Lots of drama on the EPA Renovators Rule implementation. The rule took effect, as scheduled, on April 22nd, in spite of protests about capacity and public confusion over the “opt-out” provision. EPA made a case that there was plenty of training available, using statistics from trainers and firm certification applications to demonstrate thet there are about 100,000 qualified Renovators in place. We can certainly support that claim, given the number of folks that we’ve seen in our courses. We’ve trained about 6,000 individuals in the last six months or so.
The Agency also set July 6, 2010 as the effective date for the elimination of the opt out provision. Here’s a quote from the Federal Register: “EPA is eliminating the ‘‘opt-out’’ provision that currently exempts a renovation firm from the training and work practice requirements of the rule where the firm obtains a certification from the owner of a residence he or she occupies that no child under age 6 or pregnant women resides in the home and the home is not a child-occupied facility.”
EPA also released a couple brand new items, including provisions for dust sampling at the conclusion of high hazard projects, in 2011, and requirements to apply lead-safe work practices to renovations on public and commercial buildings, sometime after 2014. The Agency is looking for comment on both of these notices, and the public is encourage to submit comments by July 6, 2010. Check out www.epa.gov/lead for more detail.
Things really got interesting again in May, when the US Senate voted to withhold enforcement funding for the rule, a measure that was largely symbolic, since EPA had previously stated that they would be focusing on “compliance assistance” instead of enforcement for 2010. Nonetheless, EPA responded with their own “Enforcement Guidance” on June 10, 2010 which extended the enforcement deadline for RRP firm certification requirements until October 1, 2010 and permitted Renovators who have not completed training to register for training by September 30 and complete training by December 31, 2010 without fear of EPA enforcement actions. I’m told that the folks at EPA who actually run the RRP program found out about the extensions at the same time as the general public, much to their dismay.
Mark Twain said “the reports of my dealth are greatly exaggerated”, in response to a comment in 1897 by President Howard Taft. Similarly, the Renovators rule is alive, healthy and on course for implementation.
Toward that end, EEA is please to announce that we have been approved to offer the RRP initial on-line. We’ll have a link at our website in place in the near future that will allow folks to complete the “first half” of the RRP initial training on-line and the attend a 2.5 hour hands-on session and course completion test. Look for that at www.environmentaleducation.com in July.
Have a great summer.
Andy McLellan
Andy
Organizations across the country have begun the process of identifying properties and training individuals who will find career opportunities as building analysts and weatherization technicians. This initiate has a tremendous upside, beyond creating jobs and cutting homeowner expenses for heating fuel, which includes creating new business opportunities for suppliers and contractors and, lest we forget, reducing carbon emissions and the threat of significant global warming. You just can’t argue with that.
Consider, nonetheless, the effect that the simple acts of sealing up leaks in the building envelope and replacing windows and other aspects of the building system that often occurs for weatherization. Inhabited residential structures should exchange indoor air at a rate of two air changes every hour, or once a half hour. Ventilation does many wonderful things, not least of which is creating air movement that dries up wet surfaces and expels contaminated, stale air. Allergens and contaminants like mold, tobacco smoke and even carbon monoxide can build to unacceptable levels over an extended period and create serious health hazards for those living in the house when proper ventilation is not established.
Similarly, renovation activities to replace HVAC systems may lead to an unintentional release of asbestos while any disturbance of a building component painted before 1978 could result in lead based paint hazards. Often new building products, like pressed wood and carpeted, can contain contaminants like formaldehyde and volatile organic compounds (VOCs) which can be troublesome in houses that are too “tight”
Fortunately, these unintended consequences can be avoided. Proper understanding of ventilation and assessment of potential hazards is critical to ensuring that this latest “green revolution” creates a permanent change that leads to improved health and environmental outcomes for all Americans. In fact, the push for green housing presents a wonderful opportunity to integrate consideration for healthy homes into housing maintenance, improvement and renovation.
Great things are underway; let’s not let ignorance spoil the success.
Andy McLellan
