What could an extension of the LRRP program to commercial buildings mean for contract glaziers?

Last April, the Environmental Protection Agency enacted the Lead Renovation, Repair and Painting Rule requiring contractors that perform renovations and repairs—including window replacements— to pre-1978 homes, childcare facilities and schools be conducted using lead-safe work practices. Now, the EPA is looking to extend the LRRP program to public and commercial buildings as well.

Gil DiMaio, president and CEO of CBO Glass, Alden, N.Y., and a member of the McLean, Va.-based National Glass Association's Architectural Glazing Committee, has been selected to serve as a small entity representative on the EPA's Small Business Advocacy Review Panel. Sahely Mukerji, senior editor, Glass Magazine, talked to Dimaio about how the extension of the LRRP program to the commercial sector could affect contract glaziers.

In your opinion, what are the chances that the EPA will extend the LRRP rules to commercial applications?

I believe there is more than a 50 percent chance that the LRRP rules will be extended to commercial applications.

How would such an extension affect contract glaziers, and the glass and glazing industry, as a whole?

In a time with staggering double-digit unemployment across the construction industry, any additional regulations [that] add costs and time to new public and commercial projects will have an impact. While the focus must always be on safety first, in my opinion, a thorough review of existing lead-safe work practices and enforcement is the first best step before the enactment of new and costly regulations.

There very well could be a 5 percent to7.5 percent cost impact, specifically related to training, additional PPE [personal protective equipment] and containment, not to mention the additional administration requirement, which also costs money. Clearly, if there's evidence that workers and/or the public are being exposed to lead poisoning because the existing regulations are not protective enough, then by all means, we need this. Safety is first. But we don't know that yet, and that'll certainly be a discussion point.

My goal, first and foremost, is to determine the reason why the regulation and procedures would need to change, and then be an advocate for the least intrusive and least [expensive] approach. As an SER, the EPA expects written feedback from the meetings, which I am committed to do. I will report to the NGA Architectural Board.

Please describe your role on the advisory panel.

As an SER, I will provide advice and recommendations that will be based on safe, yet pragmatic, cost-effective means and methods for lead-based materials abatement.

My question to the EPA and other representatives is what has changed that will require possibly more stringent regulation in this field? I can see in an environment where we are dealing with childcare or within homes, but in commercial construction? What's the driving force behind that? That's my starting point.