2014 RCCP Survey Results
In 2014, Boston University students and the RCCP created a survey for lead experts and interested parties to see if consensus could be discerned concerning what states ought to be doing to make the best use of the opportunity presented by the promulgation of EPA’s Renovation, Repair, and Painting Rule. This rule requires that anyone who is compensated for work that disturbs over minimum amounts of surface area in pre-1978 housing or “child-occupied” facilities must implement lead-safe work practices.
Here is the survey in a PDF: 2014 RCCP Lead Survey or to take it yourself:
The responses that we received can be found here: 2014 Survey Responses. (Please note that this report has been adjusted to protect the identities of the respondents.)
We took the rankings of the experts of the importance of program components that had been included in the original queries made to states, and used them to produce comparative weightings of the responses of the states. A graphic presentation of the results of this, showing which states told us they are implementing these features, judged most important by experts, can be found here.
Here are some interesting results that we wanted to highlight:
49 experts completed the survey:
Actions were divided into 4 sections: 1) actions pertaining to outreach toward the regulated community, 2) actions pertaining to outreach toward the public/relevant facilities, 3) actions pertaining to enforcement of the RRP Rule, and 4) actions pertaining to lead testing. Experts were asked to rank each action on a 5-point scale of: not necessary, not as important, important, very important, and absolutely necessary. Here are the two highest ranked actions (by mean) per category:
Experts were also asked to select one action per category that they deem the most important. Here are the results:
Experts were asked for other comments and any important aspects of a successful and effective state program that were not previously mentioned. Here are some comments of highlight:
One expert said, “Most states have promulgated sensible regulatory standards governing work procedures which may affect hazardous materials including lead paint in industry and in construction which may also may cause a personal exposure potential. The main trouble which causes these regulations to be ineffective is the current lack of enforcement. Enforcement of the laws that we currently have in place is the primary issue this country faces in the protection of public health and the environment.”
Another expert said, “There is not enough enforcement, so many contractors are not following the rule and/or are not getting trained because their chances of getting caught are very, very low. If contractors know a program is being actively enforced, fines being issued, etc., it would make RRP more of a concern for them.”
Other experts mentioned these aspects:
–funding for improving housing conditions and for evaluating and correcting lead hazards
–experienced staff and in-house legal support
–in the absence of universal testing, an empirically validated targeted testing plan must be in place along with a strong professional educational component
–congruence and good communication between abatement regulators and childhood poisoning offices
Finally, experts were asked what actions the EPA should take to improve the RRP Rule. 16 out of 39 comments mentioned enforcement, 9 out of 39 mentioned funding, and 6 out of 39 mentioned education/outreach.