UPDATE ON LEAD-BASED PAINT RULES
You probably haven’t heard much about lead-based paint lately but rest assured that many people are still battling over the plan to extend lead renovation rules to commercial buildings.
Despite numerous groups opposing it, the Environmental Protection Agency (EPA) continues to move forward with a potential rulemaking that would expand the existing Lead Paint Renovation and Repair and Painting rule to include public and commercial buildings.
The New Commerical Rule
The proposed rulemaking, which likely would regulate renovation, repair and painting activities on and in public and commercial buildings to address possible lead-based paint hazards, is listed on EPA’s regulatory agenda for July 2015.
The EPA had originally agreed to introduce such a rule by September 2012 but that timeline was delayed in part due to the work by the National Association of Home Builders and other building trades groups.
Based on the current rule making schedule, the deadline for the new final rule is January 1, 2017.
The Hold-up
One of the biggest issues holding up the new rules is the fact that the agency has failed to perform prerequisite studies on the potential lead dust exposures to adults – not children – during renovation activities in pre-1978 commercial buildings.
In effect, the EPA has not yet shown the need for such a rule.
Residential Rule Still in Effect
The existing Lead Renovation, Repair and Painting Rule is still in effect and applies to any work performed in pre-1978 residential structures or any commercial space where a child under the age of six resides or “regularly” visits, such as day care centers.
Opt-Out Back In?
Additionally, the Lead Exposure Reduction Amendments Act of 2013 (H.R. 2093) was recently introduced in the U.S. House of Representatives.
The bill would reinstate the opt-out provision to allow home owners without small children or pregnant women residing in the home to decide whether to require LRRP compliance, allow remodelers to correct paperwork errors without facing full penalties and provide an exemption for emergency renovations.
It would also eliminate the requirement that recertification training be “hands on,” so that remodelers would no longer have to travel to training facilities out of their region.
This is a re-introduction of a rule that was in Congress last session and, so far, does not appear to be moving through very quickly. But sponsors of the Bill say they are committed to getting this passed.
Need Lead Training?
Indoor Environment Group, in cooperation with the University of North Dakota's Environmental Training Institute, offers training in all lead certification programs including the Lead RRP program.
Contact us today at 651-779-4300 and we’ll be happy to set up a training program for you or your entire company.
