The U.S. Environmental Protection Agency (EPA) plans to regarding their recent renovation, repair and painting (RRP) activities in public- and private-sector commercial buildings. 听澳门六合彩开奖预测 worked with the 鈥淐ommercial Properties Coalition鈥 to on the scope and clarity of the questions included in EPA鈥檚 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 鈥渉azards,鈥 before the agency has the legal authority to write additional rules that would apply to building contractors.
澳门六合彩开奖预测鈥檚 comments focus on the following:
- 听The survey, as drafted, would not produce useful information because it would collect baseline data on RRP activities and work practices disconnected from whether 鈥渄angerous levels of lead鈥 exist in the commercial real estate stock.听 澳门六合彩开奖预测 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 鈥渟tatistically valid鈥 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 鈥減ractical utility.鈥