Comment submitted by Colleen Beck, Saint Louis County Department of Health

A protective renovation, remodeling and painting rule is an important way to prevent lead poisoning. The only possible conclusion that can be drawn from the new research is that the final rule must ban all dangerous methods of paint disturbance, require post-work clearance testing, require proper training for all workers, and ensure adequate enforcement. It is imperative that these 4 pieces be included in the rule. The proposal as it stands, gives contractors too many loopholes and permits unsafe work practices such as sanding and blasting, open flame burning and torching. These extremely dangerous methods of removing paint create and disperse lead- based paint hazards. The study conducted by EPA demonstrates that these practices, which are considered unsafe by HUD, really are unsafe and should be prohibited. However, using lead safe work practices is not by itself protective enough. Only clearance testing can verify that in fact no lead-based paint hazards exist. EPA's proposed cleaning verification does not verify the absence of lead dust. In the EPA study, cleaning verification was not always accurate in identifying the presence of lead levels above the EPA standard. All renovation and remodeling workers as well as painters have the right to be properly trained in lead safe work practices. Proper training is beneficial to the worker, the employeer, the home owner and his/her family as well as the family of the worker. I strongly urge EPA to include the 4 pieces listed above in the proposed renovation, remodeling and painting rule.