This past June, I wrote about the promising news that the Environmental Protection Agency’s Lead: Renovation, Repair and Painting rule (LRRP) was to be subject to an EPA review in order to determine whether the rule, as written, should be continued, amended or eliminated based on its negative impact on small business.

That review is currently underway, and we’re seeing comments from some important industry bodies convincingly affirm what our industry has felt for a few years now: The rule has had an outsized negative impact on home renovations, and we’ve got the numbers to prove it.

Writing to the EPA in August, the American Architectural Manufacturers Association (AAMA) offered some key statistics that highlight the shortcomings and overall feasibility of the rule. The full comments are worth reading, but some of the most important include:

• Our industry is still without an approved test kit for lead that meets the original criteria of the rule at the proposed cost. Currently, approved kits will test positive for the presence of lead at levels lower than required by the rule, resulting unnecessary additional remediation costs at over $130 per window or more than $5,000 per home.

• When the original rule was written, EPA had assumed that with the availability of more affordable test kits, consumer costs for lead remediation would drop by $200 million in subsequent years. But such kits remain unavailable, and AAMA estimates the added cost for consumers has been in the range of $1.3 billion.

It’s impossible to estimate the number of home renovation projects that have been forsaken due to these restrictive and unnecessary costs. AAMA notes that this is particularly devastating for small-business renovators, who often lack the means to comply with the rule as written. And of course, many homes throughout the United States remain without needed energy-efficiency upgrades.

The View From Here is that the LRRP needs adjustment, not abandonment, and comments from groups like AAMA provide the hard evidence. Reinstating the “opt out” provision, which was eliminated in a 2010 amendment to the rule, is the simplest way to start, allowing homes without pregnant women or young children to forgo unnecessary remediation. Overall, the rule has had a demonstrably negative impact on our industry. And it needs to change.

1 Comment

  1. Thanks, Ric, for acknowledging how difficult this rule has been for our industry and the lack of necessary tools to protect those at risk. As we move forward, the hope is that the EPA review will push towards fewer and more sensible regulations being put into practice. Especially in the realm of the regulations that affect manufacturers, installers, builders and others in our industry, our collective hope is that we are moving into a time when regulations protect both consumers and industry workers without hindering the growth and best interests of businesses.

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