Comment submitted by Bob Weaver, FCA Painting and Wallcovering Contractors Advisory Committee

As a trade advisory committee representing thousands of contractors across the nation, we follow the current rules regarding the EPA RRP residential program. Most of our contractors that do this type of work are already certified and employ a trained and certified workforce. We are disappointed by the lack of enforcement with the current laws and feel this puts an unfair burden on those contractors that are in compliance. Additionally, protections for whistleblowers should be part of any enforcement policy.
In regards to expanding these rules into commercial projects, our concern is on the implementation and enforcement rather than the rule itself. We believe that the responsibility for initial testing on a commercial project should fall on the property owner and General Contractor. The findings should be part of the bid documents along with a lead plan showing where there is lead and what needs to be done, putting all bidders on an even field.