Comment submitted by Marcy Bauer, Public Health Solutions, District Health Department

While strengthening requirements for renovation of lead-containing, child-occupied facilities is most certainly a step in the right direction, please take into consideration potential ramifications for child-care facilities in rural areas. If the final language of this rule requires child-care service providers to use certified, licensed abatement contractors to do renovations, rural providers will most certainly be left without any legal options for updating their pre-1978 facility. The small job size and extra travel costs associated with renovating rural child-care facilities all but guarantees this, as demonstrated by our recent EPA-funded lead poisoning prevention program. In one case, the only licensed contractor in the entire state that we could get to work on a rural day care charged nearly twice the normal fees for his trouble, and refused to come on the weekend to avoid renovating while the children were present. The end result was increased acute risk to the children and wasted state money. Just like with the asbestos programs, there needs to be a waiver process for rural child-care providers to use trained but unlicensed contractors for lead abatement if we expect them to do the right thing by their children.