8-10-15 RRP Update – EPA’s Blatant Disregard for the Rule of Law and 20 years of research.
EPA’s Renovation Repair and Painting Rule (RRP training) – What’s up? Is EPA’s 40 CFR Part 745 to be or not to be is the question? A lot of us are wondering and the time to know is getting shorter. Is the EPA going to require hands-on training for the trades as is required in the RRP Training or is it going to have a unwarranted, unsupported and non-Environmentally Protective amendment occur. Is the EPA going to re-consider the opt-out rule after substantial discussion in 2010 and is the EPA going to suspend the RRP Training until an acceptable chemical test kit is market available?
On January 23, 2015, the EPA’s Renovation, Repair and Painting (RRP) Training Rules’ initial refresher round was supposed to have begun (90 days prior to 4/23/15 expiring). Many days and dollars of pre-training were invested by many and many regulated trades began to sign up and refresh. On February 14, 2015, with no solicitation, consensus of stakeholders, or prior public announcement, the EPA amended the RRP training rule. This non-sensible amendment allowed those who disturb toxic lead-based painted surfaces, who are responsible to assess if the paint is leaded or not, responsible to assure proper lead safe work practice & containment and perform the not so protective, “Cleaning Verification,” which in theory is to ensure safety upon project completion, not have to refresh with any form of hands on or live interaction.
The industry that successfully has been educated through trade schools and schools of technologies for well over a half a century all of a sudden learns better via computer based e-training. Are our children’s future no longer of a concern? Or is it just not a concern for wealthy politicians and large trade associations who have to comply? This year’s (10/25-31/2015) National Lead Poisoning Prevention Week theme, “Lead-Free Kids for a Healthy Future,” will focus on the importance of the many ways parents can reduce a child’s exposure to lead and prevent its serious health effects,” according to the EPA. (http://www2.epa.gov/lead/lead-poisoning-prevention-week-2015). (To learn about lead and how to protect your family, contact the National Lead Information Center at 1 (800) 424-LEAD (5323) or visit epa.gov/lead.)
Correlation Between Lead-Free Kids and the RRP Training Amendments
I find it very ironic that the EPA’s theme this year is Lead-Free Kids for a Healthy Future, but after five and a half years of RRP training in play, the EPA still cannot decide if the contractors who, assess, disturb and assess the project completion safety via a visual evaluation do not need to complete a live interactive refresher course with hands on at a minimum of every five years. What’s even more ironic is that the National Association of Home Builders (NAHB)‘s members are some of the EPA’s most compliant RRP professionals, but who have also been strong opponents of the EPA’s RRP training, and are now sharing their frustration with EPA’s questionable behavior. On August 4, 2015, the NAHB wrote in an e-blast called, “We Need Your Help in Exposing EPA’s Blatant Disregard For the Rule of Law,” which recently unveiled documents on how the EPA dismissed legal and regulatory objections to the rule by the U.S. Army Corps of Engineers (Corps) and shed light on an EPA that is acting with little regard for the impact of the rule on home builders and homeowners.
Now, more than ever, we need your help in forcing the EPA to withdraw this flawed RRP training rule. As we reported to you last week, the EPA has not been an honest broker and has made a mockery of the regulatory process. The recently unveiled documents confirm the long-held belief that the EPA forcefully advanced this RRP training rule without the requisite input and oversight of its co-authoring agency, the Corps…. (http://www.nahb.org/en/news-and-publications/Press-Releases/2015/july/nahb-calls-on-epa-to-terminate-water-rule.aspx)
What is in Store for the RRP Training Rule?
The hypocrisy and self-serving interest by our government and blatant use of used car salesperson tactics coupled with total disregard for realty, was most recently portrayed by three senators; Jim Inhofe (Oklahoma), John Thune (South Dakota) & Chuck Grassley (Iowa), who on August 11, 2015, introduced a piece of legislation they claim would help increase compliance with US EPA RRP training. Of course it would, because what they are asking for is to suspend the rule. If the rule is suspended then everyone is in compliance, obviously it will increase compliance with the rule, since there will be no rule to follow. While at the same time, ALL of our children will be a risk of lead poisoning which has been clearly documented, researched and proven to be a national epidemic problem according to CDC 2012, when 1 out of every 50 children under 6 years of age is considered to have a blood lead level of 5ug/dl or greater- Reality!! “You can fint he article here where senators introduce the bill to ‘increase’ lead paint rule compliance” https://chemicalwatch.com/30843/senators-introduce-bill-to-boost-lead-paint-rule-compliance .
So EPA, what’s up with this RRP training amendment? Are we going to comply with the research of the past twenty years that strongly supports lead safe work practices and a trained labor force that minimizes the risk of children getting lead poisoning or are we going to ignore all the studies, data and realities of the world just to play politician and bureaucrat? If bureaucrat it is, then Donald Trump will get my next vote.
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