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EPA
December 9, 2010
EPA Launches Website to Increase Transparency of Regulatory Activity
WASHINGTON - The U.S. Environmental Protection Agency (EPA) has launched a new website called Reg Stat that will enhance public understanding of its regulatory process and the number, type, and range of regulatory documents developed each year by the agency. This new resource is part of the EPA’s continuing efforts to enhance the accessibility and transparency of its regulatory activities.
Reg Stat provides information on EPA documents published in the Federal Register between 2005 and 2009. It also provides in-depth information on rulemakings likely to be of most interest to stakeholders -- those rules signed by the EPA administrator that substantively amend the Code of Federal Regulations. Users will be able to determine the number of rules signed by the administrator, how long it took to develop each rule, whether a rule underwent Executive Order 12866 regulatory review by the Office of Management and Budget (OMB), and the length of OMB review. Both summary graphics and searchable data tables are available.
An analysis of the data featured on Reg Stat shows that EPA publishes 1,700 to 1,900 documents in the Federal Register each year. Notices, which provide general information of public interest such as meeting announcements, make up the majority of these documents. Approximately 7 percent, or about 100, of those documents are rules that amend the Code of Federal Regulations and require the administrator’s signature; the average time to publish these rules is 974 days.
Users will be able to download and sort the data based on categories of interest. Information on Reg Stat will be updated annually.
More information on Reg Stat: http://www.epa.gov/regstat
October 19, 2010
EPA Seeks Small Businesses Input on Formaldehyde
WASHINGTON – The U.S. Environmental Protection Agency (EPA) is inviting small businesses to participate in an advocacy review panel focusing on formaldehyde. The agency plans to implement regulations for the new Formaldehyde Standards for Composite Wood Products Act, enacted in July 2010.The proposed regulation will establish limits for composite wood products (hardwood plywood, medium-density fiberboard, and particleboard) so these products meet emission standards.
Formaldehyde is a known eye, nose, and throat irritant, and in 1991, EPA classified formaldehyde as a probable human carcinogen. Formaldehyde-based resins are sometimes used as adhesives in composite wood products.
The Regulatory Flexibility Act requires EPA to establish a federal panel for rules that may have a significant economic impact on a substantial number of small organizations. The panel will include representatives from the Small Business Administration, the Office of Management and Budget, and EPA. The panel will ask a selected group of small entity representatives (SERs) to provide advice and recommendations on behalf of their company, community, or organization to inform the panel on impacts of the proposed rule.
EPA seeks self-nominations directly from the small organizations that may be subject to the rule requirements to facilitate the selection of SERs. Self-nominations may be submitted through the link below and must be received by November 2, 2010.
More Information: http://www.epa.gov/sbrefa/formaldehyde.htmApril 7, 2010
AMD REQUESTS ATTENTION ON EPA – LEAD PAINT REGULATIONS MEMBERS OF CONGRESS RESPOND
AMD President, Dan Warren and AMD staff addressed specifics of the latest controversial Environmental Protection Agency (EPA) lead paint regulations forcing businesses to comply with the EPA Renovation, Repair and Painting (RRP) Program scheduled to take effect on April 22, 2010.
In early March, on behalf of the Association of Millwork Distributors, its members and the millwork industry, Dan Warren outlined the concerns with the EPA lead paint regulations and an appeal directly to Representative Stephanie Herseth Sandlin in Washington D.C.
First, although the window and door industry recognizes the need to comply, the majority in the industry will not be incompliance by the required date. Secondly, though the rules were promulgated in 2008, the window and door industry was not informed about the need for supplemental training and certification until much later. Third, the regulation originally included an "opt-out" provision allowing customers to sign a waiver releasing liability to the installing dealer as long as there are no pregnant women or children under the age of six living in the home. The understanding is that the opt-out provision may not be part of the final rule.
The appeal presented was two-fold -
1) Preserve the opt-out provision. This is a common-sense, cost-reducing carve-out that puts control in consumers'
hands while not compromising health and safety.
2) Defer the regulation's implementation date to January 1, 2011, or later.
The current tax credit for energy improvements is scheduled to expire on January 1. The delay will allow contractors, remodelers and renovators the time needed to attend training courses (which are currently in high demand or even sold-out) and earn their certifications. Without this added cushion, many quality service providers could have their insurance policies canceled due to carriers' concerns about liability associated with the lead paint rules.
Dan communicates the seriousness and potentially devastating issues the regulation is to companies requesting legislature implore the EPA to extend some much-needed breathing room so that compliance does not push more businesses to close.
On March 26th, 2010, a letter endorsed by several members of Congress, was submitted to the Administrator, Office of Information and Regulatory Affairs addressing the April 22, 2010 deadline and the concerns that the necessary steps have not been taken to certify the appropriate number of industry professionals to meet compliance standards.
Dan states, “I strongly encourage our AMD members, their customers and all those associated with the window and door industry to continue to contact their representatives and express your concerns on the EPA Lead Paint Regulation. The time is now. It’s not too late to get involved.”
To view the letter from Congress addressing the concerns with the EPA Lead Paint Regulation, click here
For more information on the EPA Lead Paint Regulation or how to take action and receive a copy of a draft letter outlining the concerns, contact Rosalie Leone rleone@AMDweb.com or mail@amdweb.com.
March 7, 2010 AMD Millwork Magazine
EPA gears up for new lead paint rules
By Jeff Burton, AMD Director of Codes and Standards
This month’s article is specifically related to the new EPA’s new lead paint rules (officially named EPA's Renovation, Repair, and Painting (RRP) Program). AMD has been following the development of these new requirements and developed an Advocacy Kit for our members and the industry.
AMD is very concerned about the timing and costs associated with complying with and getting ready for the lead-safe compliance deadline of April 22, 2010. Will there be any chance that the deadline for the lead rule to take effect will be pushed back? According to the EPA, the rule will become effective on April 22, 2010, as planned.
As part of the AMD advocacy, members are strongly encouraged to contact their Congressman and policy makers and voice our industry concerns. Though the rules were implemented in 2008, the industry was not informed about the supplemental training and certification until much later. In addition, the regulation originally included an "opt-out" provision allowing customers to sign a waiver releasing installation liability to the dealer as long as there are no pregnant women or children under the age of six living in the home. It is our understanding now that this “opt-out” provision may not be considered in the final rule.
The AMD position requests that-
- The regulation preserves the opt-out provision. This is a common-sense, cost-saving policy that puts control in consumers' hands while not compromising health and safety.
- Defer the regulation's implementation date to early 2011 or later.
Just this week an AMD member asked “What type of compliance” is in the works for these regulations. Who will be doing enforcement? EPA states that their staff will be doing enforcement in states that are not yet authorized. State personnel will be doing enforcement in authorized states. That answer leaves a lot to be desired.
Many installers believe that the EPA has grossly understated the cost of compliance. It is felt that compliance will add much more than $35 per job (EPA's estimate) when training, equipment, materials, much slower man-hours, paperwork, etc., are included. It is unclear as to how the EPA determined $35 per job and in what scenarios does the EPA feel that number applies?
For jobs where lead-based paint is present, EPA has estimated that the costs of containment and cleaning verification will range from $8 to $167 per job, with the exception of exterior jobs where vertical containment would be required. These are incremental costs attributable to the rule.
Information collected by EPA for the purposes of the rulemaking indicates that many contractors already follow some of the work practices required by the rule, such as using disposable plastic sheeting to cover floors and objects in the work area. EPA's cost estimates only include the additional steps that those contractors would have to take as a result of the rule.
In addition, in developing the rule, EPA was particularly concerned with having reasonable record-keeping requirements for renovation firms. As a result, the record-keeping requirements specific to the RRP rule are designed to be completed by a typical renovator in 5 minutes or less. EPA believes that the records pertaining to the RRP rule will make up only a small portion of the records renovation contractors typically keep for each renovation job.
Add our voice to AMD in educating our members of Congress as we urge them to delay the effective date of EPA’s new lead paint rules. (http://www.builderonline.com/business/epa-issues-new-lead-paint-rules.aspx)
AMD’s “EPA Lead Paint Rules Advocacy Kit” includes a draft letter (below) that can be personalized to your representatives (find your local representatives onlinehttp://www.contactingthecongress.org/). This letter includes the AMD official stance on EPA’s new lead paint rules. Specifically, AMD’s stance communicates that our industry urges officials to preserve the “opt out” clause of the original draft and support a deferral of the date of implementation.
AMD continues to work on your behalf; AMD Side Hinge Exterior Door Standard (SHEDS) is only one of numerous important projects. AMD also has Certification services for EnergyStar and now, Fire Rating, and we offer a state of the art technology in AMD’s online Education Program. For more information or to have this draft letter emailed directly to you, contact mail@amdweb.com
