On April 22, 2008, EPA issued a final rule to address lead-based paint hazards created by these activities in target housing and child-occupied facilities built before 1978. In this rule, child-occupied facilities are a subset of public and commercial buildings or facilities where children under age 6 spend a great deal of time. The 2008 rule established requirements for training renovators, other renovation workers, and dust sampling technicians; for certifying renovators, dust sampling technicians, and renovation firms; for accrediting providers of renovation and dust sampling technician training; for renovation work practices; and for recordkeeping. This new rulemaking will address renovation or remodeling activities in the remaining buildings described in TSCA section 402(c)(3): Public buildings built before 1978 and commercial buildings that are not child-occupied facilities.

Shortly after the RRP Rule was published, several petitions were filed challenging the rule. These petitions were consolidated in the Circuit Court of Appeals for the District of Columbia Circuit. On August 24, 2009, EPA entered into an agreement with the environmental and children’s health advocacy groups in settlement of their petitions (Ref. 18). In this agreement, EPA committed to propose several changes to the RRP Rule. EPA also agreed to commence rulemaking to address renovations in public and commercial buildings, other than child occupied facilities, to the extent those renovations create lead-based paint hazards. For these buildings, EPA agreed, at a minimum, to do the following: 

• Issue a proposal to regulate renovations on the exteriors of public and commercial buildings other than child-occupied facilities by December 15, 2011 and to take final action on that proposal by July 15, 2013. 
• Consult with EPA’s Science Advisory Board by September 30, 2011, on a methodology for evaluating the risk posed by renovations in the interiors of public and commercial buildings other than child-occupied facilities. 
• Eighteen months after receipt of the Science Advisory Board’s report, either issue a proposal to regulate renovations on the interiors of public and commercial buildings other than child occupied facilities or conclude that such renovations do not create lead-based paint hazards.