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.
Comment submitted by Terrance M. Brady, Tampa Housing Authority
This is comment on Proposed Rule
Lead; Renovation, Repair, and Painting Program; Extension of Comment Period
View Comment
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