AGC July 6 responded to an Advance Notice of Proposed Rulemaking by the U.S. Environmental Protection Agency (EPA) to expand the Agency's Lead Renovation, Repair and Painting Program (RRP) requirements to cover work performed in commercial and public buildings.
The ANPR includes no proposed language. Rather, the public was invited to respond to over 100 detailed questions and data requests. Currently there are no limits on the potential scope of regulated commercial and public buildings. Other unresolved questions include: What renovation and repair work should be covered? What activities create the most risk? Should exposure pathways be broadened to include nearby properties? AGC invited members to help shape the future lead paint rule and solicited input on a variety of important industry-specific issues currently under consideration at EPA.
AGC Comments
As part of a coalition with 15 other organizations, AGC filed comments [insert PDF file] 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.
For more detail on AGC's comments on the EPA's ANPR and background on the Lead Paint Renovation, Repair, and Painting Program, please click here.
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