NAHB is drafting comments on behalf of its members against the proposed rule changes, but it is also encouraging remodelers and other affected industry partners to respond. Comments are due by July 6.
The U.S. Environmental Protection Agency published a proposed rule change to the lead paint rule regulation on May 6 in the Federal Register regarding clearance and clearance testing requirements to the rule.
To better understand the proposed changes, NAHB has prepared “NAHB’s Summary of EPA’s Proposed Rule for “Lead: Clearance and Clearance Testing Requirements for the Renovation, Repair, and Painting Program,” which explains how the EPA’s proposed change to clearance testing effectively blurs the federal regulatory distinction between residential remodeling firms and lead-based paint abatement firms and makes contractors responsible for cleaning pre-existing lead hazards in pre-1978 homes.
NAHB has developed a template letter (available to members only) that members can download and edit in order to submit their comments on the effects of proposed rule change. The web page also includes a separate optional document with paragraphs that may be inserted if members have evidence supporting specific problems.
The letter will be most effective if members tailor it to their specific experiences.
When submitting comments to the EPA, NAHB also suggests that members also send a copy of their comments to their Congressional representative so that Congress also understands the burden the change would have on remodeling businesses.