Methylene Chloride; Commercial Paint and Coating Removal Training, Certification and Limited Access Program

Please find attached comments submitted by Lindsay McCormick, Chemicals and Health Program Manager, on behalf of Environmental Defense Fund.

To Whom It May Concern: Attached, please find the signatures of 37,051 EDF supporters from across the country who have submitted electronic comments regarding EPA's proposed rule: Commercial Paint and Coating Removal Training, Certification and Limited Access Program: Methylene Chloride. The comment they each submitted reads: "I am deeply concerned about your decision to continue allowing deadly paint strippers in America's workplaces. "In January 2017, EPA proposed to ban methylene chloride-based paint and coating removal products for all consumer and most commercial uses. The proposal was based on years of study and public input through which the agency compiled overwhelming evidence of the dangers the chemical presents to workers and consumers when used in such products. "After putting off action for two years, the EPA has finalized a ban limited to consumer uses only. While a ban on consumer use is essential, given that the great majority of reported deaths from these products have been of workers, a ban that does not protect workers is unacceptable. "Instead of banning commercial uses -- as originally proposed -- the EPA published an Advanced Notice of Proposed Rulemaking that merely starts a process to gather input on what a possible future worker certification and training program might look like -- delaying any real action for years. Further, in its proposed rule, EPA considered but rejected a training and certification program for workers as too costly and burdensome on business. "Kevin Hartley was just 21 years old when he was killed while using a methylene chloride-based paint stripper to refinish a bathtub for the small, Nashville painting company where he worked. "There's still a chance to fix this mistake and protect workers like Kevin Hartley. Please finalize a ban on commercial uses to ensure we get these deadly products out of America's homes and workplaces." Please contact me if you have any questions or concerns about this submission. Thank you, Heather Shelby Manager, Grassroots Organizing & Activism Environmental Defense Fund hshelby@edf.org