WDMA Critical of EPA's Initial Effort to Expand Lead Rule to Commercial Buildings

WDMA Critical of EPA's Initial Efforts to Expand the Lead; Renovation, Repair, and Painting Program (LRRP) Rule to Commercial Buildings

[Washington, DC] - The Window and Door Manufacturers Association (WDMA), along with a coalition of building industry associations, submitted comments to the Environmental Protection Agency (EPA) yesterday regarding EPA's Advanced Notice of Proposed Rulemaking (ANPRM) to expand its Lead; Renovation, Repair, and Painting Program (LRRP) to Commercial and Public Buildings. This is EPA's first step toward expanding the LRRP beyond residential buildings.

"As we stated in our comments, WDMA and the coalition do not believe that the EPA has the authority under the Toxic Substances Control Act to impose the new regulations they are considering for public and commercial buildings. We also believe that EPA has much more work to do before it can reasonably conclude these regulations are necessary" said Jeff Inks, WDMA Vice President of Codes and Regulatory Affairs. "We're very concerned that these regulations would unduly discourage needed building improvements in public and commercial buildings, especially the replacement of windows and doors, without providing a clear benefit."

The building industry coalition members working together on this issue are: The Real Estate Roundtable; Associated Builders and Contractors; Associated General Contractors; Building Owners and Managers Association International; International Council of Shopping Centers; Institute of Real Estate Management; NAIOP, the Commercial Real Estate Development Association; National Association of Home Builders; National Association of Real Estate Investment Trusts; National Association of Realtors; CCIM Institute; National Lumber & Building Material Dealers Association; Plumbing-Heating-Cooling Contractors-National Association; and WDMA.

In addition to EPA's ANPRM, EPA has announced it will extend the comment

period for its Notice of Proposed Rulemaking (NPRM) for Lead; Clearance and Clearance Testing Requirements for the Renovation, Repair, and Painting Program rule until August 6. Under this proposal, the current regulations would be expanded to require renovation firms to perform more regimented dust wipe sampling after certain renovations including replacement of window and door frames, and for the samples to be tested by an EPA accredited lab. WDMA has similar concerns with respect to EPA's authority to expand the regulations in this way and their substantiation of the need for them. WDMA will be submitting comments on that proposed rule as well. Click here to read the full notice.

Please click here to read the coalition's full comments submitted to EPA.

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Founded in 1927, the Window & Door Manufacturers Association is the premier trade association representing the leading manufacturers of residential and commercial window, door and skylight products for the domestic and export markets. WDMA members are focused on Total Product Performance™ products that are designed and built to performance-based standards. The association is focused on key member needs in the areas of advocacy, product performance, education and information and facilitating business interactions and relationships in the fenestration eco-system. For more information, please visit www.wdma.com.