NARI Letter to the EPA

Wednesday, July 30th, 2014

I was fortunate enough to be allowed a guest blog on Sean Mccaden’s RRPedia site and received plenty of responses some of which made sense and others not. One of the most interesting comments came in the form of a video clip from Fox News “The Sky is Falling Channel” in the piece they interview a guy that is fairly knowledgeable about RRP and said that in his industry costs would be elevated about 10%. The fox folks went on to cut away and insert their bias into “the news” The bottom line is that their poisonous speech and anti establishment leaning  is causing fulminating anti RRP fervor. Sadly, some remodelers around the country are on board with the ” throw the bums out” mentality. I spoke with Chuck Norris a fellow lead tester in Saint Louis MO. who spoke to a localNARI chapter that attendees were acting/ speaking like renegades and wanting to duck the regulations. I will be gathering comments from my fellow NARI members in the North West to share with NARI National in an effort to reflect the views of the membership with the ultimate goal of letting the EPA know where NARI as an organization of Professional Remodelers stands. I hope that we can stick together as adults and put our thoughts on paper. I found this letter on line sent a few months ago that was the opinion at the time but things are ever changing.

January 11, 2011

The Honorable Lisa Jackson
U.S. Environmental Protection Agency
Washington, DC 20460

Re:  Enforcement of Renovation, Repair and Painting Rule

Dear Administrator Jackson:

On behalf of the 7,000 companies that belong to the National Association of the Remodeling Industry (NARI), I am writing to encourage the U.S. Environmental Protection Agency (EPA) to aggressively and fairly enforce the Lead Renovation, Repair and Painting (LRRP) rule.

NARI is a non-profit trade association based in Des Plaines, Illinois.  We have 58 Chapters in major metro areas nationwide and our membership is comprised of remodeling contractors, local suppliers, and national suppliers.  83 percent of NARI members have fewer than 20 employees.  NARI’s core purpose is to advance and promote the remodeling industry’s professionalism, product and vital public purpose.

As you know, EPA postponed enforcement of LRRP last summer to allow for contractors to receive training.  The agency set December 31, 2010 as the training deadline for remodelers who do work on homes built before 1978.  In our view, now that the initial training deadline has passed, EPA must aggressively and consistently enforce the LRRP rule so families can have confidence that work on their homes is being done safely and professionally.

NARI is proud to represent some of the most highly trained and certified remodelers in the business.  NARI members voluntarily subscribe to a strict Code of Ethics and Standards of Practice and we deliver rigorous education and certification programs.  When EPA finalized LRRP in August of 2008, NARI made it a top priority to inform our members of their responsibilities and to direct members to trainers so they could be certified.  NARI members received information on LRRP via numerous article in our main membership publication, The Remodelers Journal; NARI’s e-newsletter, The Spec Sheet; and in our e-notice, Tuffin’ It Out.  NARI published and distributed Issue Briefing Papers, and we continue to devote space to the LRRP on NARI’s Web site,

We recognize that over 400,000 professionals have been trained in lead-safe work practices. NARI and other professional trade and membership organizations joined EPA in public education campaigns on LRRP, and a growing list of states are qualified to run LRRP.  However, non-certified contractors are working on pre-1978 homes in violation of LRRP, and we are concerned that such illegal activity will continue unless EPA launches a tough enforcement campaign.  Non-certified contractors who do work on pre-1978 homes heighten the risk of lead exposure and threaten the economic viability of remodelers who made the investment to become EPA-certified.  In our view, the only way for EPA to address the problem of non-certified contractors is to aggressively and publicly enforce the LRRP rule and to push authorized states to do the same.

NARI would like to work with you to publicize EPA’s enforcement efforts and maximize the campaign’s impact.  Through a public enforcement strategy, we can lessen harmful exposure to lead during construction and we can drive more homeowners towards certified contractors when they consider remodeling projects.


Mary Busey Harris, CAE
Executive Vice President