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AGC Hosts Federal Owners to Discuss EPA’s Consideration of Expanding Lead-Paint Work Practice Program

On Jan. 14, AGC hosted representatives from the Office of the Secretary of Defense, Naval Facilities Engineering Command, General Services Administration and Department of Veterans Affairs to participate in a roundtable discussion with industry groups on the U.S. Environmental Protection Agency’s (EPA) consideration of new nationwide rules that would expand and strengthen the current federal Lead Renovation, Repair and Painting (LRRP) Program requirements. Specifically, EPA is looking at expanding the LRRP Program to include renovations of both the exteriors and interiors of public and commercial buildings. Under the current LRRP Program, paid contractors who perform work in most pre-1978 housing, child-care facilities and schools (i.e., that have, or are assumed to have, lead-based paint) must comply with federal accreditation, training, certification, recordkeeping, pre-renovation education/outreach, and other work practice requirements, or risk fines of up to $37,500 per day per violation.  EPA is in the process of determining whether LRRP activities on and in public and commercial buildings create lead-based paint hazards, and, for those that do, developing a similar suite of requirements as directed by the Toxic Substances Control Act (TSCA). EPA recently signed a revised litigation settlement with environmental groups that gives EPA until the end of 2016 to finalize an approach to regulating lead paint dust in commercial and public buildings.  On December 31, EPA announced [see Federal Register notice] a public hearing to develop the LRRP rule for public and commercial buildings.  The hearing will be held on June 26, 2013.  Comments are due by April 1st. Of particular interest to EPA for developing a proposed rule is information concerning:
  1. The manufacture, sale, and uses of lead-based paint after 1978.
  2. The use of lead-based paint in and on public and commercial buildings.
  3. The frequency and extent of renovations on public and commercial buildings.
  4. Work practices used in renovation of public and commercial buildings.
  5. Dust generation and transportation from exterior and interior renovations of public and commercial buildings.
AGC held the meeting with federal owners to exchange information and encourage collaboration in order to provide EPA with well-informed comments from both public and private building owners and constituencies. For more information or to offer input specific to EPA’s data needs (see #1-5 above), contact Leah Pilconis at 703-837-5332 or pilconisl@agc.org or Jimmy Christianson at 703-837-5325 or christiansonj@agc.org.