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.