Comment submitted by Anita Weinberg, Chair, Illinois Leah Safe Housing Task Force

Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) U.S. Environmental Protection Agency 1200 Pennsylvania Ave., N.W. Washington, D.C. 20460-0001 RE: Docket EPA ? HQ-OPPT-2004-0126 To Whom It May Concern: The Illinois Lead Safe Housing Task Force thanks the EPA for the opportunity to offer the following comments on the proposed brochure ?Protect Your Family From Lead During Renovation, Repair, and Painting? which is referenced under the Docket above. The Task Force is an alliance of public, private, and not-for-profit groups including community-based organizations, property management and realtor associations, the insurance industry, federal, state and local public health and housing agencies, universities, children?s health and welfare advocates, tenant organizers, physicians, attorneys and parents of children who have been lead poisoned The EPA has taken a very important step in informing renters and homeowners that the remodeling or renovation work that is about to begin in their dwelling may expose the residents to dangerous levels of lead and what they should expect from the contractor. The Task Force applauds the planning that went into revising this brochure for the use of the public. The Task Force, in its work with communities most affected by deteriorating lead paint due to old housing stock and lack of resources to address the problem, recognizes that information to the most at-risk public must be geared toward renters as well as homeowners and must be simply stated and concretely helpful. In the view of the Task Force the brochure needs improvement in these two areas. The brochure should announce at the outset that the information is intended for renters as well as for homeowners. If the EPA includes the requirements that have been proposed for lead safe work practices, including banned practices, as has been urged by several commentators, the brochure should tell renters and homeowners that the contractor who will be performing the work on their dwelling is required by law to provide them with the brochure and to observe work practices that do not create lead dust that could poison them and/or their children. Further, in the interest of shortening the brochure, increasing the chance that it will be read, a series of pictures, depicting specific unsafe work practices if finally decided upon for inclusion in the rule, should be substituted for lengthy verbal descriptions, with perhaps an X through those practices. A check-off box could be provided beside each picture, asking the tenant or homeowner to check whether he or she had received assurances from the contractor that those work methods would not be used. Finally, we suggest a place for the tenant/homeowner and the contractor to sign indicating that the work practices have been discussed. This check list would also serve as a convenient way for the tenant/homeowner to monitor whether the disallowed practices were in fact used. The section ?Who Should Read This Pamphlet? could be eliminated. Basic facts about lead can be presented briefly in bullet points. The rest of the bullets in this section either assume that the contractor has not been hired yet, (and if so, how does he present the brochure?) or are provided elsewhere, i.e., ?Where to Get Information About Lead.? The section ?Where Does Lead Come From? will be confusing to the person receiving the brochure. It suggests that the work and clean up will be done by the tenant or homeowner. The point of the brochure is to alert them to the responsibilities of the contractor, not their own responsibilities to do lead safe work. Where the brochure asks, ?Who is Responsible?? and answers ?You Are?, the point is again confused. The contractor must work safely and the tenant or homeowner should be helped by this brochure to know if that is occurring. Finally, we suggest that the proposed language about contractors? lead safe methods imply that these methods are optional. The public needs to be clear that whatever requirements are finally adopted by the rule are not optional.. The last part of the brochure is a ?how to? for contractors, but it suggests that the tenant/homeowner must do the clean up. It also states that when the cleaning is done no dust or debris should be visible.This is an inaccurate and harmful statement. What is not in dispute in all the studies and stated in the EPA?s own literature is that lead dust is often invisible and the fact that it cannot be detected by the naked eye is no assurance that it is not present. Thank you for the opportunity to comment on and offer suggestions for the brochure. It is an important tool in our collective efforts to eliminate childhood lead poisoning. The Illinois Lead Safe Housing Task Force looks forward to a final version that will build effectively on this fine beginning. Respectfully submitted, Anita Weinberg, Chair Illinois Lead Safe Housing Task Force