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Review of Dust-Lead Clearance Levels

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Environmental Defense Fund filings
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Environmental Defense Fund filed 1 comment on this docket between Aug 26, 2020 and Aug 26, 2020. 3 other organizations filed here. The comment window closed 2164d ago.

What Environmental Defense Fund filed (1)

Aug 26, 2020· Comment submitted by Tom Neltner, Chemicals Policy Director, Environmental Defense Fund (EDF)· EPA-HQ-OPPT-2020-0063-0377

Environmental Defense Fund (EDF) respectfully submits the following comments regarding the Environmental Protection Agency's (EPA) review of the dust-lead, post-abatement clearance levels. We disagree with the agency's conclusion to set the dust-lead clearance levels for floors and windowsills to be equal to the dust-lead hazard standards as well as to the agency's failure to tighten the clearance level for window troughs. The problem appears to stem in part from the agency's fundamental misunderstanding of the purpose of the clearance testing and its continued reliance on its flawed assessment of laboratory capacity to reliably measure lower levels. Therefore, we request that EPA seriously consider: - Reducing the clearance levels for floors and windowsills to be at least 5 micrograms per square foot (g/ft2) and 40 g/ft2 respectively. - Tighten the clearance levels for window troughs to at least 40 g/ft2. See attached for EDF's full comment.

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Abstract

Addressing childhood lead exposure is a priority for EPA. EPA is considering changes to the dust-lead clearance levels (DLCL) following the recent changes to the dust-lead hazard standards (DLHS). Specifically, EPA published a final rule on July 9, 2019 (RIN 2070-AJ82) to change the DLHS from 40 µg/ft2 and 250 µg/ft2 to 10 µg/ft2 and 100 µg/ft2 on floors and window sills, respectively. These standards apply to most pre-1978 housing and child-occupied facilities, such as day care centers and kindergarten facilities. In that final rule, EPA indicated it would review the DLCL at a later date.

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