EPA again overreaches with punitive regulations.

I received the below from a national trade organization. It speaks for itself and will cause harm to both struggling homeowners who won't be able to afford to protect their largest investment, their home, and small business contractors and their employees or soon to be ex-employees.

"The EPA is proposing several revisions to the 2008 Lead Renovation, Repair, and Painting Program (RRP) rule that established accreditation, training, certification, and recordkeeping requirements, as well as work practice standards for persons performing renovations for compensation in most pre-1978 housing and child-occupied facilities.

EPA is proposing additional requirements be added to the existing LRRP Rule, requiring dust wipe testing after many renovations covered by LRRP. Under the proposed rule contractors may be responsible for cleaning pre-existing lead hazards in the home, as well as lead that may be disturbed during a remodel, because it adds the following to a project in a pre-1978 built home: an EPA certified dust sampler, risk assessor or lead inspector must collect a dust sample and prepare a clearance testing report, similar to what a lead abatement firm would do.

EPA is proposing to order that contractors performing specific renovation activities must conduct lead dust clearance testing in both the work area and rooms adjacent to the work area.

EPA is also proposing to remove the current regulatory option under the existing LRRP rule that allows contractors to skip the current rule’s cleaning verification obligation and immediately conduct dust clearance testing. We need your input in order to present our latest data findings on Capitol Hill."

While most people will agree that lead is dangerous the amount of lead typically exposed in a remodeling or painting project is minimal and some very basic procedures can minimize them further. The EPA requirements create a burdensome demand on homeowners and contractors alike. The standard lead test authorized for use in California alone can run $400 - $1200 per home and still doesn't guarantee or verify the presence of lead.

If enforced to its maximum homeowners will choose not to have the work done and instead these properties will fall into disrepair which will increase the lead exposure through peeling paint and other products. The other options will include the homeowner utilizing un-skilled labor from in front of your local big box home improvement center.

The EPA in its efforts to justify its existence in the name of protecting you is instead causing you to forfeit more of your home's value and to add more skilled workers to the unemployed.