EPA postpones LRRP for commercial work

On August 24, 2009, EPA entered into a settlement agreement with several litigants that challenged the 2008 Renovation, Repair, and Painting rule. Under this agreement, EPA agreed
to sign a proposal to regulate renovations of public and commercial buildings by September 14, 2012) and to take final action by February 15, 2014.

On September 7, 2012, EPA and the litigants revised the previous agreement and set a deadline of July 1, 2015, to issue a proposal, unless EPA determines that such renovations do not create a lead-based paint hazard, and to take final action in January 2017.

NARI’s testimony before the House Small Business Committee was instrumental in the EPA’s decision. Watch NARI Government Affairs Chairman David Merrick, MCR, UDCP’s, testimony (19 minutes in) on YouTube.

NARI sent the letter below to EPA Administrator Lisa Jackson in support of this decision.

September 21, 2012

The Honorable Lisa Jackson
Administrator
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Dear Administrator Jackson,

On behalf of the National Association of the Remodeling Industry (NARI), I am writing to applaud your decision to properly assess the potential lead paint risks from construction at public and commercial buildings before adopting new Lead Renovation Repair and Painting (LRRP) rules.

NARI is a non-profit trade association based in Des Plaines, Illinois.  We have 58 Chapters in major metro areas nationwide and our membership of 7,000 companies is comprised of remodeling contractors, local suppliers, and national suppliers.  Eighty-three percent of NARI members have fewer than 20 employees and many are 1 or 2 man operations.  NARI’s core purpose is to advance and promote the remodeling industry’s professionalism, product and vital public purpose.  NARI members voluntarily subscribe to a strict Code of Ethics which NARI rigorously enforces.

We consider ourselves partners with the U.S. Environmental Protection Agency (EPA) in trying to prevent lead poisoning because of our concern for the safety and comfort of our customers’ families and for our employees.  NARI takes its responsibility as a professional organization very seriously, and we are proud of our history of educating remodelers on lead paint hazards.  In fact, NARI worked with the U.S. Department of Housing and Urban Affairs (HUD) to run a lead paint training program in 1998.  Curriculum NARI developed for that program continues to be used today and NARI remains dedicated to training remodelers in how to ensure their customers and their employees are not harmed from lead paint.

NARI believes that the best way for EPA to address lead paint hazards from construction activities is for the agency to focus on situations that present the greatest risk.  That is why we have continually pressed for stricter enforcement against non-certified remodelers.  We have also encouraged EPA to educate homeowners so they understand the importance of hiring certified remodelers and to discourage do-it-yourselfers from creating lead-paint hazards that could potentially harm themselves and their loved ones.

Issuing new LRRP rules without closely examining whether construction activities at public and commercial buildings pose a risk would drive up construction costs and would over-burden agency resources without necessarily protecting pregnant women and children under six from lead paint hazards.  Your decision to put off imposing new LRRP rules so that EPA can properly assess risks from construction activities in public and commercial buildings is a positive step in re-focusing your limited lead poisoning prevention resources towards the greatest risks.

We will continue to work with your agency to meet our mutual goal of protecting young children and pregnant women from the hazards of lead paint from construction activities.  Thank you for your consideration and please do not hesitate to contact me if you have questions about this letter or about NARI’s position on EPA’s LRRP program.

Sincerely,

Mary Busey Harris, CAE
Executive Vice President

Cc:       The Honorable Cynthia Giles, Assistant Administrator, Office of Enforcement and Compliance Assurance

The Honorable Jim Jones, Assistant Administrator, Office of Chemical Safety and Pollution Prevention

| 9/24/2012 12:00:00 AM | 1 comments
Add Blogs to RSS FeedAdd Blogs to RSS Feed

Recent posts

No recent posts

Post archive

June 2022(2)
May 2022(2)
April 2022(2)
March 2022(3)
February 2022(1)
January 2022(5)
October 2021(2)
August 2021(3)
July 2021(1)
June 2021(2)
May 2021(1)
March 2021(2)
February 2021(1)
December 2020(1)
November 2020(2)
October 2020(2)
September 2020(3)
July 2020(3)
May 2020(2)
March 2020(2)
January 2020(2)
November 2019(1)
October 2019(4)
September 2019(3)
August 2019(3)
July 2019(5)
June 2019(3)
May 2019(5)
February 2019(3)
January 2019(3)
December 2018(1)
November 2018(3)
October 2018(2)
September 2018(3)
August 2018(3)
July 2018(4)
June 2018(6)
May 2018(3)
April 2018(2)
March 2018(3)
February 2018(1)
January 2018(1)
November 2017(4)
October 2017(5)
September 2017(6)
August 2017(4)
July 2017(2)
June 2017(2)
May 2017(4)
April 2017(6)
March 2017(3)
February 2017(6)
January 2017(6)
December 2016(3)
November 2016(4)
October 2016(8)
September 2016(5)
August 2016(3)
June 2016(3)
May 2016(5)
April 2016(4)
March 2016(5)
February 2016(4)
January 2016(4)
December 2015(3)
November 2015(4)
October 2015(9)
August 2015(4)
July 2015(3)
June 2015(7)
May 2015(2)
April 2015(5)
March 2015(9)
February 2015(6)
January 2015(7)
December 2014(2)
November 2014(7)
October 2014(5)
September 2014(3)
August 2014(5)
July 2014(6)
June 2014(7)
May 2014(3)
April 2014(5)
March 2014(8)
February 2014(7)
January 2014(7)
December 2013(6)
November 2013(8)
October 2013(5)
September 2013(4)
August 2013(4)
July 2013(6)
June 2013(8)
May 2013(8)
April 2013(15)
March 2013(6)
February 2013(11)
January 2013(8)
December 2012(6)
November 2012(7)
October 2012(20)
September 2012(14)
August 2012(6)
March 2012(4)
January 2012(1)
April 2011(2)