As required by the same law that authorized residential lead hazard rules, EPA is undertaking an analysis of potential lead hazards in public and commercial buildings and considering a new rule to expand the regulations that apply to the disturbance of lead during building renovation, repair and painting (RRP) activities in public and commercial buildings.
The rule would apply to work in all buildings regardless of age; current regulations apply only to buildings constructed prior to 1978, when lead paint was banned. However, exceptions are commercial and public buildings that contain “child-occupied” facilities such as day care centers, which must comply with the stringent rules that apply to pre-1978 housing.
In response to a formal request for information, NMHC/NAA filed comments in early April with EPA as members of the Commercial Properties Coalition, a group of trade associations whose members are involved in various aspects of commercial real estate development, ownership, management, contracting and building product supply. The coalition’s main message was that additional research is necessary to support new regulation.
More specifics on EPA’s proposal and NMHC/NAA’s comments are available here.
