Commercial RRP

RRPInfoGraphicx230The current Lead Safe Renovation, Repair and Painting (RRP) Rule impacts pre-1978 housing and child-care facility, renovation and maintenance projects.  Contractors performing renovation and maintenance work are required to have company certification, supervisor training certification, provide owners and tenants with Lead Hazard information before starting work, and complete work using Lead Safe work practices.  These work practices include, workforce training, significant containment of work areas, documentation and record keeping, limitations of typical work practices and use of expanded clean up procedures.

Commercial and Public Building RRP is moving forward as conditions of lawsuit settlements with groups like the Sierra Club.  EPA’s disregard for use of widely accepted scientific methodology to prove a need, prior to moving forward, underscores the lack of critical analysis of facts in favor of agency agenda.  The EPA’s Office of Inspector General identified shortcomings in the agency’s economic analysis prior to implementing the original RRP rule.  The Inspector General’s recommendations included reexaminig the costs and benefits to determine whether the rule should be modified, streamlined, expanded or repealed.

During the first phases of the EPA’s Commercial RRP expansion, when requested, significant input from interested parties was provided.  The process in place requires response to the comments from the EPA.  A response has yet to be published. In its process to expand the rule, the agency has stated it would seek input though the current comment period and from a small business advocacy review panel.  Seeking and actually utilizing input from all interested parties, rather than just lead-free advocates and agency agenda is hoped for.

Significant changes are ahead for the ongoing maintenance of and up-fit/remodel work to pre-1978 Commercial and Public buildings.  The expansion of RRP Rules to Commercial and Public buildings will increase owner’s risk and liability and increase costs for maintenance and up-fit work in pre-1978 buildings.  Undoubtedly, we want to protect our children from the hazards or exposure to lead paint dust.  For Public Building and Commercial Buildings that are not child occupied, the EPA has yet to provide scientific proof that there is a hazard.  This expansion or RRP Rules would impact every building in the United States that was built prior to 1978.  State managed RRP programs, such as those in North Carolina and currently eleven other States will be required to adopt these changes.

We shared in our January 5th blog post the announcement of the EPA’s comment period and request for comments from interested parties. We were interested in activating building owners and managers, facility managers and contractors to participate by adding their comments either directly or through engaging and participating with their industry association to submit comments.

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EPA Commercial and Public Building RRP