Comment submitted by Terrance M. Brady, Tampa Housing Authority

Document ID: EPA-HQ-OPPT-2005-0049-0487
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: May 23 2006, at 04:11 PM Eastern Daylight Time
Date Posted: May 24 2006, at 12:00 AM Eastern Standard Time
Comment Start Date: January 10 2006, at 11:34 AM Eastern Standard Time
Comment Due Date: May 25 2006, at 11:59 PM Eastern Standard Time
Tracking Number: 80178c59
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1.) This is an ideal time to begin the transition from reacting to blood levels of 10?g/dl in children to being proactive and including children with 5?g/dl in the first stage. Doesn?t cost any thing simply helps adjust the priority list to relieve children of the ?canary? position. 2.) Allowing certified renovators to both train their workers and perform a visual ?white glove? clearance is an incentive to take short cuts. Ethics are nice but time is money and money pays the bills. There needs to be an informed third party to protect the integrity of the program. I am also curious on how data will be collected to determine the efficiency of this program both in children?s health and costs. 3.) Eliminating the prohibited work practices of dry sanding, high temperature heat guns and methylene chloride is another incentive to use the fastest removal methods not the safest. Who monitors these activities? OSHA, in their spare time? 4.) Last, HEPA vacuums are now priced equivalently with everyday vacuums; there is no need to not require them for renovation contractors.

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