The
National
Center
for
Healthy
Housing
requested
a
meeting
with
EPA.
EPA
met
with
representatives
of
the
National
Center
for
Healthy
Housing
(
NCHH),
on
February
16,
2006
In
attendance:

Jack
Anderson,
Healthy
Houses
Solutions,
Inc
Tom
Nelter,
National
Center
for
Healthy
Housing
Rebecca
Morley,
Executive
Director,
National
Center
for
Healthy
Housing
Johnathan
Wilkson,
National
Center
for
Healthy
Housing
(
via
teleconference)
Maria
Doa,
Director,
National
Program
Chemicals
Division,
Office
of
Pollution
Prevention
and
Toxics,
USEPA
Jackie
Mosby,
Chief,
Program
Assessment
and
Outreach
Branch,
National
Program
Chemicals
Division,
USEPA
John
Schwemberger,
Statistician,
Program
Assessment
and
Outreach
Branch,
National
Program
Chemicals
Division,
USEPA
Dan
Reinhart,
Statistician,
Program
Assessment
and
Outreach
Branch,
National
Program
Chemicals
Division,
USEPA
Andrew
Simons,
Attorney,
Office
of
General
Counsel,
USEPA
Representatives
of
the
National
Center
for
Healthy
Housing
raised
the
following
issues
related
to
the
Swiffer
Study
and
the
Proposed
R&
R
Rule
were
raised:

 
NCHH
was
unable
to
locate
the
final
economic
analysis
in
the
docket.
EPA
provided
information
to
NCHH
concerning
how
to
obtain/
access
the
most
current
economic
analysis.

 
NCHH
stated
that
they
felt
standardization
(
or
reliability
evaluation)
of
the
`
white
glove'
(
WG)
decision
rule
was
very
important,
and
suggested
that
perhaps
50
raters
could
be
used
in
a
study
to
compare
the
WG
decision
and
this
data
could
be
used
to
evaluate
the
precision
of
raters.

 
It
was
noted
that
no
`
lay
person'
had
been
involved
in
conducting
the
DCC
protocol
even
though
they
would
constitute
the
population
that
would
be
conducting
the
DCC
testing.
Suggestions
were
made
that
both
a
trained/
experienced
individual
and
an
inexperienced
`
lay
person'
might
conduct
the
DCC
protocol
under
matched,
side­
by­
side
conditions.

 
It
was
also
noted
that
there
was
no
mention
of
Carpets
in
the
proposed
rule,
and
believed
this
was
a
serious
omission.
In
addition,
it
was
noted
that
empirical
data
had
been
collected
that
demonstrated
a
correlation
between
lead
from
wipe
samples
(
of
the
carpets)
and
children's
BLLs.
The
question
of
whether
Swiffers
can
be
used
on
carpets
came
up.
Since
many
homes
have
wall­
to­
wall
carpets,
this
is
a
serious
issue.
 
NCHH
emphasized
that
they
would
like
to
see
greater
geographic
diversity
and
a
large
overall
sample
size
in
a
future
study.

 
Suggestions
were
made
that
EPA
form
some
type
of
cooperative
arrangement
with
CDC
or
some
other
program
where
the
DCC
protocol
could
be
targeted
in
housing
of
EBL
kids
(
or
some
other
direct
way
of
implementing
and
assessing
the
DCC
protocol).

 
Another
issue/
question
raised
was
floors
in
poor
condition.
What
should
be
done
when
the
floor
is
not
in
good
enough
shape
to
use
a
DCC?
EPA
noted
that
floors
in
poor
condition
still
passed
the
hazard
std.
after
DCC
treatment.

 
Concerns
were
expressed
that
the
proposed
rule,
as
currently
written,
essentially
denied
the
use
of
a
wet
vacuum
technology
that
he
personally
had
found
to
be
very
effective
at
reducing
lead
loading
to
below
the
hazard
standard.
They
asked
if
this
technology
could
be
used
as
an
option
for
the
second
part
of
the
prescribed
cleanup.

 
NCHH
stated
that
they
hoped
EPA
would
also
develop
a
Dust­
lead
kit
that
was
practical
for
contractors/
homeowners
to
use.

 
The
NCHH
also
noted
that
the
DCC
protocol
that
was
described
in
the
proposed
rule
had
not
been
tested,
and
a
study
to
verify
the
efficacy
of
this
protocol
was
essential.

 
It
was
noted
that
additional
data
for
the
economic
analysis
was
needed.
Data
to
estimate
the
time,
effort,
and
cost
of
conducting
the
DCC
protocol
should
also
is
generated
by
any
future
research.

 
NCHH
asked
about
the
application
of
the
DCC
protocol
to
areas
no
bigger
than
40
square
feet,
and
noted
that
if
a
typical
100
square
foot
floor
was
tested
with
the
DCC
protocol,
it
would
take
three
separate
implementations
of
the
testing
protocol
and
this
would
be
very
time
and
energy
consuming.
Was
this
the
intent
of
EPA?

While
EPA
listened
to
NCHH's
concerns,
we
stated
at
the
beginning
of
the
meeting
that
all
concerns
(
comments)
related
to
the
proposed
rule
and
the
Swiffer
Study
would
have
to
be
submitted
in
writing
to
the
docket.
