Following up on EPA Proposed Changes to RRP Rule

No News Is Not Good News

Requests for updated information regarding the pending RRP Rule changes which would mandate inclusion of Commercial and Public building as well as require wipe testing have been sent to the EPA.  We have not received any response and will post all information here when and if received.  

National Lead Expert, Burt Olhiser was contacted and shared he believed the RRP rule extensions would be ratified.  He suggested that could mean by fall of 2011, exteriors of commercial and public buildings could be included, and the following year interiors and dust wipe testing would be included.  Effectively this would bring EPA Lead Abatement goals into the construction remodeling world.  

Back on May 6, 2010, the EPA proposed several significant changes to the Renovation, Repair and Painting Rule. They requested public comment on the proposed changes, and comments were due on or before July 6, 2010.  The two areas the proposal will affect are:

1.The EPA is proposing a Renovation, Repair, and Painting Program for Public and Commercial Buildings. 
2. The EPA is proposing to require Dust Wipe Testing after many renovations.

The PDCA Commercial Forum petitioned National PDCA to gain assistance from National Lead expert Burt Olhiser to submit comments from PDCA.  To best represent member interests, National PDCA joined a coalition of construction related groups and became part of the comment submittal process through the coalition.

Under the first Proposal, the EPA is asking for comment on the Development of a Renovation, Repair, and Painting Rule to apply to: 
1.Exteriors of Public and Commercial buildings 
2.If lead-based paint hazards are determined to exist, Interiors of Public and Commercial buildings
Please see the Federal Register/Vol. 75, No 87/ Thursday, May 6, 2010/ Proposed Rules page 24848 for further information on this proposal.

Under the second proposal, the EPA would require Dust Wipe Testing for a variety of circumstances:
1.Use of a heat gun below 1100° F 
2.Removal or Replacement of Window or Door Frames 
3.Scraping of 60ft2 or more of painted surface 
4.Removal of more than 40ft2 of Trim, Molding, Cabinets or other Fixtures 
5.Use of Machines designed to remove paint through high speed operations 
6.The Demolition or Removal, through destructive means, of more than 6ft2 of plaster and lath building components
Cleaning Verification would still be required. However, upon successful completion of the Verification Procedure, a Certified Lead Inspector, Certified Lead Risk Assessor, or a Dust Sampling Technician would have to complete a Dust Test Wiping. 
Please see the Federal Register/Vol. 75, No 87/ Thursday, May 6, 2010/ Proposed Rules page 25038 for further information on this first proposal.