AAMA responds to EPA call for comment on LRRP regulations.
Press Release Summary:
Responding to EPA's call for comments on existing regulations, AAMA provided comments and information regarding economic impact of EPA's 2010 implementation of the Lead: Renovation, Repair and Painting regulations and amendment to "opt-out" provision. AAMA questions EPA's decision to move forward on this rule based on limited and questionable scientific data; dichotomy of CDC research; and continued use of lead test kits that do not meet EPA false-positive criteria.
Original Press Release:
AAMA Responds to EPA Call for Comment on LRRP Regulations
Schaumburg, Ill. -- On March 18, 2011, the American Architectural Manufacturers Association (AAMA) responded to the Environmental Protection Agency's (EPA's) call for comments on existing regulations. The EPA request was made following the issuance of Executive Order 13563, which seeks to identify regulations that are economically damaging, impede job growth and impact the opportunity to enhance energy efficiency. AAMA provided comments and information regarding the economic impact of the EPA's 2010 implementation of the Lead: Renovation, Repair and Painting (LRRP) regulations and amendment to the "opt-out" provision.
Rich Walker, AAMA's president and CEO, states that "the AAMA response questions the EPA's decision to move forward on this rule based on limited and questionable scientific data; the dichotomy of CDC research, which clearly exhibits a rapid and continuous decrease in blood lead levels during the same period of increased pre-LRRP home renovation activity; the continued use of lead test kits that do not meet the EPA, September 1, 2010, required false-positive criteria; and the severe economic burden of increasing the original LRRP cost to $1.3 billion."
Walker also reports that AAMA questions the EPA's ability to properly monitor compliance activity on the 7.2 million renovation events it suggests will occur during the first year of implementation and the subsequent 5.4 million events where test kits will exhibit a positive result and LRRP practices are mandated.
Across the country, renovators who have paid for the required EPA training and certification credentials and who comply with the costly LRRP procedures continue to compete with non-compliant renovators who do not carry the same cost burdens. Walker reports that this has led to the foreseeable industry divisiveness the EPA was warned about by the Small Business Advocacy review panel and many others in the industry during the comment period.
Walker stated that "the removal of the opt-out clause continues to impede the recovery of the residential fenestration industry by passing along significant and, at times, unwarranted renovation costs to homeowners. It is vital that the EPA understands the full impact that these regulations continue to have on the building products industry as well as the construction industry as a whole."
If you would like to express your support of AAMA's comments, please submit your comments on the LRRP "opt-out" amendment directly to Regulations.gov and your Congressional Representatives, or write a brief note on company letterhead supporting the comments submitted by AAMA, attach it to the AAMA correspondence and submit the document in its entirety to Regulations.gov. Comments must be received by April 4, 2011. If you need any additional information or guidance in submitting information, please contact Maureen Knight at mknight@aamanet.org.
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