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This week the EPA held a public hearing on on renovation, repair and painting activities in public and commercial buildings. In 2010, EPA issued an advance notice of proposed rulemaking (ANPRM) concerning renovation, repair, and painting activities in public and commercial buildings. EPA is in the process of determining whether these activities create lead-based paint hazards, and, for those that do, developing certification, training, and work practice requirements as directed by the Toxic Substances Control Act (TSCA). Harold Huggins of Burtonsville, MD, testified on behalf of NAR, IREM and the CCIM Institute.
The testimony focused on three specific points: 1) EPA has not conclusively determined the degree to which lead hazards exist in public and commercial buildings; 2) residential buildings are definitively different than public and commercial buildings –in tenancy, construction, operation and maintenance; and 3) EPA does not have sufficient research on lead hazards in public and commercial buildings; and has not conducted adequate outreach with governmental entities, who own and lease a significant proportion of commercial and public buildings.
Other members of the industry coalition on this issue also spoke at the hearing. They reinforced the message that EPA has yet to conduct necessary research and analysis and has not demonstrated any hazard in commercial and public buildings. EPA has also reopened the public comment period on this issue through July 12, 2013.