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QUESTION: Building cavity dust is a potential source of lead exposure in renovation, repair and painting (RRP) activities - 30 Jun 2007 District of Columbia, USA

Dear Sir,

I have worked in the Lead Program of the U.S. Environmental Protection Agency for over 10 years. The U.S. EPA is currently completing work on a rule designed to reduce lead exposure to household residents associated with renovation, repair and painting (RRP) activities.

In creating this rule, the U.S. EPA has focused entirely on existing lead-based paint (LBP) as the source of potential lead exposure. In fact, if a dwelling is found to contain no LBP, that structure is declared exempt from all lead-safe work practices prescribed in the rule. It is assumed that RRP work conducted in dwellings without LBP is incapable or extremely unlikely of creating a lead exposure hazard for the residents.

As a statistician and member of the workgroup developing the RRP rule, I have repeatedly noted that broad empirical evidence demonstrates that leaded dust reservoirs in attics, above ceilings and in wall cavities can be disrupted by renovation or repair work. The data shows that hazardous levels of leaded dust may be released into the living space of a dwelling even if no LBP is found in the dwelling.

I have argued that exempting structures with no lead-based paint is a serious mistake. It ignores non-paint sources of leaded dust, and creates the incorrect impression that RRP projects in houses with no LBP are unlikely to produce a lead exposure hazard.

I am writing to you for help on this matter. The U.S. EPA management (Lead Program) will not consider the validity of my argument about non-paint sources of leaded dust in buildings, but they may feel compelled to listen to Government officials and lead exposure experts from NSW.

Please confirm that you have received this message. I am open to suggestion about how to proceed to correct what I believe to be a most unfortunate policy decision.


Dan Reinhart

Senior Statistician,

National Program Chemical Division,

Office of Pollution Prevention and Toxics,

U.S. Environmental Protection Agency

ANSWER: 02 Jul 2007

Dear Dan,

It is most gratifying to receive your long-awaited email. It has been more than a baker's dozen years that I have dreamed of it dawning on someone in your position that building cavity dust is a potential source of lead exposure.

We have some anecdotal evidence of elevated cavity dust lead levels in US buildings but what is really needed is a proper study. Do you agree with that?

I am copying this email to the head of our Technical Advisory Board, Professor Brian Gulson, as he has vast experience of designing and supervising such studies and I feel certain that some useful correspondence can be entered into.

Hopefully you have already seen the Australian Dust Removalists Association (ADRA) Code of Practice at and the Guidance Note For Ceiling Dusts Containing Lead by NSW WorkCover Authority. I look forward to hearing from you again. Please let me know what you would like me to do to get this show on the road.

Yours Sincerely

Elizabeth O'Brien

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