--- title: Was The RRP Created for the Right Reasons? - Guest Blog description: Guest blog submitted by Ray Douglas to express his opinion about the RRP Rule image: https://www.shawnmccadden.com/hs-fs/file-16117264-jpg/images/ray_douglas-wr.jpg --- [![Shawn McCadden](https://www.shawnmccadden.com/hs-fs/hub/81069/file-1539748069.jpg)](https://www.shawnmccadden.com/) # Welcome to RRPedia Your Interactive Resource for EPA RRP Information ## ![RRPedia logo](https://www.shawnmccadden.com/hs-fs/file-1549005086-jpg/images/RRPedia_Logosmall_-wr-1.jpg)Looking for accurate information about the EPA RRP rule? RRPedia has been created by Shawn McCadden to help remodelers and others affected by the New EPA Renovation Repair and Painting Rule.  ## Please read *[RRPedia Use and Contribution Information](https://www.shawnmccadden.com/using-and-contributing-to-rrpedia-/) *before using or contributing to RRPedia.   --- # You Can Browse For RRP Topics By Using The Tags List To The Right ## [Was The RRP Created for the Right Reasons? - Guest Blog](https://www.shawnmccadden.com/rrpedia/bid/53023/Was-The-RRP-Created-for-the-Right-Reasons-Guest-Blog) Posted by [Shawn McCadden](https://www.shawnmccadden.com/rrpedia/author/shawn-mccadden) on Wed, Jan 19, 2011 @ 06:05 AM - [Tweet](https://twitter.com/share) ## Was The RRP Created for the Right Reasons?   #### **![Ray Douglas](https://www.shawnmccadden.com/hs-fs/file-16117264-jpg/images/ray_douglas-wr.jpg?width=118&height=161&name=ray_douglas-wr.jpg)** #### **One Person’s Opinion:** This is a guest blog submitted by Ray Douglas to express his opinion.  Ray is a remodeling contractor in Brodhead, Wisconsin and has been in business for 34 years. He comments and contributes to RRPedia quite often.  If you would like to express your opinion or offer something of value for RRPedia visitors let me know.         ### **Was RRP Created for the Right Reasons?**   The EPA had good reasons and intentions at first to study the effects and causes of elevated blood lead levels, but the levels of EBLL’s in children ages 6 and under dropped dramatically in years 1997-2007. [Data from the CDC documents the drop.  ](http://www.cdc.gov/nceh/lead/data/national.htm)   ![Drop in EBLL's](https://www.shawnmccadden.com/hs-fs/file-15759985-jpg/images/graph_of_ebll_confirmed_by_year_1997-2007-wr.jpg)   So common sense and logic would say this problem was correcting itself without this new rule.  So what is the reason for RRP? The EPA has been working for years on the effects of remodeling and renovation in connection with EBLL’s.  The EPA’s [Proposed RRP Rule issued on January 10, 2006](http://edocket.access.gpo.gov/2006/pdf/06-71.pdf) describes how some of their research was conducted.   ![Money spent on RRP Research](https://www.shawnmccadden.com/hs-fs/file-16114838-jpg/images/pile_of_money_with_flag-wr.jpg?width=118&height=178&name=pile_of_money_with_flag-wr.jpg)In a document dated December 1998 EPA received a [study](http://www.epa.gov/lead/pubs/finalreport.pdf) that “was funded and managed by the US Environmental Protection Agency.”   I suspect EPA spent millions if not billions of taxpayer dollars on research, studies, the writing of and implementation of the RRP rule. But something happened along the way and EBLL’s in children 6 and under dropped dramatically.  So why did EPA go ahead with the RRP?  In my opinion one of two things happened.  1. EPA didn’t notice EBLL’s were dropping       2. EPA knew the levels were dropping, but had to justify all the taxpayer money they had already spent.  The EPA couldn’t go back to congress and tell them most of the money they spent was a waste because the problem was correcting itself. So what did EPA do?  Create the RRP.  Why?  In my opinion I think it was to justify taxpayer money spent and to create a need for future EPA growth.   A similar situation would be like a department in industry that doesn’t use its entire operating budget in a year.   The next year the budget gets cut (layoffs etc), so the department finds a way to use the money whether it is productive or not, so they don’t have to face a budget cut the following year. Education and public awareness were keys to EBLL’s dropping, but that may have been problematic for the EPA.  If education and public awareness were enough to reduce the problem then the EPA could potentially lose some of its congressional funding.   But by creating RRP, EPA takes a problem that was solving itself---creates regulations to solve it---then those regulations in themselves become a problem----therefore giving EPA a reason for its own existence and more congressional funding. Topics: [Guest Blogs](https://www.shawnmccadden.com/rrpedia/topic/guest-blogs), [Statistics](https://www.shawnmccadden.com/rrpedia/topic/statistics), [Opinions from Renovators](https://www.shawnmccadden.com/rrpedia/topic/opinions-from-renovators), [Health Effects of Lead](https://www.shawnmccadden.com/rrpedia/topic/health-effects-of-lead) [![cs-ye-234x16](https://www.shawnmccadden.com/hs-fs/hub/81069/file-1553381212.gif)](http://www.copyscape.com/duplicate-content/) ### Subscribe to RRPedia by Email and get notified about new postings as soon as they happen! ### Are You Documenting Yor Crew's Compliance With The RRP Rule?  [![download free RRP checklist](https://no-cache.hubspot.com/cta/default/81069/dd6aace9-6cb0-4ad2-a55a-09846d7f5b5e.png)](https://cta-redirect.hubspot.com/cta/redirect/81069/dd6aace9-6cb0-4ad2-a55a-09846d7f5b5e) ### Still Using a Yellow Pad for Your Estimating? 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[Worker Training (15)](https://www.shawnmccadden.com/rrpedia/topic/worker-training) ### I just wanted to say thank you for your efforts to keep us informed.  *"Thank you again for the hundreth time for keeping a vigil on this business nightmare. Your site is one of the best resources we have to stay on level ground"*  **Christian Peter**   *"I am quite impressed with all the confusion out there at Shawn McCadden’s clear and concise voice that continues to help contractors and those involved in this industry truly understand the rule. His efforts should be applauded."*  **Christopher Wagner, LBPFiles**   *"RRPedia is an accurate and contractor friendly interpretation of the very complex and confusing EPA RRP rule"* * * *"Thanks for taking the time to write the blog.  It's about the only place one can go to get some serious info on this dreadful subject"*   *"I would like to begin by thanking Shawn for all of his postings and education that he has been sharing with the remodeling industry. He has personally been extremely helpful in guiding me through various interpretations of the RRP rule, his advice and knowledge are priceless."* **Michael A. Mahoney*** * ### Suggest or Contribute a RRPedia Topic ### Want a Simple Summary of the EPA RRP? #### Shawn McCadden has created an EPA RRP Summary for Remodelers. *"Hi Shawn, **Nice RRP write up on the website.   I've already forwarded a link to it to a number of local builder types."*   #### [Click here to go to the summary.](https://www.shawnmccadden.com/epa-rrp-summary-for-remodelers-by-shawn-mccadden/)  You can also download it if you want your own copy. ### Add this widget to your Web page, blog, or social networking site. A widget is a CDC.gov application that displays the featured content directly on your web page. Click the buttons to see the next tip to prevent lead poisoning.