Small Business Advocacy Review Panel (SBAR)
In an effort to reduce lead-based paint exposure from the renovation, repair, and painting of public and commercial buildings, the Environmental Protection Agency (EPA) announced in April that it will be teaming up with various small business owners while deciding on future policies involving lead paint. The small business owners will be consultants as a part of the Small Business Advocacy Review Panel and membership will be comprised of self-nominated members from small businesses, small governments and other small organizations.
The SBAR will include representatives from:
- The Small Business Administration (SBA)
- The Office of Management and Budget (OMB)
- The Environmental Protection Agency (EPA)
It will also include several Small Entity Representatives to consult on the “impacts of a proposed rule on small entities involved in the renovation, repair, and painting of public and commercial buildings.”
SBAR’s creation is a result of possible extensions being considered to the Lead Renovation, Repair and Painting (LRRP) program.
What is the LRRP?
The LRRP program was passed in 2008 and amended in 2010. Its goal is to “protect the public from lead-based paint hazards associated with renovation, repair and painting activities.” In short, any work activities that can stir up lead dust require “workers to be certified and trained in the use of lead-safe work practices, and requires renovation, repair, and painting firms to be EPA-certified.”
The LRRP was originally aimed at residences and public housing, but in May of 2013, the EPA considered expanding the program to all public and commercial buildings. The organization has not yet ruled on if it will expand the program and says it will make a judgment by July 2015. Commercial contractors and others across the industry are nervously awaiting the EPA’s decision as the financial impact of this ruling could be monumental due to the potential hike in costs associated with seemingly simple renovations and repairs. This is the reason why the EPA has decided to include so many different organizations and businesses in the process: the impacts of the proposed expansion will be tremendous and will affect businesses at all levels.
What’s Covered in the Proposed Expansion?
The EPA will debate the issue of renovation, removal and repair from two different angles:
(1.) Interior Renovations can impact individuals who are indoors during window replacement, carpet removal, heating ventilation and cooling (HVAC) replacement, demolition, and other actions.
(2.) Exterior Renovations can impact the outdoor ground soil, where people could be exposed to dangerous chemicals either outdoors or in the event that they are tracked back indoors during work or after.
What’s It All Mean for Contractors?
Consistent with the Regulatory Flexibility Act, the SBAR will be a helpful advocacy group for the EPA and small businesses. Far too often, new rules and regulations are introduced by the government that have unintended consequences. Such is often the case when policies are put in place that are directed at regulating and checking big businesses, but end up having an adverse impact on small businesses. With the experience and insight of small business owners at the EPA’s disposal, this should help to prevent the introduction of rules that will unnecessarily harm small businesses.
With the EPA’s decision on the matter still over one year away, it will be business as usual in construction, real estate, and all other relevant fields. But in the meantime, there will be many anxious contractors wondering how they might end up being affected.
Learn more about safe and lawful lead paint removal.