NAHB Urges EPA to Reevaluate Cost-Benefit Analysis of RRP Rule

Filed in Advocacy, Codes and Standards, Remodeling by on May 2, 2017 0 Comments

Former NAHB Remodelers Chairman Bob Hanbury, CGR, a remodeler from Newington, Conn., Tuesday asked the Environmental Protection Agency (EPA) to reconsider the costs of complying with the Lead Renovation, Repair and Painting (RRP) Rule.

EPA’s hearing on Tuesday, where Hanbury testified on behalf of NAHB, is the first in a series of steps the agency is taking to reevaluate its regulations.

The RRP rule requires remodeling companies and other firms performing renovation, repair and painting projects that disturb lead-based paint in homes, childcare facilities and preschools built before 1978 to have their firm certified by EPA (or an EPA-authorized state program), use certified renovators trained by EPA-approved training providers, and follow lead-safe work practices.

When the rule was finalized in 2008, EPA assured the industry that an inexpensive, accurate test kit would be commercially available by September 2010 so that remodelers could save their clients the additional expenses associated with RRP compliance. The promised test kit is still not available.

“NAHB urges the EPA to conduct a revised cost-benefit analysis that acknowledges a compliant lead testing kit has not come to market,” Hanbury said. “In addition, the EPA should identify ways to appropriately limit the scope of the rule’s coverage, limiting it to specified buildings built before 1960, which have a greater likelihood of containing regulated levels of lead-based paint.”

Because there is no test kit meeting EPA approval, remodelers working in pre-1978 homes must either assume lead-based paint is present or accept the findings of the currently available test kit, which is prone to produce false positive results.

HUD has found that 24% of homes built between 1960 and 1977 contain regulated levels of lead-based paint. This means when renovators assume that lead is present in these homes, it is likely that 76% of the time renovations are in a home never intended to be covered by the program.

The agency will also accept written comments through May 15.

Take advantage of NAHB’s resources to help members understand RRP compliance and recertification requirements.


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