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NAR Comments on Lead Paint Framework

July 18, 2014

NAR, as part of the Commercial Properties Coalition, recently filed the latest in a series of comment letters relating to efforts by the U.S. Environmental Protection Agency (EPA) to regulate purported lead paint hazards that may arise from renovation and remodeling activities in public and commercial buildings.  The June 30 letter focuses on EPA’s proposed “framework” for determining whether renovation and remodeling activities in public and commercial buildings — such as new tenant build-outs — actually cause lead-based paint hazards. On the basis of such a determination, EPA could then move forward with proposed regulations affecting commercial real estate.

Although EPA’s framework correctly acknowledges that public and commercial (P&C) buildings “vary greatly” (with respect to sizes, shapes, configurations, uses, occupancies and cleaning frequencies) — and that a “one-size-fits-all” approach is not appropriate for renovation, repair and painting (RRP) activities in such buildings — it appears to circumvent a process set forth by Congress in the Toxic Substances Control Act (TSCA) for developing new regulations.

Download the letter