Draft
Deliberative
­
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Not
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or
Quote
 
June
9,
2003
 
Page
1
EPA
Conference
Call
With
Industry
Representatives
About
Possible
LBP
Activities
Framework
(
May
29,
2003)

1.
Summary
Discussion,
Qs
&
As,
and
Comments
Introduction
&
Background
In
response
to
questions
that
EPA
received
following
the
May
9
conference
call,
Mike
Wilson
(
EPA)
opened
the
discussion
by
clarifying
that
EPA
is
considering
two
tracks
for
implementation
of
lead­
safe
work
practices
(
LSWP)
by
renovation
and
remodeling
(
R&
R)
contractors:

1.
A
regulatory
track,
which
we
are
discussing
today.
Since
this
approach
involves
significant
effort
and
is
specified
by
statute,
EPA
needs
to
carefully
examine
how
this
track
could
be
implemented
and
its
likely
impact.
Work
on
this
track
has
been
somewhat
delayed
due
to
the
extent
of
the
rule's
scope
and
the
fact
that
the
regulatory
process
is
generally
lengthy.

2.
A
voluntary
program,
which
EPA
has
discussed
externally
at
other
meetings
(
e.
g.,
PDCA
conference).
Because
the
regulatory
track
takes
time
to
finalize,
EPA
is
pursuing
a
voluntary
approach
as
a
more
timely
way
to
get
contractors
to
integrate
LSWP
in
their
daily
work
practices.
It
will
be
a
membership
program,
with
a
logo,
marketing
to
homeowners
to
seek
out
member
contractors,
etc.
EPA
plans
to
launch
the
voluntary
program
in
summer
2003
and
sees
the
experience
and
success
of
the
voluntary
program
as
helping
to
frame
any
ultimate
regulatory
framework.

Eric
Oetjen
from
ICF
Consulting
served
as
the
facilitator.
He
asked
participants
to
focus
their
comments
on
the
following
five
overarching
topics
of
primary
interest
to
EPA:

1.
Expanding
Capacity.
Will
the
updated
framework,
as
currently
described,
increase
the
number
of
firms
that
perform
hazard
reduction,
including
interim
controls
(
ICs)?
Increase
the
use
of
lead­
safe
work
practices
(
LSWP)
during
renovation
and
remodeling
(
R&
R)
activities
in
target
housing?

2.
Unintended
Impacts
on
ICs
and/
or
Use
of
LSWP.
Are
there
aspects
of
the
framework
which,
in
their
opinion,
will
hinder
or
discourage
use
of
firms
performing
ICs
or
using
LSWP
during
R&
R?

3.
Other
Impacts
on
Industry.
What's
the
overall
impact
on
the
abatement
industry?
On
the
R&
R
industry?

4.
Cost
and
Quality
of
Lead­
based
Paint
(
LBP)
Services.
What
are
the
cost
implications
of
the
possible
framework
changes?
Are
there
any
quality
implications?

5.
Other
Implementation
Issues.
What
other
implementation
issues
do
they
foresee?
Are
there
things
that
EPA
should
be
thinking
about
that
impact
practical
implementation
of
the
framework?
Draft
Deliberative
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or
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June
9,
2003
 
Page
2
Preliminary
Qs
and
As,
and
Comments
Before
discussing
these
five
topics,
participants
had
some
general
questions
and
comments
regarding
the
regulatory
and
voluntary
tracks:

Q:
It
seems
that
the
voluntary
initiative
could
save
all
parties
a
lot
of
headaches.
So
instead
of
focusing
today's
discussion
on
the
regulatory
approach,
could
we
focus
instead
on
the
voluntary
approach?
(
Jeff)
A:
Today,
it
is
important
for
EPA
to
focus
on
the
regulatory
approach.
We
have
received
good
feedback
on
the
voluntary
track
from
the
organizations
that
EPA
has
approached,
and
the
Agency
hopes
to
kick
off
the
program
later
this
year.
Group
members
can
provide
specific
suggestions
on
the
voluntary
approach
along
with
any
written
comments
on
the
possible
framework
for
the
regulatory
approach.
(
Mike)

Q:
How
will
EPA
define
"
usually
successful"
in
terms
of
showing
success
under
a
voluntary
approach
­
specifically,
success
that
might
preclude
the
need
for
EPA
to
go
forward
with
regulations?
(
Kevin)
A:
The
regulatory
program
will
affect
250,000+
contractors
nationwide,
most
of
whom
are
small
(
e.
g.,
single
employee),
unlicenced
entities.
So
the
question
becomes,
what
is
the
best
way
to
reach
them?
The
voluntary
initiative
can
readily
target
larger
contractors
through
trade
associations,
i.
e.,
firms
with
employees,
that
are
licensed,
bonded
and
insured,
etc.
If
the
voluntary
initiative
can
get
these
large
contractors
to
join
and
branch
out
to
smaller
contractors,
EPA
may
reconsider
the
need
for
a
regulatory
program.
(
Mike)

Q:
How
would
you
measure
success?
(
Brandt)
A:
The
voluntary
program
is
building
reporting
mechanisms
to
receive
feedback
from
national
organizations
and
individual
contractors.
So,
EPA
will
have
information
on
which
to
make
decisions
re.
next
steps
with
any
regulatory
program.
(
Mike)

Q:
If
EPA's
voluntary
initiative
is
hugely
successful,
it
may
not
be
necessary
to
pursue
a
regulatory
track
at
all.
Is
there
really
the
need
for
both
tracks
to
run
at
once?
(
Brandt)
A:
Yes.
Most
contractors
do
not
use
LSWP
(
one
example
is
data
from
previous
studies
in
Philadelphia).
If
the
voluntary
program
can
get
more
or
most
contractors
to
use
LSWP,
then
that
might
minimize
the
need
for
a
regulatory
program.
(
Mike)

Q:
How
does
EPA
arrive
at
the
conclusion
that
"
most"
contractors
are
not
using
LSWP?
(
Kevin)
A:
EPA
does
not
have
systematic
national
data,
but
the
studies
that
have
been
done
offer
evidence
that
contractor
use
common
work
practices
that
can
create
lead
dust
hazards
when
used
on
surfaces
where
LBP
is
present.
The
contractors
on
this
call
are
the
"
cream
of
the
crop"
­
the
ones
that
use
best
methods.
EPA
believes
that
typical
contractors
use
general
use
more
traditional
methods.
For
example,
shop­
vac,
dry
broom
sweeping,
etc.,
which
are
good
for
general
cleanup,
but
not
effective
at
getting
floors
clean
to
the
lead
standard.
(
Mike)
Draft
Deliberative
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June
9,
2003
 
Page
3
Comments
°
Echoed
Kevin's
concern
over
EPA's
statement
regarding
lack
of
use
of
LSWP
by
contractors.
She
does
not
see
the
numbers
EPA
is
talking
about
in
terms
of
widespread
non­
compliance.
Wants
to
see
the
data.
(
Amy)
Acknowledges
her
request
for
data.
(
Mike)

°
I
didn't
think
the
regulatory
framework
went
beyond
R&
R.
(
Jeff)
Confirmed
that
the
framework
addresses
hazard
reduction
(
abatement
and
ICs)
and
LSWP
during
R&
R.
(
Mike)
Then
there's
a
huge
enforcement
issue.
Contractors
will
not
comply,
and
there
will
not
be
enough
enforcement
staff
to
enforce
the
requirements.
Education
is
the
answer,
not
regulation.
(
Jeff)

Topic
1:
Expanding
Capacity
Question
Posed
by
EPA:
Will
the
updated
framework,
as
currently
described,
increase
the
number
of
firms
that
perform
hazard
reduction,
including
ICs?
Increase
the
use
of
LSWP
during
R&
R
activities
in
target
housing?

Answers,
Comments,
and
Other
Qs
and
As
Number
of
firms
may
increase:

°
Initial
information
does
suggest
that
the
framework
will
increase
the
number
of
firms
doing
IC
and
using
LSWPs.
However,
training
expenses
are
going
to
increase
with
the
rule
(
see
Topic
2
below).
(
Patrick)

°
Agrees
with
Patrick
 
framework
may
expand
capacity
to
do
hazard
reduction
and
IC,
but
creates
problems,
too
(
see
Topic
2
below).
(
Amy)

Number
of
firms
may
decrease:

°
Concerned
about
a
decrease
in
capacity.
Homeowners
in
pre­
1978
are
essentially
being
penalized
by
having
to
have
contractors
do
additional
things.
Working
on
pre­
1978
homes
is
already
tough;
it's
harder
to
make
money
on
some
of
these
jobs.
So
may
see
contractors
pull
out
of
R&
R
market
for
older
homes.
Has
specific
concerns
with
two
elements
of
the
framework
 
prohibited
practices
and
any
type
of
clearance
testing.
With
respect
to
prohibited
practices
­
feels
that
even
those
things
listed
may
be
done
successfully
by
other
skilled
contractors.
So,
prohibiting
anything
that
may
be
done
successfully
is
a
problem.
(
Kevin)

°
Agrees
­
some
contractors
may
decide
not
to
do
work
in
pre­
1978
homes.
So,
older
homes
that
are
not
maintained
may
become
more
dilapidated.
(
Jeff)
Draft
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June
9,
2003
 
Page
4
°
For
R&
R,
the
good
players
may
leave
the
field
 
there's
not
enough
money
in
it,
and
the
insurance
issues
are
too
great
(
see
Topic
2
below).
So,
the
"
underground"
(
i.
e.,
noncompliant
contractors
may
remain
and
pick
up
more
of
the
work.
Since
there
are
fewer
contractors
in
the
market,
they
may
charge
consumers
more,
even
if
they
are
doing
noncompliant
work
that
is
possibly
increasing
the
lead
hazards.
(
Brandt)

Topic
2:
Unintended
Impacts
on
ICs
and/
or
Use
of
LSWP
Question
Posed
by
EPA:
Are
there
aspects
of
the
framework
which,
in
their
opinion,
will
hinder
or
discourage
use
of
firms
performing
ICs
or
using
LSWP
during
R&
R?

Answers,
Comments,
and
Other
Qs
and
As
State
reciprocity:

Q:
How
can
we
get
states
to
work
together,
so
federal
program
will
be
adopted
nationwide
(
e.
g.,
so
states
will
not
tack
on
their
own,
more
stringent
requirements)?
He's
looking
at
40+
individual
licenses
to
do
LBP
and
inspection
work,
each
costing
an
estimated
$
200
annually
or
biannually.
He
has
40
inspectors
and
2
people
full­
time
who
do
nothing
but
licensing
to
keep
the
inspectors
up
to
spec.
Under
the
HUD
Section
1012
Federal
assisted
housing
program,
property
owners
have
to
send
employees
to
3
separate
courses
to
cross
MD­
VA­
DC
lines.
The
average
contractor
may
have
to
pay
$
125/
employee
in
multiple
states,
and
may
experience
a
50
percent
employee
turnover
rate.
The
average
contractor
will
not
be
able
to
keep
up
with
the
training
certification
paperwork.
Anything
EPA
can
do
to
promote
reciprocity
in
multi­
state
training
would
go
a
long
way
to
increasing
the
use
LSWP.
(
Patrick)
A:
R&
R
falls
in
the
same
statutory
section
as
abatement,
so
it
is
delegated
to
the
states.
Under
TSCA,
the
state
program
must
be
at
least
as
stringent
as
the
federal
program
and
be
enforceable.
It's
hard
to
say
exactly
what
EPA's
role
could
be
in
this
issue
of
reciprocity.
EPA
has
heard
from
larger,
multi­
state
abatement
contractors
regarding
problems
with
having
to
receive
accredited
training
from
multiple
states.
(
Mike)

Insurance:

°
The
possible
framework
will
create
problems
with
state
requirements
re.
licensing
and
insurance
coverage
 
concerned
that
R&
R
contractors
will
lose
their
general
liability
coverage.
She
would
not
want
to
see
R&
R
contractors
certified
to
do
lead
hazard
reduction
work,
since
that's
not
the
focus
of
their
work.
(
Amy)

°
Agrees
with
Amy
 
R&
R
contractors
are
not
in
the
world
of
lead
hazard
reduction,
yet
the
framework
puts
them
in
that
world.
Concerned
that
later
regulatory
changes
may
put
them
into
even
a
tighter
bind.
(
Brandt)

°
To
enable
contractors
to
get
insurance
cvoerage,
EPA
may
need
to
increase
work
Draft
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June
9,
2003
 
Page
5
practices
since
insurers
may
not
see
the
practices
as
protective
enough.
Too
often,
nothing
seems
to
be
good
enough
for
the
insurance
industry
once
a
risk
is
identified.
Insurers
are
now
focusing
on
mold,
just
like
they
previously
focused
on
asbestos
hazards.
EPA
needs
to
address
the
concerns
of
insurance
carriers.
Contractors
may
lose
their
pollution
liability
coverage
and
general
liability
coverage,
and
small
businesses
may
lose
their
"
umbrella"
coverage.
It's
hard
for
electrical
contractors
now
even
to
get
general
liability
coverage
for
work
in
institutional
settings;
how
do
insurance
carriers
already
view
the
residential
market?
R&
R
contractors
would
face
2
very
hard
tasks
:
(
1)
performing
work
to
restrictive
work
practices,
and
(
2)
maintaining
insurance.
(
Dave)
EPA
has
been
approached
by
the
insurance
industry
regarding
these
issues.
So,
the
Agency
is
beginning
to
work
on
it.
(
Mike)

Topic
3:
Other
Impacts
on
Industry
Question
Posed
by
EPA:
What's
the
overall
impact
on
the
abatement
industry?
On
the
R&
R
industry?

Answers,
Comments,
and
Other
Qs
and
As
°
I
design
and
oversee
abatement
jobs,
and
provides
cost
estimates
for
owners.
I
think
the
framework
for
R&
R
will
completely
replace
abatement
industry.
No
longer
will
we
use
word
"
abatement."
We
are
already
seeing
that
in
Maryland
with
IC
regulations.
(
Patrick)

Q:
Has
there
been
an
increase
in
use
of
LSWP
in
MD?
(
Mike)
A:
Yes.
(
Patrick)

Q:
Where
is
the
unsafe
work
being
done?
In
homes?
Apartment
buildings?
(
Fred)
A:
Looking
at
target
housing
(
pre­
1978)
and
child­
occupied
facilities
(
e.
g.,
homes,
day
cares,
schools).
Primarily
in
residential
units.
(
Mike)

Q:
What
adds
to
the
cost
of
abatement?
Is
it
regulatory?
Demand
for
the
job?
(
Amy)
A:
Historically,
costs
have
been
driven
by
(
1)
the
limited
number
of
contractors
who
did
abatement;
and
(
2)
the
regulations
themselves
(
e.
g.,
building
plastic
enclosures,
doing
preand
post­
tests,
wearing
suits
and
respirators,
etc.).
A
lot
of
owners
were
charged
a
lot
of
money
for
jobs
that
might
not
have
been
that
good.
This
experience
has
changed
a
bit
over
time.
(
Patrick)
Labor
is
a
big
variable;
it's
the
most
difficult
number
to
put
a
figure
to
when
proposing
a
project.
The
human
element
is
not
an
exact
science.
(
Jeff)
In
the
past,
the
asbestos
industry
transitioned
to
lead
when
the
regulations
were
first
passed.
That
brought
in
expertise,
but
also
brought
on
the
high
cost
and
scale
of
asbestos
projects.
Philosophically,
the
Agency
has
moved
from
a
"
lead­
poisoned
child
=
abate
everything"
position,
to
one
of
"
controlling
paint
hazards
"
(
i.
e.,
a
combination
of
abatement
and
ICs).
That
combination
is
less
expensive
than
the
old
"
tear
it
out
and
replace
it"
philosophy.
(
Mike)
Draft
Deliberative
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Quote
 
June
9,
2003
 
Page
6
Lead
Sampling
Technician
(
LST):

Q:
What
was
the
reason
behind
the
creation
of
LST?
Is
that
in
line
with
achieving
EPA's
goals
of
trying
to
reduce
the
cost
of
abatement?
(
Amy)
A:
LST
started
with
Congress,
which
gave
HUD
money
under
the
lead­
safe
housing
rule
to
develop
a
course
and
recognize
the
discipline.
LSTs
can
work
in
federally­
assisted
housing.
(
Mike)

Q:
Is
LST
a
full­
time
job,
or
could
an
LST
also
do
testing
and
clearance?
A:
An
LST
can
work
for
the
firm
doing
the
job
and
perform
clearance
at
the
end
of
the
job.
Please
submit
any
comments
you
might
have
re.
this
approach
and
any
potential
conflict
of
interest
(
COI).
(
Mike)
Note
that
at
least
10
states
prohibit
allowing
anyone
who
did
the
work
on
the
job
from
performing
clearance
at
the
end
of
the
job.
(
Patrick)
Yes,
and
even
with
HUD's
lead­
safe
housing
rule
there
are
COI
issues.
(
Mike)

Q:
How
well
has
the
LST
concept
worked
for
federally­
assisted
housing?
(
Patrick)
A:
It's
worked
­
short
course,
no
pre­
requisites.
Has
built
capacity
for
people
to
support
the
lead­
safe
housing
rule.
(
Mike)

Q:
His
company
never
went
to
any
of
these
trainings,
since
the
state
did
not
recognize
LST
discipline.
How
many
states
are
going
to
recognize
it?
(
Patrick)
A:
Could
try
to
get
information
about
states
where
LST
discipline
is
recognized.
New
England
is
one
area
where
some
states
have
definitely
recognized
this
discipline.
EPA
will
try
to
provide
more
information
about
these
states;
see
Section
2
of
this
document.
(
Mike)

Clearance
testing:

°
Clearance
testing
is
a
big
concern.
Even
though
the
framework
"
recommends"
clearance
for
R&
R,
the
use
of
this
term
in
a
regulatory
context
is
misleading.
Saying
"
recommended"
is
the
same
as
saying
"
required."
All
reference
to
clearance
testing
needs
to
be
removed.
(
Amy)
Seconds
this
comment.
(
Brandt)

Q:
Interior
clearance:
Under
EPA's
possible
framework,
what
area(
s)
in
homes
will
need
to
be
tested?
Areas
worked
in?
Stored
in?
Walked
through?
(
Patrick)
A:
1
to
2
dust
wipes
from
contained
work
area
(
e.
g.,
a
window
sill
and
floor).
For
exterior
clearance
it's
just
visual
clearance
(
e.
g.,
making
sure
no
paint
chips/
debris
are
lying
around).
(
Mike)

Q:
Could
people
avoid
the
requirement
by
working
from
the
outside
 
that
is,
instead
of
"
containing"
it
from
the
interior
(
e.
g.,
when
replacing
a
window),
sealing
off
the
window
on
the
inside
with
plastic
and
removing
it
from
the
outside?
(
Patrick)
A:
Remember,
under
the
framework
clearance
in
voluntary
for
R&
R.
(
Mike)
Draft
Deliberative
­
Do
Not
Cite
or
Quote
 
June
9,
2003
 
Page
7
Topic
4:
Cost
and
Quality
of
LBP
Services
Question
Posed
by
EPA:
What
are
the
cost
implications
of
the
possible
framework
changes?
Are
there
any
quality
implications?

Answers,
Comments,
and
Other
Qs
and
As
°
If
the
good
R&
R
contractors
stop
working
on
pre­
1978
housing,
then
lower
grade
firms
will
remain
and
do
more
of
the
work
on
these
properties.
Their
work
will
not
stand
the
test
of
time,
since
such
non­
compliant
firms
will
not
perform
quality
work.
The
results
is
that
there
work
may
actually
generate
more
hazards,
and
work
will
have
to
b
e
performed
more
often
because
of
the
lower
quality.
(
Brandt)

Supervisor
requirements:

Q:
What
is
EPA's
intention
in
increasing
supervisor
oversight?
To
what
extent
is
that
necessary?
(
Dave)
A:
Currently,
abatement
supervisors
have
to
be
on
site
at
key
times
(
e.
g.,
during
set­
up)
and
within
a
2­
hour
driving
distance.
EPA
is
looking
for
comments
regarding
the
need
for
greater
supervisory
oversight
of
workers,
who
would
only
receive
on­
the­
job
training,
etc.
(
Mike)

Q:
That's
a
cost
issue
 
more
supervisors
and
more
time
on
individual
projects.
(
Patrick)
A:
Note
that
EPA
is
revising
supervisor
training
to
make
it
more
focused
on
LSWP.
(
Mike)

Q:
Who
is
a
supervisor?
Anyone
who
has
gone
through
formal
training?
(
Amy)
A:
Yes
­
trained
and
certified
as
a
supervisor.
(
Mike)

Q:
Could
a
supervisor
direct
work
on
site?
(
Amy)
A:
Perhaps.
Supervisors
bring
expertise
in
bringing
LSWP
to
the
job.
But
whether
they
are
the
job
overseer
depends
on
how
the
firm
is
organized.
(
Mike)
Note:
if
a
worker
violates
a
work
practice
standard,
enforcement
action
would
be
taken
against
the
firm
that
employs
them,
and
perhaps
the
supervisor.
(
Mark)
Right,
EPA
could
take
away
their
certification
so
that
bad
supervisors
would
not
move
on
to
another
firm
and
continue
to
cause
problems.
(
Mike)

Topic
5:
Other
Implementation
Issues
Question
Posed
by
EPA:
What
other
implementation
issues
do
you
foresee?
Are
there
things
that
EPA
should
be
thinking
about
that
impact
practical
implementation
of
the
framework?

Answers,
Comments,
and
Other
Qs
and
As
°
It's
hard
to
look
at
the
regulation
as
practical
for
R&
R,
so
it's
hard
to
look
at
practical
implementation
of
its
elements.
(
Brandt)
Draft
Deliberative
­
Do
Not
Cite
or
Quote
 
June
9,
2003
 
Page
8
°
A
voluntary
program
is
best,
since
it
educates
the
consumer,
not
just
the
contractor.
Problems
with
the
regulatory
approach
include:
conflicts
with
state
regulations,
insurance,
enforcement,
training,
costs
of
clearance
testing,
and
supervisor
costs.
(
Amy)

°
Agrees
with
Amy.
There
is
very
little
consumer
awareness
re.
pre­
1978
lead
issue.
In
surveys,
only
1
out
100
people
say
it's
an
issue.
So
a
big
problem
with
the
two­
track
approach
is
that
contractors
trying
to
comply
with
the
law
will
encounter
higher
costs,
while
consumers
not
seeing
the
value
of
that
incremental
cost.
Contractors
who
do
the
right
thing
will
be
caught
in
the
middle.
If
consumers
don't
value
LSWPs,
contractors
will
be
forced
to
ignore
the
requirements
if
they
are
to
stay
in
business.
If
they
don't,
they
will
lose
business
to
less
scrupulous
contractors.
The
requirements
will
be
very
difficult
for
EPA
and
States
to
effectively
enforce.
It
is
important
that
EPA
recognize
this
reality
if
it
proceeds
with
the
regulatory
approach.
(
Kevin)

°
Implementation
and
cost
issues
are
affected
by
the
definition
of
de
minimis.
Two
sq.
feet
of
surface
area
does
not
equal
a
two
foot
cut
by
saw!!.
Electrical
contractors
cut
into
walls
to
put
in
new
electrical
panels,
switch
boxes,
etc.
Changing
the
de
minimis
so
as
to
consider
linear
saw
feet
different
from
surface
area
would
greatly
reduce
implementation
burdens
on
electrical
contractors
and
others
that
do
not
routine
disturb
extensive
amounts
of
paint.
(
Dave)

Q:
Will
there
be
online
Internet
courses?
(
Amy)
A:
EPA
will
look
at
different
ways
to
present
courses.
EPA
has
considered
using
the
OSHA
online
training
as
a
model.
Perhaps
on­
line
training
can
be
developed
for
workers.
For
supervisors,
the
testing/
certification
requirement
may
preclude
the
use
of
online
training.
(
Mike)

Q:
Re.
cleaning
in
general
 
will
the
rule
restrict
cleanup
technologies,
e.
g.,
allow
use
only
of
HEPA
vacuums
and
lead
detergent?
Or
can
firms
do
whatever
they
want?
(
Patrick)
A:
There
is
some
flexibility,
but
OSHA
standards
say
that
vacuuming
done
when
disturbing
lead
must
be
done
with
a
HEPA
vacuum.
EPA
is
looking
at
other
things,
like
electrostatic
cleaning
cloths
(
ECCs)
as
a
cleaning
and
clearance
tool.
HEPA
vacuum
costs
have
declined
over
time,
but
they
are
still
relatively
expensive.
(
Mike)

Q:
Can
EPA
and
OSHA
coordinate
to
amend
these
requirement,
subject
to
research?
(
Patrick)
A:
Please
submit
your
written
comments
on
this
issue.
(
Mike)
Draft
Deliberative
­
Do
Not
Cite
or
Quote
 
June
9,
2003
 
Page
9
2.
Information
from
HUD
Regarding
States
With
Differing
R&
R
Requirements,
and
Where
LST
can
Be
Used
B.
Information
About
States
Where
the
Lead
Sampling
Technician
Discipline
is
Recognized.

A
national
lead
safety
organization
reported
that
the
following
states
recognize
the
LST
discipline.
If
EPA
receives
additional
information,
it
will
advise
the
group.

°
Maine
°
New
Hampshire
°
Wisconsin
°
Minnesota
°
Indiana
°
Ohio
°
Kentucky
°
Iowa
°
Vermont
Note:
Additional
state
have
discussed
taking
action
to
recognize
the
discipline.
Draft
Deliberative
­
Do
Not
Cite
or
Quote
 
June
9,
2003
 
Page
10
3.
Industry
Representative
Stakeholder
Group
List
[
An
(*)
denotes
participants
in
May
29,
2003,
conference
call]

Richard
Baker
Baker
Environmental
Consulting
7941
Westgate
Street
Lexana,
KS
66215­
2636
ph:
913­
541­
0220;
fax:
913­
541­
0457
Patrick
Connor
(*)
CONNOR
Environmental
Services
&
Engineering
Assessments
Bare
Hills
Business
Center
1421
Clarkview
Road,
Suite
100
Baltimore,
MD
21209­
2188
ph:
410­
296­
7971;
fax:
410­
296­
3419
Paul
Corey
Paul
J.
Corey
Painting
and
Decorating
769
East
Street
Dedham,
MA
02026
ph:
781­
326­
4225;
fax:
781­
320­
9062
Lake
Coulson
(*)
National
Association
of
Plumbing,
Heating,
and
Cooling
Contractors
180
S.
Washington
St.
Falls
Church,
VA
22046
ph:
1­
800­
533­
7694;
fax:
703­
273­
7442
Brandt
Domas
(*)
Domas
&
Associates,
Inc.
2330
South
Kalamath
Street,
Unit
B
Denver,
CO
80233
ph:
303­
733­
7186;
fax:
303­
733­
2802
Amy
Erickson
(*)
National
Association
of
Home
Builders
1201
15th
Street,
NW
Washington,
DC
20005
ph:
202­
266­
8662;
fax:
202­
266­
8559
Draft
Deliberative
­
Do
Not
Cite
or
Quote
 
June
9,
2003
 
Page
11
Keith
Farnham
K&
R
Christopher,
Inc.
216
Prairie
Street
Elgin,
Illinois
60120
ph:
847­
741­
0437;
fax:
847­
741­
9695
Pat
Fink
Mechanical
Contractors
Association
of
America
1385
Piccard
Drive
Rockville,
MD
20850
ph:
301­
869­
5800;
fax:
301­
990­
9690
Claudia
Harris
National
Association
of
Plumbing,
Heating,
and
Cooling
Contractors
180
S.
Washington
St.
Falls
Church,
VA
22046
ph:
1­
800­
533­
7694;
fax:
703­
273­
7442
Bob
Hanbury
House
of
Hanbury
Builders
109
Stamm
Road
Newington,
CT
06111
ph:
860­
666­
1537;
fax:
860­
665­
7815
Jeff
Hurst
(*)
Hurst
Total
Home,
Inc.
2852
Haig
Avenue
Kettering,
OH
45419
ph:
937­
296­
1133;
fax:
937­
296­
1134
Eileen
Lee
(*)
National
Multi
Housing
Council
1850
M
Street,
NW
Suite
540
Washington,
DC
20036
ph:
202­
974­
2326;
fax:
202­
775­
0112
Andy
Moelk
JEFFCO
Painting
and
Coating,
Inc.
1260
Railroad
Ave.,
Bldg.
750
Vallejo,
CA
94592
ph:
707­
556­
1900;
fax:
707­
556­
1907
Kevin
Nolan
(*)
Nolan
Painting,
Inc.
181
West
Hillcrest
Avenue
Havertown,
PA
19083
Draft
Deliberative
­
Do
Not
Cite
or
Quote
 
June
9,
2003
 
Page
12
ph:
610­
642­
1415;
fax:
610­
642­
7856
Frank
Pietranton
Peir
Associates
Real
Estate
2132
Wisconsin
Avenue
NW
Washington,
DC
20007
ph:
202­
337­
8500;
fax:
202­
337­
1129
Dave
Potts
(*)
National
Electrical
Contractors
Association
3
Bethesda
Metro
Center,
Suite
1100
Bethesda,
MD
20814
ph:
301­
657­
3110;
fax:
301­
215­
4500
Fred
Quercetti
(*)
Delaware
Apartment
Association
799
Montclair
Drive
Claymont,
DE
19703
ph:
(
302)
798­
0635;
fquercettisr.
naamans.
com
Chris
Wallis
Peir
Associates
Real
Estate
2132
Wisconsin
Avenue
NW
Washington,
DC
20007
ph:
202­
337­
8500;
fax:
202­
337­
1129
