EPA Requests Public Comments about RRP for Commercial Buildings

The U.S. Environmental Protection Agency has announced a public comment period and requested data and other information about whether RRP (Renovation, Repair and Painting) activities on public and commercial buildings might create lead-based paint hazards. The public is also being asked to comment on appropriate certification, training and work-practice requirements. The comment period runs through April 1, 2013.

Who Should Comment?

This document is directed to the public in general. However, you may be potentially affected by this action if you perform renovations, repairs, or painting activities on the exterior or interior of public buildings or commercial buildings. Potentially affected entities may include:

• Building construction: commercial building construction, industrial building construction, commercial and institutional building construction, building finishing contractors, drywall and insulation contractors, painting and wall covering contractors, finish carpentry contractors, other building finishing contractors.
• Specialty trade contractors: plumbing, heating and air-conditioning contractors; painting and wall covering contractors; electrical contractors; finish carpentry contractors; drywall and insulation contractors; siding contractors; tile and terrazzo contractors; glass and glazing contractors.
• Real estate: lessors of non-residential buildings and dwellings, non-residential property managers.
• Other general government support: general services departments, government, public property management services, government.

EPA has also announced a public meeting on this topic will be held on June 26. For more information, including instructions for providing comments, read the Federal Register notice.

About RRP

Title IV of TSCA, 15 U.S.C. 2681 et seq., was enacted to assist the federal government in reducing lead exposures, particularly those resulting from lead-based paint. Section 402(c)(3) of TSCA specifically requires EPA to revise its Lead-based Paint Activities Regulations (Ref. 1), promulgated under TSCA section 402(a), to apply to those renovation and remodeling activities in target housing, public buildings constructed before 1978, or commercial buildings that create lead-based paint hazards. In April 2008, EPA issued the final Lead Renovation, Repair and Painting (RRP) Rule under TSCA section 402(c)(3) (Ref. 2). The RRP Rule covers renovation, repair and painting activities in target housing, which is most pre-1978 housing, and child-occupied facilities, defined in the rule as a subset of public and commercial buildings in which young children spend a significant amount of time.