EPA Adds Up YOUR Costs To Meet New Lead-Paint Rules for Public, Commercial Buildings
AGC Needs Your Help Confirming Whether the Cost Estimates Are Correct
The U.S. Environmental Protection Agency (EPA) is exploring whether to expand its Lead Renovation, Repair and Painting Program (LRRP) rule to cover construction work on existing public and private-sector commercial (P&C) buildings. The EPA has estimated how much it would cost YOU to meet its new lead-paint rules under consideration. However, AGC needs your thoughts on these EPA estimates to ensure they reflect real-world impacts of a potentially huge expansion of EPA’s current LRRP requirements.
EPA’s anticipated action would add lead-related certifications, training, work practice, recordkeeping and other requirements and costs to much of the construction work inside/outside existing P&C buildings, including restaurants, hotels, hospitals, churches and office buildings to name a few. (For a detailed list of the types of buildings that could be regulated in the future, click here.)
Three Areas Where We Need Your Feedback
Please review EPA’s estimates of the time, tasks and costs burdens to the regulated community that would result from an expansion of the current LRRP rule to include P&C buildings. Please let AGC (firstname.lastname@example.org) know by Dec. 7 whether these estimates are reasonably accurate—
- Renovator Training and Certification Costs – EPA has estimated renovator training and certification costs, which range from $70.00 (refresher training) to $455.39 (classroom initial 8-hour course) per student, based on the anticipated availability of online training programs and/or travel to an in-seat course held within a 50-mile radius without hotel accommodations. EPA is assuming that on-the-job training of the workforce, by the certified renovator, would take either 10 or 30 minutes depending on the format, and cost $5.00 to $15.00 per student. Cost estimates include “training time burden” in addition to tuition and expenses. (For details on EPA’s training cost estimates and assumptions, click here.)
- Work Practice Requirements and Costs – EPA has pulled together a listing of work practices that may be required under an LRRP rule for P&C buildings, such as interior containment and cleaning. EPA has also estimated the costs associated with those practices (testing fees, shoe covers, wipes, polyethylene sheeting, etc.). The estimated costs range from $0.01 for an electrostatic cloth sweeper (e.g., Swiffer) per 1,800 ft2 job to $613.80 in wet wipes (including labor) for the same square footage. (Click here to see EPA’s list of potential work practice requirements for P&C buildings. Click here to review EPA’s estimated costs associated with these work practice requirements.)
- Recordkeeping Requirements and Costs – EPA has estimated a company’s recordkeeping costs, under an LRRP rule for P&C buildings, for the first/initial year of certification, re-certification years, and other years. Costs include time to familiarize oneself with the rule requirements (3 hours), complete and return the certification form, and perform an estimated 4.8 hours per firm per year of recordkeeping responsibilities. Total cost estimates are as follows: initial year $392.00; re-certification year $251.00 and; other years $227.00. (Click here to review EPA’s estimated recordkeeping costs.)
Please send your comments to AGC’s Leah Pilconis at email@example.com by Dec. 7.
EPA’s current LRRP rule applies whenever lead paint is affected by construction work in pre-1978 “target housing” or “child-occupied facilities” only. For several years, EPA has been working to develop a new federal rule to address purported lead-based paint hazards that may be created by renovations on the interior or the exterior of existing public and private-sector commercial buildings. In accordance with the terms of its September 2012 litigation agreement with environmental and health advocacy organizations, the agency agreed to either sign a proposed rule by July 1, 2015, covering renovation, repair, and painting activities in P&C buildings, or determine that these activities do not create lead-based paint hazards. EPA recently notified the litigants that it is not going to meet the July 1, 2015, deadline for proposal. EPA plans to revisit the timing of this rulemaking action after it conducts the necessary steps to complete: (1) the Small Business Advocacy Review process (EPA has invited AGC to a Dec. 9 meeting to begin discussion of the issues above), (2) an industry survey (forthcoming), and (3) peer review of EPA’s “technical approach” documents.
For more information on EPA’s LRRP requirements, read AGC’s fact sheet and contact Leah Pilconis at firstname.lastname@example.org.
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