EPA Rep Gives Lead Paint Enforcement Update
“There are a lot of cases in the pipeline and many others
under review,” said Don Lott, Environmental Protection Agency (EPA) associate
director, waste and chemicals enforcement division, when he presented
updates regarding enforcement of the EPA’s Lead Renovation Repair and
Painting Rule (LRRP). Lott spoke to members of the Window and Door Manufacturers
Association (WDMA) and the National Lumber and Building Material Dealers
Association (NLBMDA) who gathered in March for the their joint legislative
conference. The lead paint rule was a topic in many of the meetings.
But it was in the Lead Rule Issues Panel that Lott outlined particular
aspects of the rule including updates regarding enforcement.
“We have a consistent national approach to how we assess penalties, which
gives an even playing field,” he said.
He added the EPA gives its regional offices general guidance each year
on lead enforcement. “Because they [regional offices] deal with multiple
lead rules we ask the regions to come up with an integrated strategy.”
While Lott said the EPA has several lead paint programs he admitted that,
because the LRRP rule is the newest, most of its resources are directed
“Our main goal is making sure lead safe work practices are in effect,”
Lott answered the question that he says the agency is asked most: Do we
use the list of certified firms as a target list? “Absolutely not,” he
He said the agency performs two types of inspections: record review and
“Personally, I’d like to see more on-site inspections and I think we will
see more of those,” he said.
The EPA has performed more than 1,000 inspections to date, has issued
more than 40 notices of non-compliance and more than 30 pre-settlement
negotiations are ongoing. Additionally, two RRP complaints were filed—not
settled—and according to Lott, “Many more will be issued over the next
“Of those 1,000, a lot of non-compliance is being found, but it is a question
of how bad it is … The majority of our tips reveal non-certified firms,”
“We do need your help to identify those,” he added.
NFRC Helps Retailers Keep Consumers Informed
“Fenestration ratings are rarely understood by door and window consumers,
but are critical to how they choose the window or door that best fits
their needs,” says Tom Herron, senior manager, communications and marketing,
National Fenestration Rating Council (NFRC).
To make the process easier, the group is actively educating consumers
about energy efficiency ratings through its retailer program. The program
involves tear sheets To make the process easier, the group is actively
educating consumers about energy efficiency ratings through its retailer
program. The program involves tear sheets developed by the NFRC, and distributed
to retailers free of charge. The retailer can then brand the materials
so when a homeowner weighs their options they remember that company.
Herron says the NFRC is aiming to educate consumers instead of having
them be confused about the NFRC label, which has happened in the past.
“They would back off thinking it [the label and terms such as SHGC and
U-factor] was complicated,” he says. “That is bad news for a retailer.
You don’t want them to leave.”
The NFRC started the retailer program when it saw a glaring need for consumers
to become more educated.
“What we found was that the consumer didn’t understand the NFRC labels
and didn’t know what things stood for so we use down-to-earth language
to help them in their decision-making process,” says Herron. “It helps
that the info is coming from a third-party, independent certification
The third-party data is what’s key, according to the NFRC.
“That’s what we find to be a big deal,” says Herron. “It is one thing
to take the word of the person selling … we all know how that may go sometimes.
Obviously they [retailers] have a motivation to move that product. We
don’t make money from this.”
The program isn’t new, however. The NFRC developed the fact sheets back
in 2009 and is now looking to distribute the program more widely to retailers.
Herron says those currently using the tools have experienced positive
“We have had retailers who have come to us and said they had been using
[the fact sheets] in one location and want to order [more] for additional
locations,” says Herron. “That speaks to the efficacy of the program.”
Herron adds he doesn’t usually use clichés, but just has to in
“It’s truly a win-win situation,” he says. “The retailer gets to help
consumers along in the decision-making process and consumers get fair
and objective information to assist them.”
AMD Seeks ANSI Approval of SHED Standard
The Association of Millwork Distributors (AMD) is seeking ANSI approval
of its AMD 100 standard, Structural Performance Ratings of Side-Hinged
Exterior Door Systems and Procedures for Component Substitution as an
American National Standard.
The AMD 100 standard provides an objective process for obtaining a design
pressure rating for a side-hinged exterior door system (SHEDS) and for
substituting components in a rated SHEDS. The testing required by this
standard follows the ASTM E330 test method. The standard defines methods
for qualifying door system components for substitution, and applies to
both single- and multi-panel systems, in-swing, out-swing, and fixed assembly
installations. Door slab stiffness testing is used and outlined in this
standard as a means for determining component substitution.
(For the AMD viewpoint see page
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