WASHINGTON, DC -- The Window and Door Manufacturers Association (WDMA) has submitted comments to the U.S. Environmental Protection Agency voicing concern about EPA's
potential plans to expand the scope of its controversial Lead: Renovation, Repair and Painting rule (LRRP).
According to the WDMA, the EPA is considering whether to establish additional requirements to ensure that renovation work areas are adequately cleaned after the work is finished and before the areas are re-occupied. WDMA said these additional requirements could include expensive multiple dust wipe tests through EPA-approved labs after renovations are completed and depending on the type of renovation work, ensuring that the renovation work areas meet stringent clearance standards before re-occupancy.
"While we are still greatly troubled by EPA's decision to remove the opt-out provision from the original RRP rule without adequate justification, we are equally troubled by EPA's intent to mandate even more onerous clearance testing requirements, once again we believe without adequate justification and without a proper understanding of potential unintended negative impacts," said Jeff Inks, WDMA vice president of codes and regulatory affairs. "To give a specific example, our members report that the actual cost of window replacement in homes covered by the rule range from $90-$170 per window opening, far greater than the average $35 per job originally and erroneously estimated by EPA. If the proposed additional dust wipe and clearance testing requirements are implemented by EPA, those costs will increase greatly. We're concerned that will further discourage home owners from making energy efficient renovations to their homes which is unfortunate because of the limited benefit we believe the additional testing will provide. We are also concerned about reports that contractors are refusing jobs on pre-1978 homes that must comply with rule because of the significant liability associated with it."
WDMA outlined several other concerns in its comments to EPA, including:
* EPA lacks the authority under the Toxic Substances Control Act (TSCA) to impose dust wipe testing or clearance requirements on renovators;
* EPA's proposal is inconsistent with TSCA because it eliminates the distinction between lead abatement activities and renovation work;
* The cost of the rule would far outweigh any possible benefits; and
* EPA's has failed to provide any data or circumstances to justify the proposed expansion of the lead rules.
The WDMA recently joined with the National Assocaition of Home Builders and other home-related trade groups to file a lawsuit against the EPA's LRRP rule.
potential plans to expand the scope of its controversial Lead: Renovation, Repair and Painting rule (LRRP).
According to the WDMA, the EPA is considering whether to establish additional requirements to ensure that renovation work areas are adequately cleaned after the work is finished and before the areas are re-occupied. WDMA said these additional requirements could include expensive multiple dust wipe tests through EPA-approved labs after renovations are completed and depending on the type of renovation work, ensuring that the renovation work areas meet stringent clearance standards before re-occupancy.
"While we are still greatly troubled by EPA's decision to remove the opt-out provision from the original RRP rule without adequate justification, we are equally troubled by EPA's intent to mandate even more onerous clearance testing requirements, once again we believe without adequate justification and without a proper understanding of potential unintended negative impacts," said Jeff Inks, WDMA vice president of codes and regulatory affairs. "To give a specific example, our members report that the actual cost of window replacement in homes covered by the rule range from $90-$170 per window opening, far greater than the average $35 per job originally and erroneously estimated by EPA. If the proposed additional dust wipe and clearance testing requirements are implemented by EPA, those costs will increase greatly. We're concerned that will further discourage home owners from making energy efficient renovations to their homes which is unfortunate because of the limited benefit we believe the additional testing will provide. We are also concerned about reports that contractors are refusing jobs on pre-1978 homes that must comply with rule because of the significant liability associated with it."
WDMA outlined several other concerns in its comments to EPA, including:
* EPA lacks the authority under the Toxic Substances Control Act (TSCA) to impose dust wipe testing or clearance requirements on renovators;
* EPA's proposal is inconsistent with TSCA because it eliminates the distinction between lead abatement activities and renovation work;
* The cost of the rule would far outweigh any possible benefits; and
* EPA's has failed to provide any data or circumstances to justify the proposed expansion of the lead rules.
The WDMA recently joined with the National Assocaition of Home Builders and other home-related trade groups to file a lawsuit against the EPA's LRRP rule.
Read the Window and Door Manufacturers Association's press release.
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