RRP Impact Already Negative, WDDA Survey Finds

June 15, 2010

Designed to gather input to make a case against clearance testing requirements, a Window & Door Dealer Alliance survey indicates that new Environmental Protection Agency rules covering renovations in homes with lead paint are having a significant negative impact.  More than 70 percent of the 100-plus respondents to date say their company has lost business since the Renovation, Repair and Painting rule went into effect in April.

"We have lost work to contractors who refuse to abide by the LRRP rule and therefore can provide lower prices," says one respondent, discussing the impact of the current regulations.  "Interestingly, the average consumer agrees with them that the law is much ado about nothing." 

"Customers don't seem to really care about the lead paint ruling and are unwilling to go through the hoops to comply with the new ruling and will not pay additional costs," reports another. "There are non-legal people that will install without the concerns."

As reported last week, WDDA is preparing comments and collecting input from dealers around the country to present to EPA regarding new clearance testing requirements proposed when the RRP rules went into effect.  According to a WDDA statement of principles, contractors would be required to hire (or have as a member of staff) an EPA-certified inspector, certified dust sampling technician, and/or certified risk assessor. This person would collect dust samples to be sent to an EPA-accredited lab to a conduct lead-based paint dust clearance test after the contractor has completed “cleaning verification.”

More than 70 percent of respondents to the online survey, which is still live and still being used by WDDA to collect input and comments, indicated they agreed with the organization's statement of principles opposing additional testing requirements.  Nearly 80 percent of respondents say they have already seen an increase in hard and soft costs as a result of the RRP. 

WDDA notes that by EPA’s own estimate, contractors may incur a minimum cost of $250 for testing lab fees. Respondents to the survey offered a wide range of predictions regarding additional costs for testing, but most seemed to think it would be significantly higher.

Commenting on the additional cost of clearance testing, one respondent notes, "You did not mention the additional cost of money that will be incurred by contractors as they await final payment for a job. Homeowners will not make final payment on most renovation jobs until it is complete and signed off. This rule will result in huge cash flow problems for contractors, as they await testing results and possibly re-testing as well. Then, good luck chasing down the customer. This affects financed jobs greatly, as many of those programs only pay out once the customer signs a completion certificate."

"The real cost is going to be the lost business," says another respondent. "People are not going to want their home tested for fear of disclosure. Property values will decline and the values will decline in our older neighborhoods."

"I cannot believe that the EPA has taken this rule so far. They are putting the economy in more jeopardy and costing thousands of useless dollars," another respondent asserts. "We are already losing tons of business due to this rule with hardly adding any cost to the job. This is going to ruin the home improvement industry, and put many companies out of business. Honestly, we just don't know what we are going to do."

David Walker, WDDA VP, notes that the group is not only continuing to collect data using the online survey, but it is also gathering letters to be presented to EPA officials in July.  WDDA has drafted a letter for dealers to use that can be supplemented with anecdotal information from their own companies and printed on company letterhead.  "We're getting tons of letters and we hope to get more," Walker concludes, urging dealers to send a copy of their letters to WDDA by June 21. 

Letters can be emailed to dwalker@glass.org or mailed to David Walker, Window & Door Dealers Alliance, 8200 Greensboro Drive, Ste. 302, McLean, VA 22102.