NAHB Comments on Lead Paint Rule Change

In January, Environmental Policy Program Manager for the National Association of Home Builders. Tamra Spielvogel submitted a letter to the EPA on their proposed rules of lead-based paint programs; amendments to jurisdiction-specific certification and accreditation requirements and renovator refresher training requirements.

Spielvogel commended and agreed with the agency’s “determination that it would be in the public’s best interest to remove the hands-on training requirement as soon as possible and supports making this change effective”

More from the letter:

NAHB supports EPA’s proposed action to amend the existing regulations under the RRP rule to remove the current hands on training requirements for the EPA accredited certified renovator refresher course. By removing this requirement and providing renovators the option to complete the required training entirely on-line, the Agency will help facilitate wider adoption of an internetbased curriculum that will benefit small businesses like those comprising NAHB’s membership. NAHB’s analysis of EPA’s proposed rule found a potential economic benefit of $45.92 million from removing the hands on training component from the certified renovators’ refresher course.

EPA’s proposal is a positive step that will provide NAHB members and other small businesses with more options to complete the required refresher training course and retain their EPA certifications. However, the time necessary for this amendment to come into effect remains a key issue. In order for EPA’s proposal to have the maximum benefit possible it must be finalized in sufficient time for certified renovators who need to complete the refresher training course prior to the deadline of July 1, 2015 to be able to take advantage of on-line only training opportunities.

NAHB is encouraged by EPA’s acknowledgement that finalizing the proposed rule in a timely fashion is critical to ensuring the estimated 200,000 certified renovators will benefit from the flexibility provided by the proposed rule. Recognizing the importance of finalizing the rule prior to the deadline, EPA included two specific actions that NAHB would like to highlight.

  • First, NAHB concurs with the Agency’s determination that it would be in the public’s best interest to remove the hands-on training requirement as soon as possible and supports making this change effective upon publication of the final rule in the Federal Register.
  • Second, NAHB commends EPA’s suggestion in the preamble to provide a 6 month extension for renovator certifications that expire by July 1, 2015. Extending the deadline is a good first step in mitigating the concerns NAHB previously raised regarding the rapidly approaching recertification deadline. The extension will help ensure that as many certified renovators as possible can take advantage of the burden savings provided by the streamlined requirements of the proposed rule.

From the NAHB Remodeler’s Counsel News.
To view the rest of the letter please visit:

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