Comment submitted by David Stanley, Central Delaware Training Academy, Inc.

"Paint Removal, removal of large structures (demolition), paint removal by abrasive sanding", [page 1596 & 1598] are high dust generating activities and should remain the responsibility of Certified Lead Abatement Supervisor and Workers. I believe, renovation activities should focus on generating a minimal of paint dust such as paint film stabilization, reducing impact and friction, etc. When high levels of paint dust are expected the job should be the responsibility of persons with the maximum of training not minimal training. "removing paint (using open flame torches, using heat guns, using chemical paint removers, and wet scraping/sanding) and preparing surfaces by sanding or scraping significantly increased the risk of EBLs." [page 1597] and all create potential health hazards for the workers. I fear when workers are trained by renovators via OJT (on-the-training) that the training may not be sufficient in alerting the worker to potential health hazards and adequate PPE (personal protective equipment). As we all know, "removing paint (using open flame torches)" is prohibited by HUD and I believe this option should not be available to renovators. In this statement "EPA has carefully considered the elements of the existing abatement regulations and revised them as necessary to craft a proposal that is practical for renovation and remodeling businesses and their customers" [page 1599} it appears to me that EPA is proposing changes to 745.225 that will benefit the renovator and maybe the client in the short run and certainly not the client's children in the long run. Not all lead paint is a hazard but when the paint is disturbed the potential of making it hazardous is greatly increased. I believe, "allowing cleaning verification in lieu of clearance testing in the abatement regulations" as described in this narrative is a conflict of interest for the renovator. If the cleaning verification is the selected form of "clearance" it should be accomplished by a third party not the renovator. I believe, using "Chemical Spot Test Kits for Lead in Paint" [page 1604] only tests the surface paint layer. I believe adjusting these kits to validate "lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight" is very questionable. I believe that paint chip samples or XRF testing, which are already proven to be reliable and should be used. Sec. 745.85 Work practice standards does not list recommended or prohibited work practices. I believe this section should clearly describe acceptable and/or prohibited work practices for renovators. When the do's and do not's are clearly stated there is less opportunity to make and honest mistake. "Sec. 745.85 Work practice standards (b)(ii) After a successful visual inspection, a certified renovator must:" suggest renovator be changed to "inspector or risk assessor". If a renovator MIGHT error, I believe it will be on the side of making a profit. Third party confirmation will assure the client he/she is getting what the renovator has promised. In reference to 745.86 (7) Documentation of compliance with the requirements of Sec. 745.85, including documentation that a certified renovator was assigned to the project, the certified renovator provided on-the-job training for uncertified workers used on the project, [the type, amount of OJT and who attended; should be documented] the certified renovator performed or directed uncertified workers who performed all of the tasks described in Sec. 745.85(a), and the certified renovator [change renovator to inspector or risk assessor] performed the post- renovation cleaning verification described in Sec. 745.85(b). Renovator on-the-job training should indicate the type and duration of the training and who attended each specific event. OJT is probably on-going and it is important to know who received training.