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EPA is seeking public comment on the “Framework for Identifying and Evaluating Lead-Based Paint Hazards from Renovation, Repair, and Painting Activities in Public and Commercial Buildings.” The Framework describes a tailored approach for identifying and evaluating potential hazards created by renovations of public and commercial buildings. EPA will consider the public comments as the Agency assesses whether hazards are created by public and commercial building renovations. The Agency will develop proposed requirements to reduce any hazards, if found; such requirements would also be subject to public review and comment.
This is the interim step EPA is taking to explain how they will make the hazard determination as to whether or not renovations in public and commercial buildings create lead hazards for children - based on this document and their methodology and data they have collected, their analysis will show that, either:
(1) these renovation activities DO NOT create sufficient lead hazards for children to move forward with a rulemaking; or
(2) these renovation activities DO create sufficient lead hazards for children, and therefore a formal rulemaking is warranted.
We are reviewing the document and methodology, and will be commenting and making the argument that the analysis will clearly demonstrate that rulemaking is not necessary in this area, because there are already sufficient regulations and standards in place to protect children from lead hazards during renovation activities in public and commercial buildings.