EPA Listens and Does the Right Thing

Based on the July 15 announcement by the EPA, I think we can all collectively say we are still living in a democracy.  Join me in patting yourselves on the back for helping to fight off excessive, additional EPA RRP regulation. Now that the dust has settled (pun intended) on the EPA’s decision not to make RRP dust sampling/testing a monumental extra headache for renovators and homeowner clients, we can take a minute and ask "why?" Perhaps EPA really listened … according to its announcement, the EPA points out that it received over 300 comments from the public.  It states, "Members of the regulated community and other industry commenters were generally concerned that the EPA had upset the balance it had struck in the 2008 RRP rule, arguing that a dust wipe testing or clearance requirement would have the effect of holding renovation firms responsible for pre-existing hazards … there was little support for dust wipe testing alone." Throughout the announcement, the EPA continues to refer to the comments in all of the  decisions contained in this ruling.  It appears that there may be a voice of reason within the system, that public criticism can be strongly considered, and we do not have to feel bullied by an immovable force, against the reality of economics and practicality. That said, as renovators, we are still in a very tough spot.  RRP is a hard sell to clients, many of whom are barely able to afford renovations in the first place.  We've all seen situations that because of the upcharge for lead paint removal regulations, customers  have to compromise on some other element of the project — elements that are more profitable for our company as well as satisfying to the homeowner. We’ll take last Friday's announcement as good news, and evidence that the evolution of these regulations will be affected, perhaps in part, by public response.  As much as the original RRP put contractors in a position of shock and disbelief, this latest ruling did not take it to another extreme. Hopefully, over time, RRP regulations will sort out to allow us to work profitably and efficiently with RRP methods, and the end result of clean worksites with less lead exposure to homeowners, workers and neighbors will be worth all the original fuss and expense.  The EPA has now stressed the value of RRP in its current form, and appears to be in a protective mode with regard to the whole package.