSHA training course. One could follow the same approach for state or local training programs, that is, demonstrate that one has taken these courses and fulfilled requirements. There were concerns about an approach that allowed another regulation to substitute for EPA's. One needs to be clear about where one regulation ends and the other picks up. One could incorporate the specifications of the other agency's regulation into the EPA regulation, rather than incorporating that regulation by reference only.
Workers protect themselves and their families.
There is no specific length of training or requirement for competency of the instructor or by the trainee. OSHA is not specific enough to accomplish the protection that Congress intended. Elevated blood lead levels in adult workers are indicative of the need for worker protection in addition to what OSHA requires. There is a big difference between buildings that the public utilizes occasionally versus when they work in the building every day. There should be separate requirements for public and commercial buildings, and steel structures.