Comment submitted by Amy Rinner, University of Notre Dame

Amy Rinner University of Notre Dame 36 Canterbury Trail Rochester Hills, MI 48309 April 7, 2006 Comments on docket ID number EPA-HQ-OPPT-2005-0049 Federal Registrar Tuesday, Janurary 10, 2006 p. 1588-1636 Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460-0001 To Whom It May Concern: I believe that the Lead; Renovation, Repair and Painting Program Proposed Rule will not prevent lead poisoning as successfully as it should for four reasons: it could leave some populations unprotected, it will increase renovation fees which will discourage homeowners from repairing their homes in the most lead-safe manners, the rule enables homeowners to make false claims to avoid compliance with the rule, and the rule does not apply to small maintenance projects even though they may cause hazardous levels of lead dust. While children under the age of six are perhaps the most vulnerable persons to lead poisoning due to their developing nervous systems, the rule does not consider other susceptible populations such as children aged 6-12 and pregnant woman (see Appendix 1). The new rules will increase fees charged by home renovation firms so that even if market forces were to lower the costs, many persons may choose to perform the repairs themselves. Individual homeowners may not know the proper cleaning techniques and are not required to follow the new cleaning standards so they may cause the spread of hazardous lead dust during their work (see Appendix 2). Also, since the proposed rule allows that owners may waive the rule?s application by signing a statement that a child under age six does not reside in the home, they may do so to save money, not clearly understanding the threat of lead-based paint (see Appendix 3). Finally, the proposal will not reduce lead poisoning as successfully as it should because the new rules do not apply to emergency projects or minor maintenance activities that ?disturb 2 ft2 or less of painted surface per component [job area]? even though they can cause amounts of lead in dust at levels which can cause adverse health effects (see Appendix 4). Thus, I encourage you to consider the explained objections to the proposal and revise the rules accordingly to more effectively eliminate lead poisoning caused by home renovation and repair. Sincerely, Amy Rinner