Draft
Deliberative
­
Do
Not
Cite
or
Quote
 
May
9,
2003
 
Page
1
EPA
Conference
Call
With
State,
Local,
and
Tribal
Government
Representatives
About
Possible
LBP
Activities
Framework
(
May
1,
2003)

1.
Summary
Discussion
and
Qs
&
As
on
"
Background
and
Rationale"
Document
Summary
Discussion:

Mike
Wilson
from
EPA
introduced
the
"
Background
and
Rationale"
document.
Briefly,
he:

°
Reviewed
EPA's
statutory
obligations
and
the
background
about
the
decisions
leading
to
the
current
regulatory
structure
and
requirements;
°
Highlighted
the
key
issues
that
EPA
has
encountered
in
implementing
the
current
regulatory
structure
and
activities;
and
°
Emphasized
that
EPA's
goal
is
to
reduce
the
burden
of
the
rule
that
regulates
lead­
based
paint
activities
while
still
achieving
the
agency's
statutory
responsibilities,
and
also
to
broaden
the
scope
of
the
rule
to
include
renovation
activities.

Questions
&
Answers:

Q:
Do
the
states
agree
with
the
five
issues
noted
on
page
2
of
the
Background
Document
 
namely,
that
the
following
implementation
issues
have
become
stumbling
blocks
to
widespread
adoption
of
abatement:
high
cost
of
abatement
services;
time
and
expenses
needed
to
comply
with
training
and
certification
requirements;
limited
availability
of
certified
contractors;
uneven
quality
of
work
performed
by
abatement
contractors;
and
perception
that
the
benefits
of
abatement
are
not
worth
the
costs?
(
Mike)
A:
Kerra,
Eileen,
and
Tom
all
agreed
that
these
issues
are
real
stumbling
blocks.
Eileen
noted
that
in
MD,
they
have
been
able
to
get
some
renovation
home
improvement
contractors
certified
in
lead
abatement.
Tom
suggested
that
the
biggest
problem
is
the
discrepancy
in
benefits
versus
costs
for
abatement
projects.
Jack
later
commented
that
in
ID,
the
issue
seemed
to
be
the
interplay
between
cost/
benefit/
risk,
with
cost
always
wining
over
the
other
2
factors.

Q:
Do
the
states
agree
that
the
same
kinds
of
work
activities/
methods
may
apply
to
both
abatement
&
renovation
projects?
(
Mike)
A:
Yes
­
2
(
unnamed)
participants
agreed
with
that.
Additionally,
Barry
noted
that
it
would
be
very
helpful
to
eliminate
or
reduce
the
discrepancies
between
EPA
and
HUD
requirements
wherever
feasible.
The
existing
differences
create
confusion
and
inefficiencies.
Draft
Deliberative
­
Do
Not
Cite
or
Quote
 
May
9,
2003
 
Page
2
2.
Summary
Discussion,
Qs
&
As,
and
Comments
on
"
Summary
Table"
&
"
Discussion"
Documents
Summary
Discussion:

Mike
Wilson
from
EPA
then
introduced
the
"
Summary
Table"
and
"
Summary
Table
Discussion"
documents,
which
describe
the
key
elements
of
a
possible
updated
framework.
Briefly,
he:

°
Described
the
key
types
of
changes
that
would
occur
across
10
key
components
of
the
current
regulatory
structure
if
the
updated
framework
were
adopted;
°
Noted
that
the
framework
would
apply
to
all
pre­
1978
housing;
°
Highlighted
that
the
framework
emphasizes
performance­
based
standards
for
work
practices
and
the
same
basic
standards
would
be
applied
to
hazard
reduction
and
renovation;
°
Emphasized
that
the
framework
seeks
to
reduce
training
and
other
costs
to
firms
doing
these
types
of
work;
and
°
Emphasized
the
importance
of
pending
results
of
several
current
research
efforts
in
understanding
the
updated
framework
(
see
Mike's
explanation
in
the
next
Section
3
of
these
notes).

Questions
&
Answers
and
Comments:

Q:
Is
EPA
considering
any
kind
of
recourse
when
a
renovator
fails
clearance
if
they
have
used
prohibited
practices?
(
Kerra)
A:
Yes.
The
contractor
would
have
to
work
in
accordance
with
the
clearance
standards,
which
will
be
in
the
rule.
So,
if
a
dwelling
unit
fails
clearance,
the
contractor
will
be
bound
to
reclean
and
retest
until
the
unit
passes
clearance.

Q:
Will
work
performed
by
Lead
Sampling
Technicians
(
LSTs)
need
to
be
reviewed
by
an
inspector,
assessor,
etc?
(
Kerra)
A:
No,
EPA
is
envisioning
that
LSTs
would
operate
independently.
An
LST
would
be
required
to
be
trained
and
certified.

Kerra:
From
industry
standpoint,
4
hours
of
training
is
NOT
going
to
be
enough
for
someone
to
go
out
and
conduct
an
effective
clearance
exam.
[
Note:
Kerra
submitted
additional
written
comments
on
LST
as
a
discipline.
These
comments
are
provided
immediately
following
this
Answer.]
Gary:
Seconded
Kerra's
concern
 
that
w/
o
modification
to
the
existing
LST
training
course,
the
preparation
for
LSTs
would
be
grossly
inadequate.
Mike:
So,
a
certified
risk
assessor
should
sign­
off
on
the
work
of
a
LST?
Gary:
No,
creating
a
second
layer
of
review
is
not
desirable.
His
concern
is
with
the
course
itself.
EPA
needs
to
restructure
the
course
itself
so
the
LSTs
can
do
it
themselves,
Draft
Deliberative
­
Do
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Quote
 
May
9,
2003
 
Page
3
w/
o
having
another
layer
of
review/
sign­
off.
Additional
Written
Comments
Concerning
Lead
Sampling
Technician
Discipline
(
Kerra)

"
Please
do
not
create
a
discipline
for
Lead
Sampling
Technician
Discipline.
We
believe
the
current
4­
hour
training
curriculum
to
be
woefully
inadequate
for
allowing
an
individual
to
independently
perform
dust
sampling
and
declare
a
property
"
lead
safe"
after
lead
hazard
reduction
or
renovation.

Oklahoma
uses
the
National
Certification
Examination.
According
to
Oklahoma's
records,
Risk
Assessors
miss
clearance
questions
at
a
rate
of
31%.
That's
after
40
hours
of
training
and
a
high
school
diploma
or
bachelor's
degree.

Please
also
consider
the
following
comparison.

LBP
Inspectors
are
required
to
take
24
hours
of
training
with
no
further
education
requirements.
LBP
Inspections
are
relatively
simple
to
do
with
XRF
instruments.
There
is
little
room
for
human
error
with
regards
to
an
XRF
reading.
The
HUD
Guidelines
have
established
inspection
protocols
that
make
test
location
selection
a
simple
task.

The
Lead
Sampling
Technician
will
face
these
tasks:

°
Determine
what
hazard
reduction
activities
have
been
performed
and
which
rooms
have
been
treated.
Sometimes
the
property
owner
will
provide
this
information,
other
times
the
individual
performing
clearance
must
figure
this
out
on
their
own.
°
Determine
which
rooms
were
contained,
if
at
all.
°
Using
the
above
information,
select
number
of
rooms
for
dust
sampling.
°
Perform
the
wipe
sampling
on
the
selected
floors,
windowsills
and
troughs.
Use
gloves
and
decontaminate
templates
between
samples
to
prevent
cross
contamination.
*
This
step
leaves
much
more
opportunity
for
human
error
in
taking
a
dust
wipe
sample
than
an
XRF
reading.
°
Ensure
that
samples
are
properly
labeled
with
a
completed
chain­
of­
custody
form
and
include
blank
wipes
as
appropriate.
°
Send
samples
to
NLLAP
lab.
°
Evaluate
samples
upon
receipt
and
send
findings
to
customer.
*
In
the
case
of
renovations
performed
with
federal
assistance,
the
clearance
examiner
will
also
have
to
write
a
report.

A
4­
hour
training
curriculum
is
not
enough
time
to
discuss
liability
and
insurance
needs,
lead
hazard
reduction
methods,
containment,
dust
sampling
techniques,
sample
interpretation
and
report
content
requirements.
A
clearance
inspector
needs
training
in
all
of
these
areas
to
perform
clearance
properly.
Considering
all
of
these
tasks,
a
Lead
Sampling
Technician
should
really
have
a
minimum
of
8
hours
of
training
with
a
minimum
of
2
hours
of
hands­
on
instruction
to
ensure
they
can
properly
perform
the
wipe
sampling.
A
minimum
of
8
hours
of
training
is
still
pushing
it!
Draft
Deliberative
­
Do
Not
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or
Quote
 
May
9,
2003
 
Page
4
I
also
have
a
gut
feeling
that
these
individuals
will
charge
nearly
the
same
amount
for
a
clearance
that
certified
Inspectors
and
Risk
Assessors
have
been
charging,
because
Inspectors
and
Risk
Assessors
have
set
the
market
prices
for
clearance.
The
housing
industry
will
not
see
a
cost
savings
as
a
result
of
EPA
creating
certification
for
this
`
stripped­
down
discipline.'"
(
Kerra)

Comment:
Jack
thought
it
would
be
helpful
to
have
documentation
re.
point
8
(
prohibited
practices)
re.
what
is
and
what
is
not
allowed,
disadvantages
&
disadvantages,
cost
issues,
etc.
Mike
responded
that
EPA
will
need
to
support
the
standards/
requirements
at
the
time
any
rule
on
this
topic
is
published.

Q:
Would
training
for
the
project
designer
(
PD)
increase
from
8
to
16­
24
hours,
while
the
training
for
supervisors
would
decline
from
32
to
8­
16
hours?
(
Gary)
A:
In
general,
EPA
would
like
to
see
supervisors
training
requirements
decrease,
while
PD
requirements
would
increase.
EPA
will
need
to
look
at
the
existing
courses,
revise
them
per
the
final
rule/
policies,
and
then
see
how
long
the
courses
will
need
to
last.

Comment:
Barry
noted
that
there
is
not
much
interest
in
the
PD
course
in
KS.
Mike
said
that
EPA
recognizes
this
concern.
He
noted
that
initially
there
was
a
proposal
that
projects
greater
than
10
units
would
need
a
PD,
but
that
requirement
was
dropped
from
the
final
abatement
regulations
as
they
currently
stand.
So,
there
is
no
current
difference
between
PDs
and
supervisors,
except
a
PD
can't
oversee
work.
Thus,
there
is
no
real
benefit
for
doing
the
extra
PD
training,
etc.

Q:
What
will
a
PD
do?
(
Gary)
A:
Given
requirement
for
accredited
supervisors,
any
firm,
including
renovators,
that
is
trained
in
how
to
contain,
minimize
dust
generation,
and
cleanup
would
be
able
to
do
hazard
reduction
(
HR)
work.
So,
a
risk
assessor
would
ID
lead
hazards
in
a
home
(
e.
g.,
windows
w/
lead
paint);
the
PD
would
develop
the
PD
Plan
to
address
the
hazards;
and
the
renovation
firm
could
perform
the
hazard
reduction
as
long
as
it
follows
proper
HR
procedures,
which
will
include
avoiding
the
use
of
prohibited
practices
(
i.
e.,
a
renovator
could
do
the
HR
following
the
PD
Plan).

Q:
Both
HR
and
renovators
would
have
performance­
based
standards,
while
HR
also
has
PD
requirements.
But
either
HR
or
renovation
firm
could
do
the
work?
(
Gary)
A:
Yes.

Q:
Is
it
an
"
independent
3rd
party"
doing
the
PD?
(
Bob)
A:
PD
could
be
on
the
staff
at
the
HR
firm.
They
don't
have
to
be
"
independent
3rd
party."

Q:
Regarding
training
and
certification
of
supervisors
and
PDs
 
is
there
some
3rd
party
testing
of
supervisors?
(
Kerra)
A:
3rd
party
testing
would
be
required.
Draft
Deliberative
­
Do
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or
Quote
 
May
9,
2003
 
Page
5
Q:
What
about
3rd
party
testing
for
PDs?
(
Kerra)
A:
Yes,
EPA
will
consider
3rd
party
testing.

Q:
What
about
3rd
party
PDs?
An
HR
or
renovation
firm
may
employ
their
own
PD
for
developing
design
specs.
Can
that
same
firm
also
employ
their
own
LSTs
to
clear
their
work?
(
Gary)
A:
An
Occupant
Protection
Plan
(
OPP)
is
currently
required,
Supervisors
and
PDs
do
that
now.
EPA
would
be
interested
in
input
regarding
in­
house
vs.
3rd
party
LSTs.

Q:
I
understand
that
it's
a
supervisors
and
PD
issue
now.
But,
if
EPA
requires
a
PD
for
HR,
it's
very
little
change
as
far
as
I
can
see.
Is
there
an
implied
conflict
of
interest
(
COI)
if
the
person
is
designing
the
project,
turning
it
around
to
a
person
to
do
the
abatement,
and
then
clearing
it
with
their
own
people?
Did
any
discussion
address
the
"
industry
feeding
on
regulation"
aspect?
(
Gary)
A:
Under
current
framework,
PD
could
be
employed
by
the
firm
doing
the
work.

Comment:
There's
an
historic
perspective
on
this
COI
issue
re.
asbestos.
Issues
arose
when
PDs
would
plan,
design,
and
abate
asbestos.
Now,
the
PD
can
NOT
be
the
contractor.
(
Gary)

Q:
Will
states
continue
to
be
able
to
have
more
stringent
programs
under
40
CFR?
(
Gary)
A:
Yes,
states
can
continue
to
be
more
stringent
than
the
federal
program.

Q:
How
will
this
impact
the
406
Pre­
Renovation
Education
rule?
(
Tom)
A:
Hopefully,
we
will
see
more
compliance
with
the
406
program
under
this
new
framework.
EPA
is
also
considering
some
changes
to
the
406
rule,
developing
a
more
targeted
brochure,
etc.

Q:
Who's
the
EPA
point
of
contact
on
406?
[
Two
states
(
Iowa
and
Kansas)
and
1
tribe
have/
are
seeking
authorization
for
406.]
(
Tom)
A:
Mike
Wilson.

Comment:
Kerra
submitted
the
following
written
questions
on
the
LBP
Certification/
Training
framework.

Additional
Written
Questions
on
the
LBP
Certification
Training/
Framework
(
Kerra)

Q:
"
Is
it
EPA's
proposal
that
all
renovation
companies
that
work
on
pre­
1978
housing
be
certified
firms?"
Will
it
be
one
time
only
or
will
renewal
be
necessary?
What
is
the
purpose
of
certifying
renovation
companies?
Under
that
requirement,
will
landlords
have
to
become
certified
firms?"
(
Kerra)
A:
Draft
Deliberative
­
Do
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or
Quote
 
May
9,
2003
 
Page
6
Q:
"
Will
the
revised
supervisor
training
still
address
liability
and
insurance
issues
for
lead
hazard
reduction
activities?"
(
Kerra)
A:

Q:
"
Will
the
third
party
certification
exam
still
apply
to
certified
Supervisors
or
will
it
be
revised
and
required
for
Project
Designer
certification?"
(
Kerra)
A:

Q:
"
Please
explain
what
options
EPA
is
considering
for
on­
the­
job
training
for
leadhazard
reduction
workers.
Will
a
certified
supervisor
need
to
be
present
at
all
times
for,
say,
40­
hours
of
on­
the­
job
training?"
(
Kerra)
A:

Q:
"
Is
EPA
planning
to
include
power
washing
as
a
prohibited
work
practice?
Typically
this
activity
will
cause
paint
chips
to
migrate
to
adjacent
properties."
(
Kerra)
A:

Q:
"
Is
EPA
considering
requiring
a
lead
hazard
reduction
if
a
risk
assessment
found
lead
hazards
at
a
property?"
(
Kerra)
A:

Q:
"
Will
EPA
require
clearance
with
laboratory
analysis
after
renovation
in
a
property
where
a
child
(
6
or
under)
resides
or
visits
regularly
(
targeting
the
protection
for
children)?
Is
EPA
or
other
states
facing
any
barriers
to
such
a
requirement?"
(
Kerra)
A:

Q:
"
Is
EPA
considering
requiring
clearance
based
on
the
age
of
the
home?
Example:
Homes
built
before
1960
have
a
much
greater
chance
of
containing
LBP
than
homes
built
1960­
1978."
(
Kerra)
A:

Q:
"
If
a
renovation
fails
clearance,
will
it
be
the
renovation
company's
responsibility
to
re­
clean
until
clearance
is
achieved
or
will
they
be
required
to
hire
a
certified
supervisor
to
re­
clean
and
obtain
clearance?"
(
Kerra)
A:

Q:
"
What
requirements
is
EPA
considering
for
Lead
Hazard
reduction
in
properties
were
an
EBL
Child
has
been
identified?
For
instance
some
states
may
require
certified
abatement
workers
to
perform
lead
hazard
reduction
in
that
property."
Draft
Deliberative
­
Do
Not
Cite
or
Quote
 
May
9,
2003
 
Page
7
(
Kerra)
A:
Draft
Deliberative
­
Do
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9,
2003
 
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8
3.
Summary
Discussion,
Qs
&
As,
and
Comments
on
Research
Projects
Underway
Colormetric
Swab
Test
Kits
HUD
is
conducting
a
study
of
the
ability
of
these
swab
tests
to
ID
LBP.
Should
it
be
determined
that
swab
tests
are
effective,
home
owners
may
test
on
disturbed
surfaces
at
low
cost.
If
not
effective,
then
the
only
ways
to
determine
the
presence
of
LBP
remain
the
higher
cost
methods
of
XRF
testing
or
laboratory
analysis
of
paint
samples.

Q:
If
the
swabs
are
not
effective,
should
the
framework
discussed
be
applied
only
to
pre­
50/
60
housing?
Or
just
to
multi­
family
dwellings?
(
i.
e,
where
there
is
still
a
greater
likelihood
of
LBP?)
(
Mike)
A:
Even
if
the
swab
test
does
work,
EPA
may
want
to
explore
moving
the
emphasis
to
pre­
50/
60
housing.
If
EPA
is
interested
in
reducing
childhood
exposure,
he
recommends
focusing
on
pre­
50
housing.
(
Barry)
Echoes
Barry's
point
­
focus
on
pre­
50
housing.
(
Kerra)
[
Note:
Kerra
submitted
additional
written
comments/
questions
on
swab
tests,
which
are
provided
immediately
below.]

Additional
Written
Comments/
Questions
Concerning
Swab
Tests
(
Kerra)

"
Pending
the
results
of
the
swab
study,
is
EPA
considering
the
following
for
renovation
activities:
(
a)
Allowing
supervisors
to
determine
whether
or
not
LBP
is
present
with
a
swab.
(
b)
Conduct
either
renovation
or
lead
hazard
reduction
based
on
the
results
of
that
swab.
(
c)
Perform
a
visual
clearance
on
this
work
and
call
it
`
good.'"
(
Kerra)

Q:
"
Is
EPA
considering
restrictions
to
prevent
supervisor's
from
finding
a
way
to
either
falsify
the
results
of
the
swab
to
avoid
the
work
practice
prohibitions
and/
or
clearance
or
scare
the
property
owners
into
paying
extra
for
lead
hazard
reduction
when
it
isn't
necessary?"
(
Kerra)
A:

Use
of
Electrostatic
Clothes
("
Swiffers")

EPA
is
studying
whether
swiffers
could
be
used
for
cleaning
and
determining
if
the
job
clears
and
passes
the
lead
hazard
standard.
The
research
is
not
complete,
but
there
is
some
preliminary
evidence
that
swiffers
perform
better
than
dust
wipe
sampling
in
picking
up
lead
dust,
and
may
be
more
effective
in
cleaning
surfaces
to
a
level
under
the
40
micrograms
standard.
[
Also,
a
dust
wipe
sample
is
limited
to
1
sq.
foot
surfaces,
while
a
swiffer
would
be
used
over
the
whole
work
area,
so
greater
assurance
that
the
levels
would
be
less
than
40
micrograms.]
A
swiffer
test
could
reinforce
the
idea
of
renovation
with
voluntary
dust
sampling
­
so
not
only
cleanup,
but
also
Draft
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clearance.
The
overarching
question
is,
how
clean
should
the
swiffer
be
after
covering
the
entire
work
area?
(
Mike)

Q:
Use
a
swiffer
with
a
visual
comparison?
On
bare
floors,
or
window
sills,
or
walls,
or
carpets?
(
Gary)
A:
First
the
visual,
then
a
final
swiffer
pass
through
over
the
entire
work
area
(
although
looking
at
carpeting,
more
than
likely
it
will
be
on
bare
floors;
not
sure
about
window
sills).

Q:
Are
there
any
test
glitches
with
swiffer
versus
a
lab
(
e.
g.,
laboratory
digestibility
of
wipes)?
(
Bob)
A:
EPA
is
envisioning
setting
a
swiffer
standard.
After
the
person
conducts
the
swiffer
pass
through,
if
their
lead
count
is
less
than
the
EPA
standard,
than
s/
he
is
done.
No
lab
analysis
is
anticipated.

Q:
Are
swiffer
tests
in
conflict
with
HUD
section
1012/
1013.
Has
EPA
sought
contact
from
HUD?
Particularly
re.
renovation
and
potential
COI
issue.
(
Bob)
A:
No,
EPA
has
not
been
in
formal
contact
with
HUD
at
this
time.
But
EPA
thinks
that
75
percent
of
the
requirements
are
similar
­
it's
renovation
that
is
different.

Q:
Is
EPA
planning
on
making
any
kind
of
national
data
base
of
renovation
forms
available
to
states
(
e.
g.,
based
on
SIC
or
NAICS
code)?
This
is
a
monumental
undertaking
to
track
down
and
certify
implementation
and
phase­
in
of
this
new
program
­
will
have
significant
non­
compliance
for
many
years
to
come.
(
Gary)
A:
EPA
will
think
about
this.
Mike
recognizes
that
compliance
would
be
an
issue.

Q:
Will
EPA
try
to
classify
renovation
firms?
(
Gary)
A:
EPA
is
open
to
suggestions
­
now
thinking
that
any
frm
that
disturbs
surface
over
some
deminimis
level.

Comment:
Kerra
submitted
the
following
written
comments/
questions
on
the
swiffer.

Additional
Written
Comments/
Questions
Concerning
Electrostatic
Wipe
"
Swiffer"
Study
for
Clearance
(
Kerra)

"
Allowing
a
certified
supervisor
to
detect
LBP
with
a
swab
and
perform
`
Swiffer'
clearance
for
a
renovation
almost
removes
the
need
to
have
a
certified
LBP
Inspector
Discipline,
unless
the
requirements
and
duties
are
dictated
in
the
rule."
(
Kerra)

Q:
"
What
age
properties
are
being
included
in
this
study?"
(
Kerra)
A:

Q:
"
What
is
the
geographic
location
of
properties
in
this
study?"
(
Kerra)
Draft
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9,
2003
 
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A:

Q:
"
Is
the
study
considering
the
differences
in
concentration
of
lead
in
paint
at
different
properties?"
(
Kerra)
A:

Q:
"
Is
EPA
considering
the
reliability
of
`
Swiffer'
clearance
in
areas
of
high
environmental
lead
contamination
such
as
the
Tar
Creek
Superfund
site
in
Oklahoma?"
(
Kerra)
A:

Comment:
EPA
will
have
to
be
able
to
justify
changes
&
their
associated
costs,
given
the
decline
in
lead
that's
attributable
to
lead
phase­
out
in
gasoline,
paint,
mining
etc.
(
Jack)

Mike
agreed
­
the
preamble
will
have
to
justify
all
changes.
Draft
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9,
2003
 
Page
11
4.
Further
Information
as
Requested
in
Advance
of
May
15,
2003,
Follow­
up
Call
Background
on
Blood
Lead
Levels
Over
Time,
and
Timing
of
Changes
in
Threshold
There
are
several
indications
that
lead
levels
have
dropped
over
time
(
i.
e.,
that
the
lead
problem
has
decreased
over
time):

°
CDC's
recent
data
halved
the
number
of
kids
w/
elevated
lead
levels
 
from
890,000
to
425,000.
°
HUD's
2000
National
Survey
showed
that
incidence
of
LBP
in
pre­
78
housing
dropped
from
67
percent
to
40
percent;
in
housing
built
between
1960
and
1978,
incidence
dropped
from
about
62
percent
to
24
percent.
°
An
estimated
18
percent
of
these
homes
had
kids
under
age
6
­
so
18
percent
of
24
percent
is
less
than
5
percent
(
i.
e.,
very
low
percent).

Examples
of
Successful
Approaches
in
Addressing
Lead­
based
Paint
and
Reducing
Lead
Poisonings
States
and
localities
have
developed
several
different
types
of
approaches
in
response
to
their
specific
needs
and
circumstances.
There
are
a
range
of
approaches
used
by
housing
and
health
departments
at
the
state
and
local
level
to
improve
lead
safety.
For
example,
some
states
and
localities
have
established
lead
hazard
reduction
or
essential
maintenance
practices
requirements
and
programs.
Training
for
property
owners
and
contractors
is
offered,
and
then
interventions
using
specific
work
practices
must
be
performed
in
target
housing
based
on
certain
trigger
events
(
e.
g.,
at
occupancy
turn­
over
in
rental
housing).
In
contrast,
some
local
jurisdictions
have
targeted
specific
areas/
neighborhoods
with
high­
risk
housing
for
lead
hazard
reduction
programs
and
assistance.
Key
considerations
are
local
capacity
and
infrastructure,
nature
of
housing
stock
and
its
condition,
and
the
extent
of
presence
of
lead­
based
paint.
The
National
Conference
of
State
Legislatures
is
a
good
resource
for
learning
more
about
the
different
approaches
taken
and
lessons
from
them.

Also,
HUD
administers
a
national
lead
hazard
control
grant
program
that
supports
state
and
local
demonstration
programs.
More
information
about
these
grantees
and
lessons
from
their
efforts
can
be
found
at
www.
hud.
gov/
offices/
lead.

Further
information
is
available
at
EPA's
National
Lead
Information
Center
Clearinghouse
at
www.
epa.
gov/
lead/
nlic,
and
EPA's
Lead
Program
at
http://
www.
epa.
gov/
lead.

Valuable
information
and
guidance
about
lead­
safe
work
practices
can
be
found
in
EPA's
training
course,
"
Minimizing
Lead­
Based
Paint
Hazards
During
Renovation,
Remodeling,
and
Painting,"
and
"
Lead
Paint
Safety:
A
Field
Guide
for
Painting,
Home
Maintenance,
and
Renovation."
Draft
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9,
2003
 
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Determining
the
Appropriate
Classification
of
an
Activity
When
Definitions
Overlap
It
depends
on
the
intent
of
the
job
and
the
type
of
work
the
consumer
requests.
With
respect
to
window
replacement,
for
example,
if
the
purpose
of
the
job
is
to
address
a
known
lead­
based
paint
hazard
by
replacing
the
window,
then
the
activity
would
be
classified
as
abatement.
If
the
purpose
of
the
job
is
to
improve
the
energy
efficiency
of
the
home
by
replacing
some
or
all
of
the
existing
windows
and
there
is
no
information
about
the
presence
of
lead­
based
paint,
then
the
replacement
would
be
considered
renovation.

Information
about
the
Success
of
R&
R
with
Lead­
safe
Work
Practices
in
Reducing
Lead
Hazards
EPA
does
not
yet
have
formal
research
results
about
the
performance
of
renovation
jobs
that
follow
lead­
safe
work
practices.
However,
the
lead­
safe
work
practices
guidance
and
training
issued
by
EPA
are
based
on
field
research
on
lead
exposure
and
lead
hazards
generated
during
renovation
and
remodeling
activities
(
see
EPA
747­
R­
96­
005).
Draft
Deliberative
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Quote
 
May
9,
2003
 
Page
13
5.
Workgroup
Participants
on
the
May
1,
2003,
State,
Local
and
Tribal
Government
Stakeholder
Group
Call
Legislators
The
Honorable
Jack
Barraclough,
Idaho
House
of
Representatives
State
Programs
Barry
Brooks
Kansas
Department
of
Health
and
Environment
Childhood
Lead
Poisoning
Prevention
Program
Tom
Morey
Kansas
Department
of
Health
and
Environment
Childhood
Lead
Poisoning
Prevention
Program
Gary
Flentge
Illinois
Department
of
Public
Health
Environmental
Lead
Program
Bob
Ford
Utah
Department
of
Environmental
Quality
Division
of
Air
Quality
Kerra
Rouderbush
Oklahoma
Department
of
Environmental
Quality
Air
Quality
Division
Housing
Programs
Eileen
Hagan
Maryland
Department
of
Housing
and
Community
Development
Linda
Thompson
Council
of
State
Community
Development
Programs
Washington,
DC
