Meeting with representatives of the National Association of Home
Builders, November 8, 2006 

In attendance:

Vince Butler, President, Butler Brothers Corporation, 2006 Chairman of
NAHB's Remodelors Council

Brindley Byrd, President, Qx2, Inc., NAHB LBP Taskforce  

Bob Hanbury, President, House of Hanbury, Inc., NAHB LBP Taskforce Chair

Michael Nagel, President, Remodel One, 2006 Vice Chairman of NAHB's
Remodelors Council  

Therese Crahan, Executive Director, Remodelors Council, NAHB

Jim Lapides, Communications Manager, Remodelors Council, NAHB

Andrew J. Holliday, Regulatory Counsel, Advocacy Group, NAHB

Mike Mittelholzer, Assistant Staff Vice President, Environmental Policy,
NAHB

James B. Gulliford, Assistant Administrator, Office of Prevention,
Pesticides, and Toxic Substances, USEPA

Susan B. Hazen, Principal Deputy Assistant Administrator, Office of
Prevention, Pesticides, and Toxic Substances, USEPA

Margaret Schneider, Deputy Assistant Administrator, Office of
Prevention, Pesticides, and Toxic Substances, USEPA

Wendy Cleland-Hamnett, Deputy Director, Office of Pollution Prevention
and Toxics, USEPA

Robert Lee, Acting Director, Economics, Exposure and Technology
Division, USEPA

Brian Symmes, Associate Director, National Program Chemicals Division,
USEPA

Julie Simpson, Chief, Lead, Heavy Metals, and Inorganics Branch,
National Program 	Chemicals Division, USEPA

Andrew Simons, Office of General Counsel, USEPA

Discussion:

Mr. Nagel introduced the individuals present on behalf of NAHB.  He gave
an overview of the organization and its activities relevant to
renovation and remodeling.  He summarized NAHB's three major policy
concerns as to regulation of renovation and remodeling activities:

A rule that is too stringent will cause professional remodeling firms to
avoid jobs involving the disturbance of lead-based paint.  These jobs
will be done by less professional firms or “do-it-yourselfers” (who
are not covered by the proposed rule).  This will increase risks of lead
exposure to occupants.  

Renovators should not be held responsible for risks resulting from
pre-existing conditions.  

EPA's proposed rule does not apply to do-it-yourself renovation jobs.

Mr. Gulliford welcomed the attendees and introduced the EPA personnel
present.

Mr. Hanbury distributed the Executive Summary of NAHB's "Lead-Safe Work
Practices Survey Project Report" and described the report's findings.  A
copy of the full report was provided to Mr. Gulliford.  

Mr. Mittelholzer asked that the report be included in the docket of the
RRP Program proposed rule.  He also asked that EPA publish a notice in
the Federal Register announcing the availability of the report and
requesting comment.  

Mr. Byrd noted that NAHB will be communicating the results of the report
to its members.  Its NAHB’s stated goal is to protect renovators and
the public from lead exposure.  Mr. Byrd emphasized that Tthere are many
opportunities for education as well as partnerships between NAHB and the
private sector, including manufacturers, contractors, and
do-it-yourselfers.  NAHB would be interested in working with EPA to
disseminate information regarding renovation activities and lead-based
paint hazards.get the message out.  

Mr. Butler discussed in more detail the policy concerns summarized by
Mr. Nagel.  

Mr. Gulliford stated that the NAHB report would be added to the docket
for the RRP proposed rule.  He noted that EPA is also conducting a study
of the extent to which renovation projects create lead dust hazards. 
This study is expected to be completed in January.  EPA expects to place
its study in the docket and seek comment on it.  

Mr. Mittelholzer thanked Mr. Gulliford for the meeting and reiterated
NAHB's concern that renovators not be held responsible for conditions
not created by the renovation -- to do so would in effect turn the
renovation firm into an abatement firm.  

