AGC Supports Agency Move Towards Greater Transparency in Regulatory Science
The U.S. Environmental Protection Agency (EPA) is proposing to lower the dust-lead hazard standard on floors and window sills (from 40 μg/ft2 and 250 μg/ft2 to 10 μg/ft2 and 100 μg/ft2, respectively). At the same time, EPA proposed no changes to the current definition of lead-based paint, and indicated that the standard would not apply to future “clearance testing” efforts, citing insufficient information to warrant such changes. In an August 16 comment letter, AGC agreed that EPA currently lacks sufficient data to change the existing lead-based paint definition or the post-abatement dust clearance levels.
AGC’s letter points out that EPA appropriately recognized that more data and information is needed on whether current EPA-recognized laboratories and portable field technologies can reliably measure dust samples at those lower levels. AGC supports EPA’s approach to acknowledging data gaps and the resultant impacts on agency decision-making, which is in keeping with EPA’s broader effort to improve the transparency and integrity of the scientific data. The proposed standards would apply to EPA’s lead abatement and related programs that cover target housing (i.e., most pre-1978 housing) and pre-1978 child occupied facilities. Apart from child occupied facilities, no other public and commercial buildings are covered by EPA’s lead paint program.
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