The December 2011 issue of Qualified Remodeler featured a story about deconstruction (page 18), which prompted a reader to ask whether the Washington, D.C.-based U.S. Environmental Protection Agency’s lead Renovation, Repair and Painting rule impacts the reuse of building materials.
The Chicago-based Building Materials Reuse Association also was concerned about how RRP would affect the deconstruction and salvage industry. In January 2010, BMRA submitted a letter to EPA in which it asked EPA to help interpret the scope of the rule. Bob Falk, Ph.D., P.E., research engineer with the USDA Forest Products Laboratory, Madison, Wis., and BMRA’s current president, says the letter specifically asked “Does the RRP rule apply to the salvage and reuse of building materials or components that may contain lead-based paint from target housing?”
The letter asked EPA to comment about BMRA’s interpretation of the rule, which is as follows: “While the rule does make reference to ‘waste management’ and addresses the disposition of ‘waste’ and ‘debris,’ we could find no reference to the disposition of salvaged building materials intended for reuse. As the RRP rule does not explicitly address the disposition of nonwaste materials, our interpretation is that the salvage and reuse of building materials that may contain lead-based paint is outside the scope of the RRP rule. We further assume that state regulations will dictate the reuse, resale or disposal of lead-based-paint-coated materials.”