Opinions on ‘Dust Wipe’ Clearance Testing Vary

The list of folks opposed to the Environmental Protection Agency’s (EPA) proposed expansion of the Renovation, Repair and Painting (RRP) Rule is long. Another group, the National Lumber and Building Material Dealers Association (NLBMDA), joined Friday.

EPA wants to broaden the RRP rule to require building contractors to collect dust samples after renovation is completed. The samples would be submitted to a lab for testing. If a sample is found to contain too much lead, the contractor would need to re-enter the job site for additional cleaning.

NLBDMA’s echoes some well-thought points. The group believes EPA is overreaching in its authority, that the distinction between a remodeling company and an abatement company is being blurred, and that we don’t know enough about the RRP rule’s effects on the remodeling industry to go change the game again … The group’s comments are just a few in the murky sea of opinions on expanding the RRP rule this way. Following is a sample from the EPA’s public comment docket on the matter.

David Bryan, president of Blackdog Builders Inc. in Salem, N.H., believes the cost of expanding the RRP rule this way could “bankrupt many companies like mine.” (On a side note, who thinks Bryan is a Led Zeppelin fan?) Bryan says he has laid off 50 percent of his staff, or 20 employees, in the past two years. “Our revenue dropped 30 percent in 2009 and we are finding the process of securing new work more and more difficult,” he continues. For this and other reasons, he can’t support expanding the rule.

While others, like Lyndon Wicker of Whitewater Environmental Consulting Inc., think the rule expansion is valid. “I routinely perform lead inspections and risk assessments in target housing. I find that 50% or more of the replacement windows I test, test positive for lead dust.”

So, where do you stand? Is dust wipe clearance testing a good idea?

To view EPA’s comment docket, go here.


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