The U.S. Environmental Protection Agency (EPA) is asking for
input on its newly released “Framework for Identifying and Evaluating
Lead-Based Paint Hazards from Renovation, Repair, and Painting Activities in
Public and Commercial Buildings.” The purpose of this Framework document is to
allow EPA to determine if renovation, repair and painting activities in public
and commercial (P&C) buildings do, in fact, create a lead-based paint
hazard. If EPA’s analysis indicates that
hazards are created, then the agency would propose appropriate regulatory
controls to reduce or prevent exposure to the general population.
To read the Federal Register announcement and the Framework
document, click
here. Public comments are due by
June 30.
EPA will consider all public comments as it continues the
process of assessing whether or not “hazards” are created by P&C building
renovations. By July 2015, EPA plans to propose nationwide legal requirements
to reduce any hazards, if found. Such
new requirements would also undergo public review and comment and would most
likely stem from the current Lead
Renovation, Repair and Painting (LRRP) rule.
Hazard Identification
The Framework document explains, in general terms, how EPA
would define a “lead‐based paint hazard” – solely for the purposes of
evaluating how interior and exterior renovation work affect the dust-lead
levels inside P&C building.
According to the document, a “hazard” would be identified as any
renovation condition or situation that exposes a group of occupants (e.g.,
children or adults) to levels of lead-paint dust that would result in adverse
health effects. For children, EPA would likely evaluate Intelligence Quotient
(IQ) decrements. For adults, EPA anticipates that it will consider
concentration-response functions, such as renal effects, cardiovascular effects
and others; however, EPA is reviewing currently available scientific literature
to determine if appropriate adverse health effects for adults can be selected
and analyzed.
Hazard Evaluation
In addition, the Framework describes a “scenario‐specific
approach” to assessing risk that EPA says is “designed to account for the
variable amounts of time spent in P&C buildings, the broad heterogeneity in
building sizes and configurations, and the short‐term nature of the exposure
resulting from renovation activities.”
EPA would model different types of interior/exterior renovation
activities on variety of building types and attempt to determine the lead-dust
levels that would be generated, in each instance. EPA would then evaluate whether or not – and
for how long – different age groups of occupants might be exposed to lead dust
and the resultant impact on their blood-lead levels and other health-based
functions. The document states that EPA would assess a “broad range of
scenarios, considering variations in types of renovation activities, building
types, sizes and configurations, use and occupancy patterns, cleaning
frequencies, etc., which are designed to be reflective of actual P&C
building settings.” For those scenarios where EPA’s models show adverse health
effects, EPA would make a “hazard” finding.
If EPA decides to move forward with this scenario‐specific
approach, the agency would use it to identify hazards inside P&C buildings
resulting from renovations of the same or nearby P&C building. The approach
would NOT address hazards to passers‐by or individuals that could be
exposed to lead outside of P&C buildings through air, soil, or other media,
or for exposure at homes and child-occupied facilities (COFs), for which
federal hazard standards are already established.
More Rules?
For those renovation activities in P&C buildings that
create lead‐based paint hazards, the federal Toxic Substances
Control Act (TSCA) directs EPA to address the hazards through regulation. EPA
would craft new regulatory requirements to apply only to those renovation
activities and P&C building categories where the modeled scenarios show an
exposure that would be deemed hazardous.
Applicability
EPA acknowledges that its analysis could indicate hazards in
scenarios that are unlikely to occur, or occur in only very limited instances
affecting a small number of people. EPA would consider how to generalize the
hazard findings from the scenario‐specific analysis to assess the
effects of a potential regulation on the population (and on sensitive sub‐populations)
in considering regulatory options
Nearby Residences and
Child-Occupied Facilities
EPA also is considering how to evaluate whether exterior
renovations of P&C buildings would pose a health risk to the occupants of
nearby homes and child-occupied facilities. EPA already has dust‐lead
hazard standards place for residences and COFs. Specifically, lead is
considered a hazard when equal to or exceeding 40 micrograms of lead in dust
per square foot on floors (40 µg/ft2 for floors) and 250 micrograms of lead in
dust per square foot on interior window sills (250 µg/ft2 for interior window
sills).
Background
Currently, EPA’s Lead Renovation, Repair and Painting (LRRP)
rule applies to paid contractors working in pre-1978 housing and a small subset
of P&CBs; specifically, buildings where children under 6 years spend
significant amounts of time such as daycare centers and schools (commonly
called “child-occupied facilities”).
The rule requires that renovators are trained in the use of
lead safe work practices, renovators and construction firms be certified,
providers of renovation training be accredited, and that renovators follow
specific work practice standards. It
includes provisions for the retention of compliance records, and the
verification of compliance with work practice obligations, as well as pre-renovation
education requirements (i.e., the distribution of EPA pamphlets and document
compliance).
Additional
information is on EPA’s website at http://www.epa.gov/lead/pubs/renovation.htm.
Click here
for AGC’s summary of what the current lead-paint rules require. If you have
additional questions, contact AGC’s Leah Pilconis at pilconisl@agc.org.
Source: AGC
of America
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