AGC Responds to EPA’s Plans to Expand RRP to Commercial Buildings

by WOHe

The EPA is actively reviewing the lead paint laws that are already on the books for residential renovation and remodeling work and considering whether and how to apply those requirements to public and commercial building renovation and remodeling, pursuant to a legal settlement agreement that the Agency made with several environmental and public health advocacy groups.

For exterior renovations of public and commercial buildings, EPA must issue a proposed rule requiring lead-safe work practices by December 15, 2011, and must take final action by July 15, 2013.  

For interior renovations, the EPA must consult with the EPA Scientific Advisory Board (SAB) by September 30, 2011, regarding a methodology for evaluating the risk posed by renovations in public and commercial buildings.  If EPA concludes that interior renovation activities do create lead-based paint hazards, then EPA must issue a proposed rule applying specified work practices to such activities within 18 months after receiving the SAB report and must take final action 18 months thereafter.

As part of a coalition of 15 other organizations, AGC filed comments with EPA maintaining that the Agency lacks the legal authority to adopt requirements for Lead RRP activities in public and commercial buildings.  In the comments, the coalition pointed out that the statute under which EPA would issue the rule grants it the authority to issue guidelines for work practice standards, but not the authority to promulgate such regulations for RRP in public and commercial buildings.

EDITOR’S NOTE: Stay tuned as we continue to report on this.

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