EPA Still Says Get the Lead Out

Through back channels only at the time of this writing, EPA announced the results of its “Section 610” review of the lead safe rules (RRP). One of the interesting findings is that since the RRP rules were first issued, the science behind lead contamination has changed. In the announcement of the EPA Office of Pollution Prevention and Toxics dated April 2018, the EPA recognizes that lead is even more toxic than previously understood. On first reading of the 67-page announcement, it appears that this fact is significant in EPA’s reasoning behind keeping the rule intact and not re-instituting the old opt-out waiver. The conclusion is that danger still exists, that the overall economic costs of lead poisoning outweigh the costs of compliance, and finally that the issue of high false positive lead test kits is not sufficient to weaken the lead protection. [Copy of EPA Section 610 Review here or see pdf at end of article] The review considered fifteen public comments related to the 610 Review, as well as providing a discretionary response to another twenty comments received during prior comment periods on the accuracy of test kits. The comments and EPA’s responses were in the following categories: lead test …

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Smile – Caught on RRP Camera

EPA Crowdsourcing lead paint enforcement in New England Crowdsourcing: The practice of outsourcing a job or task that is traditionally performed by employees or a contracted company to a non-organized, usually large group of people, generally in the form of an open call or competition. Note to self: Don’t break law in plain sight of your competition Renovator Rule Violation Rockland Maine_1 UPDATE (5/31/11): YouTube has taken down the video for unspecified violations of the Terms of Service. Last Fall, I found this video while updating a PowerPoint presentation on the legal aspects of the EPA Lead-Based Paint Renovation, Repair & Painting (RRP) Rule.  I showed it to a group of contractors at my next seminar and warned: “Be careful, these days everybody has a video camera.” At that time, the EPA had not yet enforced any provisions of the new RRP Rule.  Prior enforcement had dealt with the long-standing customer notification requirements.  For instance, in July 2010 the EPA cited a Chicago area contractor called Hanson’s Windows and Construction and assessed a $784,380 fine.  The press release stated: The “warning” rule being enforced here is the 1998 federal Pre-renovation Lead Information Rule, which requires that renovators provide homeowners, tenants and owners or …

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