WASHINGTON - The Window and Door Manufacturers Association (WDMA) has submitted extensive comments to the Environmental Protection Agency (EPA) strongly urging the agency to fix the significant ongoing problems with implementation of the Lead: Renovation, Repair, and Painting Rule (RRP Rule). WDMA submitted the comments in response to EPA initiating a review of the RRP Rule in accordance with requirements under the Regulatory Flexibility Act (RFA).

In the comments, WDMA is providing EPA with a number of recommended actions WDMA believes the agency needs to take to finally resolve those implementation problems. The recommendations address the continued lack of compliant lead-paint test kits required by the RRP Rule, removal of the "opt-out" provision from the original rule, and undue enforcement actions for first-time paperwork violations, among others.

WDMA Senior Vice President of Advocacy Jeff Inks said, "The recommendations we are making address significant problems with the rule's implementation that have emerged and persisted, without resolve, since the rule became effective in 2010. We hope that EPA fully considers WDMA's recommendations and takes advantage of this RFA review to follow them."

As part of the RFA review, WDMA was invited by the Small Business Administration (SBA) to represent the window and door industry at a roundtable discussion with EPA, hosted by the SBA. WDMA directed a number of questions to EPA regarding the Rule and the RFA review, including the scope of the review and relevant timelines. EPA expressed enthusiasm to review WDMA's written comments.

In addition to WDMA's RFA review recommendations to EPA and roundtable discussion, the association continues to put the window and door industry's concerns about implementation of the RRP Rule in the spotlight. In other efforts, WDMA has worked with Congress to introduce legislation to make necessary reforms to the RRP Rule's implementation, as well as successfully advocating for language in Congressional appropriations bills requiring EPA to address critical issues, in particular lead-paint test kits.

WDMA expects EPA to evaluate the association's written comments and issue its final report on the RFA review sometime early next year. For a copy of WDMA's written comments, contact WDMA Director of Government Affairs Kevin McKenney at 202/367.2480 or kmckenney@wdma.com.