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SSPC Seeks Input on New Lead Rules

Tuesday, February 5, 2013

More items for Environmental Controls

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SSPC: The Society for Protective Coatings is recruiting data and reports from its members on federal regulators' plan to expand lead-safe rules to commercial and public-works projects.

The U.S. Environmental Protection Agency is in the process of determining whether renovation, repair, and painting activities on and in public and commercial buildings create lead-based paint hazards that will require certification, training, and work practice requirements.

Lead Rule Redux

The proposed EPA Lead Rule: Renovation, Repair, and Painting Program for Public and Commercial Buildings follows a similar program in effect since 2010 for work conducted in pre-1978 homes and child-occupied facilities.

US Capitol renovation
Architect of the Capitol

Expansion of federal lead rules could impact work on all commercial and public buildings built before 1978. EPA is trying to determine whether such a rule is needed. The U.S. Capitol Dome was renovated in 2011.

The expansion plan stems from a 2009 federal court settlement by the EPA, Sierra Club, and New York City Coalition to End Lead Poisoning. That settlement requires EPA to initiate RRP-type rulemaking to address public and commercial renovation if that work is shown to pose lead-based paint hazards.

It's that if that is at the crux of much of the current debate on the rule. The EPA was forced last year to temporarily withdraw the proposal after a spate of complaints led the EPA Office of Inspector General to conclude that the agency had not carefully weighed the rule's costs and benefits.

Dinosaur National Monument lead paint removal
National Park Service

Lead paint was removed in 2010 from the Dinosaur National Monument. SSPC wants data on how new lead-safe rules could affect such projects.

Industry Information Needed

To remedy that, EPA is seeking industry data and feedback from public subject matter experts, with particular interest in information concerning:

  • The manufacture, sale, and uses of lead-based paint after 1978;
  • The use of lead-based paint in and on public and commercial buildings;
  • The frequency and extent of renovations on public and commercial buildings;
  • Work practices used in renovation of public and commercial buildings;
  • Dust generation and transportation from exterior and interior renovations of public and commercial buildings; and
  • Work practices used and information on costs and other potential regulatory impacts on small businesses.

SSPC's Efforts

The SSPC Government Affairs Committee, which is tracking the issue closely, is seeking member input to formulate comments on the plan.

SSPC requests that anyone with relevant data, reports, comments or information submit it to Heather Stiner at stiner@sspc.org before March 15. SSPC will compile and submit these comments representing viewpoints from membership to EPA before the April 1 deadline.

All comments submitted to EPA will be reviewed and discussed at a public meeting on June 26. The location has yet to be determined.

   

Tagged categories: Environmental Protection; EPA; Government contracts; Lead; Lead paint abatement; Lead Renovation, Repair and Painting Rule (LRRP); SSPC

Comment from Catherine Brooks, (2/5/2013, 3:23 PM)

It seems to me that asking an association which will be heavily and negatively and financially impacted to provide data and comments is like asking the fox to guard the hen house. Given the uproar of complaints about the first RRP law enactment and enforcement, the media will get flooded. The sharing of objective and repeatable research and facts will be the proof of the pudding.


Comment from Billy Russell, (3/5/2013, 6:20 AM)

Have QP certified contractors and SSPC held liable for releases over water with half a%$ built containment systems, on Bridge projects, "clearly define" and improve requirements of class 1A include put a containment over the decking, that aint fish biting the water, thats Grit and red paint chips hitting the water !!!!!


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