In the Wednesday August 24th edition of the Remodeling Daily Update, we linked to an article on FineHomebuilding.com that discussed the EPA’s RRP Rule and if it was applicable to detached garages. The article concluded that the rule does not apply to detached garages.
However, it was pointed out in the comments section of that same article by remodeling industry expert Shawn McCadden that the RRP Rule actually does apply to detached garages. This clarification is not in the RRP Rule as written but rather on the FAQ section of the EPA’s website, an area that has gotten so large that, according to McCadden, it has more text than the actual rule.
According to McCadden, he originally interpreted the rule to mean the same thing as Holloway and scores of other experts and says that the real problem is how vague the RRP Rule is that it allows itself to be open to interpretation—and misinterpretation—by professionals in the contracting and remodeling industry. “But the challenge we’re up against is it doesn’t matter what we as contractors decide is the interpretation, because it’s entirely up to the government to decide,” he says. “The bottom line is contractors need to know exactly how the EPA is going to interpret this stuff to keep themselves out of trouble and away from fines.”
Since the EPA’s RRP Rule was published in April 2010, there have been so many questions about how to interpret it that the FAQ section on the EPA’s website has flourished and has become, essentially, the “go to” authority whenever anyone has a question as to how actually to put the rule into practice. “Read the rule but defer to the FAQ section for actual interpretations before you make assumptions,” McCadden says, while also warning against the vast wasteland that can be the internet: “Don’t believe at all what you see on the blogs or in the discussion groups. It’s mostly banter or armchair lawyers, people who think they know what it means, or somebody told them and now they’re taking it as fact.”
For more contractor-friendly explanations of the RRP Rule, check out www.RRPedia.com.