On Wednesday, August 24, NLBMDA attended an Environmental Roundtable by Small Business Administration (SBA) Office of Advocacy to discuss the Environmental Protection Agency’s (EPA) examination of the Lead: Renovation, Repair, and Painting (RRP) rule under Section 610 of the Regulatory Flexibility Act (RFA). The rule’s significant economic impact on small businesses requires EPA to review it within ten years of promulgation and explore options for reducing compliance costs.
EPA did a short presentation at the roundtable and provided updated statistics concerning the RRP program. At present, there are 91,000 certified firms and 304,000 individual certified renovators. NLBMDA is concerned by comments made by EPA at the meeting that it had no plans to reevaluate the analysis justifying the rule, even though there is now six years of data to evaluate.
NLBMDA plans to submit comments on the Section 610 Review ahead of the comment deadline tomorrow. Inaccuracy of lead paint test kits, removal of the opt-out provision, and in some circumstances requiring certified contractors to do hands-on training to become recertified remain concerns with the program. NLBMDA plans to offer some ideas to streamline compliance while protecting young children from lead exposure.