Meeting
with
representatives
of
the
Alliance
for
Healthy
Homes
and
the
National
Center
for
Healthy
Housing,
January
26,
2006
In
attendance:

Jane
Malone,
Housing
Policy
Director,
Alliance
for
Healthy
Homes
Ralph
Scott,
Community
Projects
Director,
Alliance
for
Healthy
Homes
Rebecca
Morley,
Executive
Director,
National
Center
for
Healthy
Housing
Maria
Doa,
Director,
National
Program
Chemicals
Division,
Office
of
Pollution
Prevention
and
Toxics,
USEPA
Julie
Simpson,
Chief,
Lead,
Heavy
Metals,
and
Inorganics
Branch,
National
Program
Chemicals
Division,
USEPA
Mark
Henshall,
Lead,
Heavy
Metals,
and
Inorganics
Branch,
National
Program
Chemicals
Division,
USEPA
Andrew
Simons,
Office
of
General
Counsel,
USEPA
Representatives
of
the
Alliance
for
Healthy
Homes
and
the
National
Center
for
Healthy
Housing
raised
the
following
issues
of
concern:

 
The
proposed
rule
would
not
apply
to
housing
occupied
by
pregnant
women
or
women
of
childbearing
age.
 
The
proposed
rule
would
not
require
the
use
of
dust
clearance
at
the
completion
of
a
renovation
project.
 
Whether
the
incremental
cost
of
cleaning
verification
using
disposable
cleaning
cloths
would
exceed
the
cost
of
clearance.
 
The
proposal
would
allow
the
use
of
work
practices
that
are
prohibited
under
EPA's
abatement
regulations.
 
The
proposal
would
not
require
all
workers
to
receive
formal
training.
 
Proposed
recordkeeping
requirements
go
beyond
what
would
be
expected
for
normal
abatement
jobs.
 
The
proposal
would
not
apply
to
commercial
buildings,
public
spaces,
or
childoccupied
facilities.
 
The
proposal
could
be
interpreted
to
pre­
empt
more
stringent
local
requirements.
