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LRRP talks for commercial buildings underway: An insider's report

Post Time:Mar 04,2011Classify:Industry NewsView:102

Gil DiMaio, president and CEO of CBO Glass, Alden, N.Y., filed his first report from the pre-panel outreach meeting of Small Entity Representatives on EPA's Small Business Advocacy Review Panelon the Lead, Renovation, Repair, and Painting Program for the Exteriors of Public and Commercial Buildings. He was selected to serve as an SER in January, and is a member of the McLean, Va.-based National Glass Association's Architectural Glazing Committee.

In his report, DiMaio stated SER concerns about regulations that require additional work practices and containment when performing exterior renovations with lead-based materials. The concerns were: added costs that will force building owners to defer renovation projects; added costs to companiesthat comply with the regulations for training, administration and management; lack of enforcement by EPA, which creates an unfair advantage to those renovators who choose to ignore the regulations vs. those who comply; and the fact that the new regulations are being considered against an imposed deadline, before the Scientific Advisory Board presents its conclusions, particularly its assessment of the distance from child-occupied facilities or housing that lead-based airborne particulates might travel.

The SERs recommended:

Complete research to correctly define the proximity of housing and child-occupied facilities from the location of the exterior renovations before finalizing the new regulations, with the assumption that the workers are being protected as part of mandated OSHA standards.Selection for the Regulatory Option – that defines prohibited and restrictive practices within a yet to be determined proximity to housing or child occupied facilities– should be least intrusive.Alternatives for work practices– that select from a “menu” of work practices from the 2008 RRP rule and clearance proposal–should be that the practices must adhere to current OSHA standards.The definition of “public building” should be: “… any building which is owned, occupied or otherwise controlled by a federal, state or local government or political subdivision thereof.” Exterior renovation work on a government-owned public building will be more likely to have regulations enforcedApplying the regulations to exterior renovationson commercial buildings should specifically require application only if there is a recognized risk of exposure to lead-based materials in buildings built after 1978.

The SERs at the pre-panel meeting included building construction contractors, specialty trade contractors, building owners and managers, and facilities support services.

"Rep. Darrell Issa, R-Calif., wrote to NGA CEO and President Phil James, asking our industry for help to 'identify regulations that negatively impact job growth,' " DiMaio says. "Over the past month, I have received numerous inquiries from NGA members, from all over the country, of how they can help in our efforts to communicate the consequences to our government of new rules for lead paint in renovations to public and commercial buildings. When members see government regulations, which adversely affect the glazing industry, we need to 'speak up.' As a Small Entity Representative for this panel, this is exactly what we have done. I am very thankful to the members of the Architectural Glazing Committee and to the NGA team for their assistance and support."

"Gil's representation on the panel gives the nation's glaziers a considerable edge in the debate on this issue," James says. "The report he presented is an important first step at putting forward our industry's position and is a plumb-line for policy-makers to work from."


In April 2008, the EPA issued the finalLRRP ruleto address lead paint hazards created by renovation, repair and painting activities targeting housing and child-occupied facilities. Several lawsuits were filed challenging this rule. On Aug. 24, 2009, the EPA entered into a settlement agreement in whichit “agreed to commence rulemaking to address renovations in public and commercial buildings to the extent those renovations create lead-based hazards.” This agreement requires issuing a proposal by Dec. 15, 2011, to regulate renovations on exteriors of public buildings built before 1978 and commercial buildings; and take final action on that proposal by July 15, 2013. The settlement also requires a consult with the EPA’s Science Advisory Board by Sept. 30, 2011, on a methodology for evaluating the risk by renovations to the interior of public buildings built before 1978 and commercial buildings. The Science Advisory Board work is ongoing.

“It is worth noting that the ban by the Consumer Product Safety Commission in 1978 of lead-based paints allowed for exceptions to this ban for some commercial uses in post-1978 buildings,” DiMaio says.

Read related articles:

What could an extension of the LRRP program to commercial buildings mean for contract glaziers?

NGA member selected as SER to EPA panel

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Source: http://www.glassmagazine.com/news-item/commercial/lrrp-talks-commercial-buildings-underway-insiders-report-117712Author:

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