Regulations.gov #:  05-11149
Comment #:          EREG-5
Submitted:          
Author:             Rowland, Greg
Organization:       UT-Battelle,LLC
City:               
State:              
Country:            
Docket:             H023
 
COMMENT:            
The Lead Standard for Construction should reflect the transient nature of the workforce by stressing appropriate technologies for removing the hazard, such as paint removers. Reliance on information such as past "representative" sampling is not helpful given that very few construction jobs are alike. By providing guidance on effective removal processes, construction companies can focus limited resources on removing the hazard instead of performing monitoring which may or may not help with future lead hazard assessments.
 
