DES PLAINES, ILL. — Since implementation of the EPA’s Lead Renovation, Repair and Painting (LRRP) Rule in April 2010, the National Association of the Remodeling Industry (NARI) has been following the effect the rule has had on consumer behaviors and buying habits for renovations in older homes.

EPA announced it would not impose lead dust clearance as an addendum to LRRP.

According to the EPA, “After carefully weighing all available information and considering the public comments, EPA has concluded it is not necessary to impose new lead-dust sampling and laboratory analysis, known as the clearance requirements, as part of the Lead Renovation, Repair and Painting (LRRP) rule. The Agency believes that the existing lead-safe work practices and clean up requirements -- which went into place in 2010 -- will protect people from lead dust hazards created during renovations jobs without the need for additional clearance requirements.”

Lead clearance testing would have involved additional costs to pre-1978 projects, resulting in higher overall price tags for projects, and therefore increased the risk to homeowners who chose to do the work themselves or hire non-certified individuals to do the work. Both scenarios have a negative impact on certified remodelers who are unable to stay competitive with homeowner budgets.

NARI applauds the EPA for making the decision to not impose additional costs to LRRP, especially in light of the fact that so many homeowners are unaware of LRRP in general.

According to results of a recently completed survey of homeowners, using Meredith Corporation’s Home Enthusiast Panel, NARI found that 53 percent of respondents were unaware of LRRP. Fifty-nine percent of homeowners responded they would do the work themselves and 29 percent replied they would likely hire a non-certified contractor to work on their home in order to save money.

NARI feels an obligation to document these challenges and recommendations directly from the source—individuals working in the remodeling industry, who are knowledgeable of RRP, and homeowners who live in pre-1978 homes and are impacted by the rule.

To that end, NARI created a working group of members who regularly convened for the purpose of documenting challenges in the application of the LRRP rule. The working group shared its findings with officials in Washington as part of NARI’s efforts in the regulatory reform arena:

Concern #1
The rule application is presented as a "one size fits all" and fails to provide guidance on the varying conditions often found on job sites.
Recommendation #1
The EPA should revise the rule to define the desired outcomes and provide a tool box of options to address varying conditions.

Concern #2
The cost of compliance is driving homeowners to either DIY or hire an uncertified renovator thus defeating the purpose and intent of the rule. Also, the rule does not address the contractor's responsibility when the work of disturbing lead paint has been undertaken and completed by the homeowner or an uncertified contractor.
Recommendation #2
The EPA needs to educate the general public about the rule and assess the impact of homeowner-initiated projects on childhood lead poisoning.

Concern #3
The EPA lacks an effective method of providing updates and information on the rule. The Website housing over 600 FAQs is not a feasible communications tool.
Recommendation #3
EPA and states with oversight should provide a regular newsletter with necessary updates. The Website should be overhauled addressing the topical information needs of the user.

Concern #4
The rule is not clear on the training and certification requirements for subcontractors used by the certified renovator.
Recommendation #4
The EPA should clarify the responsibilities of subcontractors and define a "certified renovator of record" as a single point of contact throughout the project.

Concern #5
The model training program is not consistent with the current rule. Curriculum and materials do not reflect amendments.
Recommendation #5
The EPA must exercise responsibility in properly maintaining training curriculum and material content.

The most recent government census reports there are more than 652,000 remodeling businesses in the United States, and nearly 85 percent (or 552,191) of those businesses are not registered as a certified renovation firm with the EPA.

About NARI: The National Association of the Remodeling Industry (NARI) is the only trade association dedicated solely to the remodeling industry. The Association, which represents more than 8,200 member companies nationwide—comprised of 63,000 remodeling contractors— is “The Voice of the Remodeling Industry.”™ To locate a local NARI chapter or a remodeling professional, visit NARI’s Web site at, or contact the national headquarters, based in Des Plaines, Illinois, at 800-611-NARI.

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