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With the Environmental Protection Agency (EPA) moving forward with a rulemaking to expand its existing Lead Renovation and Repair Painting rule to include public and commercial buildings, ABC, as a part of the Commercial Properties Coalition, submitted comments on EPA’s framework for identifying and evaluating lead-based paint hazards from renovation, repair, painting activities in public and commercial buildings.

In the comments, the Coalition agrees with EPA that a “one size fits all” approach is not appropriate for public and commercial buildings; however, the letter points out that the agency is not taking the proper steps to first determine if lead-based hazards even exist in public and commercial buildings.

The Coalition believes that the agency needs to take the following steps before proceeding through the regulatory process:

  • Determine if a hazard exists
  • Subject the proposed framework methodology to peer-review
  • Follow the requirements in the Toxic Substances Control Act Subchapter IV.
EPA plans on convening a Small Business Advocacy Review Panel to get feedback from small entities on the rule’s impact in 2014.