You have failed misearbly to roll out the existing ruling for the RRP rule for present target housing. Failed to conduct this on a fair a level playing field across the board. You have ruined the small contractor livelyhood and economy for those of us that comply in an already flailing economy. You have under estimated the cost to comply for the contractor and consumer.
You have failed to notify the public and contractors about the RRP rule in a wide spread manner in advance of enforcement. In regards to epa cerification, compliance and enforcement. It has been so poorly dipsersed to the public and contractors that most homeowners have never heard of the RRP rule and look at you like your crazy when it is brought to their attention.
They say "no one else said anything else about it"
So many contractors are not complying with the rule and thus we lose most of the pre1978 housing business!. Not to mention you have unfairly singled out California as the only or one of the only states where the contractor is not alowed to test. Very poorly instituted!! As a contractor i am suffering from the EPA and state of california implimentation and surrounding policies on this matter. Fix it quick please, your ruining us.
My recommendations would be to first back up the law to a year where the levels may be more prevalent. Most 1977 homes do not seem to pose a lead hazard. Second do a widespread campain on television and radio to inform everyone that this is the new standard in residential work and all must comply. 3rd- Be fair across the nation!! Allow contractors to use approved test kits for the initial presense of lead and asbestos rather then make the customer pay costly fees of over 400 just to test and more to comply. This is what I am experiencing as a result of this and as a contractor for 30 years these are my honest comments. Make it better please so we can survive.
Anonymous public comment
This is comment on Proposed Rule
Meetings: Lead; Renovation, Repair, and Painting Program for Public and Commercial Buildings
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