Eastern MA NARI Chapter tries to get their questions about the RRP answered by the EPA
Posted by Shawn McCadden on Thu, Mar 04, 2010 @ 01:16 PM
EPA RRP Update for EM NARI Members
Written by: Shawn McCadden CR, 3/2/10
On January 5th, 2010 Greg Antonioli, Mark Paskell and I met with representatives from the EPA Region One office in Boston to discuss NARI's concerns about the new RRP rules and to submit a list of questions about the rule. The list of questions, about 7 pages in total, were intended to seek clarification on ambiguous sections of the rule and or to seek answers for questions that did not appear to be addressed in the rule. At that meeting, the EPA agreed to answer our list of questions and thanked us for our help. They did admit that they could not answer many of the questions and would need to seek the answers from the EPA's legal counsel in Washington. James Bryson, the Regional RRP Coordinator for the Boston office was to assemble the answers for us. Our impression from the meeting was positive and we felt confident that, based on our experience, the EPA would follow through as promised.
Since then, I have attempted to remain in contact with James Bryson to get a commitment from him for a date by which NARI would receive the answers to our list of questions. Despite my numerous attempts to do so, I was never able to get a commitment from him. Eventually, he stopped answering my e-mails and did not return any of my calls. I eventually contacted Nancy Barmakian, Manager of Toxics & Pesticides Technical Unit and the person overseeing the Boston office's efforts regarding the RRP. On March 18th, she did respond to let me know that our questions were forwarded to Washington and would be added to the list of questions the EPA has been receiving from other entities around the country as well. She said the EPA planned to post at least some of the questions on the FAQ section of the EPA website and she would let me know when they were posted. As of writing this, I have not heard back from her.
The EPA and the RRP program are plagued with many challenges. It has become obvious to many who are at the forefront of digesting this rule that the EPA was extremely shortsighted in regard to the completeness and practicality of the regulations contained in the rule as well as the realities that contractors are faced with in the field. The EPA is extremely short staffed, limiting their ability to keep up with marketplace awareness and implementation of this rule. The rule, regulations and work practices are extremely ambiguous and or lacking of clarity. The employees at the Boston EPA office wait for answers from the Washington EPA office and at the same time the Washington office waits for interpretation from their legal counsel so the contractors and the public can get answers. As of writing this, seven weeks have passed since submitting our questions; only two are addressed in the FAQ section on the EPA website.
In an effort to help remodelers, I will be including a FAQ section on my website as a way to collect and answer questions related to the RRP rules. This new area on my site should be up within the next 10 days. For now, you can go to the EPA RRP Info page of my site for helpful information and links related to the rule. I apologize for not having better news. Be assured that EM NARI has been trying to stay on top of this matter and will advise the membership of new information as it becomes available. As part of our efforts to do so, Greg, Mark and I will be attending a public hearing on Wednesday afternoon prior to the March NARI Membership Meeting. At this hearing the Massachusetts Division of Occupational Safety (DOS) will be seeking comments on its intent to seek authorization from the United States Environmental Protection Agency (EPA) to administer and enforce the RRP Program in Massachusetts. Greg will be able to share what we learn at the hearing with the membership at the Chapter's monthly meeting on Wednesday March 3rd.