The U.S. Environmental Protection Agency (EPA) plans to survey general contractors regarding their recent renovation, repair and painting (RRP) activities in public- and private-sector commercial buildings. AGC worked with the “Commercial Properties Coalition” to provide comments on the scope and clarity of the questions included in EPA’s draft Information Collection Request (ICR), as well as its underlying assumptions and burden/cost estimates. EPA admittedly needs more data on whether or not RRP activities in buildings expose the public to lead-based paint (LBP) dust. EPA must first determine that such activities create lead paint “hazards,” before the agency has the legal authority to write additional rules that would apply to building contractors.
AGC’s comments focus on the following:
- The survey, as drafted, would not produce useful information because it would collect baseline data on RRP activities and work practices disconnected from whether “dangerous levels of lead” exist in the commercial real estate stock. AGC has recommended that EPA restructure the survey to begin with a question on whether a property is known to contain lead paint; if the response indicates the answer is no, the survey should be terminated.
- EPA should minimize the response burden on the public by first gathering information through outreach and coordination with federal government building owners and managers.
- The draft survey is not likely to produce “statistically valid” data or data that is representative of standard industry practices. EPA should improve upon its sampling techniques and questionnaire instruments in order to generate data of “practical utility.”