Home Inspectors are specified in the LRRP Rule

[Tom Raymond]

In another thread I was questioning whether we as inspectors were subject to the EPA LRRP rule. Further research has uncovered that we are in fact specifically mentioned, albeit backhandedly, in the adopted document. I thought it important enough to warrant a new thread so that it wouldn't be missed.

The NAICS definition of Building Inspection Services: http://www.naics.com/censusfil...#N541350

The EPA Rule: http://www.epa.gov/lead/pubs/L...4-22.pdf

See page 4 for the specific reference to Home Inspectors (Building Insepction Services).

I have no idea what that means as far as compliance with the rule since we don't actually disturb any painted surfaces, but at a minimum I would think we could be required to comply with the distribution and documentation of the Renovate Right propaganda literature.

Tom

[Tom Raymond]

I just fired off an email to the EPA TSCA Hotline for their position on how this Action affects inspectors. I'll post their reply here.

Tom

[Scottpat]

Tom, those links are not working....

[Tom Raymond]

I don't have them here, I'll have to fix them tomorrow.

[Tom Raymond]

The EPA link has been removed as the Action is now available on the edocket: http://edocket.access.gpo.gov/2010/pdf/2010-10100.pdf

See page 2.

This is the definition of the NAICS code referenced;NAICS 541350: Building Inspection Services . This industry comprises establishments primarily engaged in providing building inspection services. These establishments typically evaluate all aspects of the building structure and component systems and prepare a report on the physical condition of the property, generally for buyers or others involved in real estate transactions. Building inspection bureaus and establishments providing home inspection services are included in this industry.

I clipped it from: http://www.census.gov/epcd/ec97/industry/E541350.HTM

It is clear that at some point the EPA intends to include us in this Action.

I'm glad the toxin is just lead, 72 hours and no response yet from the Toxic Substances Control Act Hotline. If it was something really dangerous I could be dead by now.

Tom