Anonymous Public Comment

Child-Occupied Facilities Without LBP Should Not be Exempt from RRP Safe Work Practice Requirements Child-Occupied Facilities (COFs) with no LBP should not be exempt from RRP safe work practice requirements. There is strong evidence that buildings, especially older structures, often contain large reservoirs of leaded dust that frequently are disturbed during RRP activities. These leaded dust reservoirs exist regardless of the presence of LBP in the structure. Extensive sampling from dwellings/structures around the U.S. and Australia shows a broad prevalence of hazardous leaded dust accumulations in wall cavities, around windows, above ceilings and in attics. It has been demonstrated that even a small (2 inch) hole cut into a wall or ceiling can release hazardous quantities of leaded dust into interior living areas. It has been shown that many RRP activities disrupt these reservoirs and release hazardous quantities of leaded dust. Studies that support the above conclusion * The recent DOE Study, Analysis of Lead-Safe Weatherization Practices and the Presence of Lead in Weatherized Homes (2006) demonstrated ?a substantial amount of leaded dust is generated during various weatherization work activities such as cutting holes, window repair, and window replacement. In particular, a large a mount of leaded dust was generated on floor sheeting by the cut holes weatherization activity, even though little leaded paint was found in cut hole wall and ceiling work locations by XRF testing.? The ?cut hole? procedure as conducted in this study involved cutting a small hole in a wall or ceiling for injection of insulation. For this study, the holes were cut almost exclusively on walls or ceilings with no measurable LBP. This leaded dust was not from existing paint! It was, rather, the product of decades of air deposition. * EPA?s Lead Exposure Associated with Renovation and Remodeling Activities: Environmental Field Sampling Study (R&R, Phase I, 1997) demonstrated that window replacement (total unit replacement) released large quantities of fine, black dust onto sample collection trays. The on-site sampling crew noted the dust that fell out of the wall cavities did not appear to originate from paint. When this dust was analyzed, it was found to contain some of the highest lead levels observed in the entire study. This dust was not from existing LBP. * EPA?s Lead Exposure Associated with Renovation and Remodeling Activities: Phase III, Wisconsin Childhood Blood-Lead Study (1999) was a very large (3650 subjects) retrospective, case-controlled study conducted throughout the State of Wisconsin. It demonstrated a significant relationship between renovation and remodeling activities and EBL children. A wide variety of factors were systematically evaluated in this study (type of work, who did the work, how extensive was work, age of dwelling). As might be expected, the age of the dwelling was an important factor. Generally, the older the dwelling, the higher the likelihood there would be an EBL child. The most surprising finding was that renovation and remodeling work conducted in houses built after 1980 was associated with an increase in the likelihood of an EBL child. * Widespread sampling of dust from attics and wall cavities at locations in Australia and two regions of the U.S. strongly corroborate that hazardous reservoirs of leaded dust are commonly found above ceilings and in exterior wall cavities. These studies demonstrate that hazardous levels of leaded dust occur in a wide range of dwellings in diverse locations. * Davis and Gulsen, (2005) sampled and analyzed dust deposited in attics of 38 houses (ranging in age from 4 to 106 years) in Sydney, Australia. The dust was found to contain a ?museum? of contamination and potential hazards. The geometric lead mean concentration of lead was 1660 ppm for industrial settings, 1173 ppm for semi-industrial settings and 477 ppm for the rural settings. It was concluded that a very small quantity of this attic dust, if allowed to penetrate into the living space, could create a lead exposure hazard throughout an entire dwelling. * Whicker, Hayes, Khoo and Bhathal, (1997) sampled of ceiling dusts from eleven dwellings in southwestern Sydney. Samples from each dwelling were analyzed for Pb, Cu, Zn and Cd. Lead (Pb). Lead concentrations varied from 519 ppm to 1165 ppm with a geometric mean of 709 ppm. Lead concentrations were significantly higher in older buildings (>15 years) and buildings located in heavily developed areas. Fine particulates typically accounted for more than half of the ceiling dust mass, which indicates that atmospheric deposition has been a significant contributor of particulate matter and associated heavy metals to these residential environments. * Ilacqua, Freeman, Fagliano, Lioy, (2003) sampled undisturbed attic dust from 201 houses built between 1879 and 1995 in New Jersey. The pattern of lead concentrations found in the attic dust closely approximated the time course of the lead emission from gasoline. The analysis of the data shows that very low lead deposition occurred during the 1990?s and late 1980?s. There was a moderate increase in lead deposition among the houses built during the 1970?s and a sharp increase for homes built in the 1960?s and 1950?s. For homes built prior to 1950, the attic lead remained at levels similar to those homes built in the 1950?s. The lead concentrations varied considerably from less than 100 ppm up to 5000 ppm. The older dwellings were more likely to contain lead concentrations above 1000 ppm although a few newer (post-1990) dwellings also had very high attic lead concentrations. Most homes contained leaded dust that could easily create a lead exposure hazard. * Two recent studies (An Exterior and Interior Leaded Dust Deposition Survey in New York City: Results of a 2-Year Study, 2005; A Survey of Spatially Distributed Exterior Dust Lead Loading in New York City, 2005, Jack Caravanos, Arlene L. Weiss, Rudolph J. Jaeger) conducted throughout the five boroughs of NYC measured lead dust deposited at scores of interior and exterior locations. Lead loadings were measured weekly and the cumulative rates of lead in dust deposited over 2 year?s time were determined. Median loadings of leaded dust on interior surfaces adjacent to open windows was 4.8 ug/ft2 per week. Exterior deposition was almost an order of magnitude higher. The data support the existence of a continuing source of deposited leaded dust in interior and exterior locations within NYC. Interior control plates with windows closed demonstrate that the source of the interior lead deposition was from exterior environmental sources. * The Environmental Protection Authority of New South Wales, Australia has long recognized that reservoirs of leaded dust in dwellings presents a most serious hazard when conducting renovation and remodeling, especially in older buildings. The NSW EPA published in 2003 Managing Lead Contamination in Home Maintenance, Renovation and Demolition Practices. A Guide for Councils (2003). In this Guide, they state, ?Unsafe home renovation is one of the most common causes of high lead levels in lead poisoning among children in NSW. Renovation can disturb lead-contaminated dust built up over many years in ceiling cavities, behind walls and between or under floorboards.? These conclusions were based on extensive sampling of ceiling and wall cavity dust from many communities in New South Wales. Summary Air deposition of leaded dust is still occurring today, but it was substantially greater three or more decades ago. Air deposition of fine lead particles produced reservoirs of leaded dust in sequestered wall cavities, spaces around doors and windows and in attics and above ceilings. These leaded dust reservoirs are greatest in older buildings. This accumulated leaded dust does not present an exposure problem until interior wall or ceiling ?seals? are disturbed. Even small cracks or holes release potentially hazardous quantities of fine leaded dust. This leaded dust exists independent of the presence of LBP. (Since both LBP and lead dust reservoirs are associated with ?age of house,? they will be correlated.) A major, and perhaps the major, source of lead released by RRP is not from LBP! Exempting buildings with no measurable LBP from lead-safe work practices will not protect residents, and especially young children. Additional Points ? EPA?s ?Dust Study? did not include houses without LBP. This is a most serious omission and flaw in the study design. What would EPA say if RRP work produced hazardous lead loadings in dwellings without LBP? ? Isotope ratio analysis of the blood-lead from EBL children demonstrates that the blood-lead rarely matches the LBP from the child?s residence. Rather, the lead in the child?s blood is far more likely to match the exterior soil or street dust. ? Isotope ratio analysis of leaded dust from floor and LBP from the same residence usually do not match. The source of interior leaded dust is usually from the soil of street dust outside the residence.