NAHB is encouraging remodelers and members to submit comments opposing a proposed change to the Lead: Renovation, Repair and Painting rule on clearance testing that, if approved, would essentially require remodelers to become abatement firms when working in homes built before 1978.

NAHB is drafting comments on behalf of its members against the proposed rule change, 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 on clearance testing under the lead paint rule on May 6 in the Federal Register.

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 the proposed rule change. The webpage 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 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. 

For more information, e-mail Matt Watkins at NAHB, or call him at 800-368-5242 x8327.

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