However, I must point out a correction to your opening paragraph that states “While the EPA only targets lead paint in this regulation, OSHA targets any known lead sources, including pipes, stain, tiles, mortar, flashings, etc…”

EPA RRP targets more than just PAINT in the traditional sense. Under Section 745.83 of RRP “Definitions” it says that “For purposes of this part, the definitions of 745.103 as well as the following definitions apply.” In 745.103, Lead-based paint is defined more broadly than the typical terminology that the word “paint” imparts. It defines lead-based paint as “Paint or other surface coatings that contain lead equal to or in excess of 1 mg/cm2 or 0.5% by weight.” The key point being that they include the phrase “other surface coating”. Therefore, this WOULD include stain, shellac, varnish, glazing on tiles, etc. Not just oil-based or latex paint.