Opportunity to Discuss RRP Rule with MA and EPA Officials
The RRP Rule has certainly changed the game for remodelers and remodeling consumers. I have met with EPA officials in the past to discuss challenges within the rule itself and the challenges created by EPA for those business that are abiding by the rule due to the lack of any serious enforcement to date against violators. So far, trying to work with EPA has been very frustrating. Little has been accomplished. As a result, the underground economy in remodeling has grown, making it difficult for legitimate businesses to compete against it. This is also in effect poisoning more children as home owners choose to hire non-certified workers who are not using lead-safe practices and or are doing the work themselves without the use of lead-safe practices
On the other hand, since taking over the RRP Rule in MA, working with MA state officials has been much more productive. The Massachusetts Department of Labor Standards (DLS), formally called the Massachusetts Division of Occupational Safety, under the leadership of the department's Director Heather Rowe, has been very receptive to meeting with concerned stakeholders, hearing and recognizing stakeholder's concerns, and working with stakeholders to address their concerns. Currently, in addition to working on amendments to the RRP regulations in MA to address concerns, the DLS is also finalizing their plans to step up enforcement and compliance actions this spring as the home improvement season begins. Is it happening as fast as we all might like, no. However, based on budget and resource realities, I think DLS is doing a good job listening and prioritizing their efforts.
As one way to continue their efforts and interact with stakeholders, the Massachusetts Department of Labor Standards is looking for additional input from contractors and lead industry practitioners in anticipation of making amendments to the MA RRP regulations. An official from this agency will be participating in a May 18 workshop on the RRP Rule being held in Marlborough, MA sponsored by the Lead and Environmental Hazards Association (LEHA) and will be discussing the Department’s plans for revising the RRP regulations as well as the Department's enforcement efforts.
Also participating in the workshop will be a representative from the MA Department of Health's CLPPP office who will discuss the differences between deleading authorization/licensing and RRP certification, as well as a representative from the EPA Office of Pollution Prevention and Toxics - the agency responsible for EPA’s implementation of the RRP Rule.
Joining the MA and EPA officials will be industry specialists, including myself and public agency representatives from CT, MA, RI and VT who will address:
- How the Prescribed Work Practices are stifling innovation, lead by Shawn McCadden (Read this for more on this topic)
- Variations between RRP, Federal/State Work Practices, OSHA Worker Safety Rules
- Promotion and Enforcement Strategies, Including the Use of Building Permits
- Delegation of the RRP Rule by New England States
If you are interested in attending the one-day workshop, go to www.rrprule.com for complete agenda, location and registration details. I hope I will see you there.