No one disagrees that we should do everything we can to eliminate the health risks associated with lead exposure in residential buildings. But how do we know what the risks are without accurate testing?

This has been one of the greatest points of contention between the fenestration industry and the Environmental Protection Agency (EPA) since the Lead: Renovation, Repair, and Painting Rule  rule (LRRP) was last modified in 2011, making it mandatory for all residential buildings built before 1978 be tested for lead paint.

Without accurate field test methods, renovations – including window replacements – are likely being delayed because of the high potential cost of remediation. That’s why over the last five years, the Window and Door Manufacturers Association (WDMA), individuals and other industry organizations have worked tirelessly to get the opt-out clause reinstated.

And that work might finally be paying off.

610 Review Issued by EPA

A 610 review is issued by government agencies, such as the EPA, to help determine “…if provisions of a rule that are related to small entities should be continued without change, rescinded, or amended to minimize adverse economic impacts on small entities.”

On June 9, the review process was initiated to take another look at LRRP. During the review, the EPA will solicit comments from a Small Business Advisory on the following factors:

• The continued need for the rule itself
• The nature of complaints/comments received
• The rule’s complexity
• Overlap with other Federal, State or local rules
• New technologies or changes in economic conditions related to the rule

This review will also serve as an additional opportunity to provide comments on lead test kits, field testing alternatives and other broader LRRP rule concerns.

The View from Here is that the upcoming 610 review is no guarantee that we’ll see positive change, but it’s certainly a step in the right direction. I’m anxious to see how this unfolds.
What’s your View? Contact me directly at Eric.Jackson@Quanex.com.

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