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EPA Meeting Chat: June 4th

Screen Shot 2014-09-28 at 9.57.08 PMHere is the conversation from the Chat Window during this EPA Meeting that I was able to capture (after being told that they did not know if they would be able to capture it, I captured what I could.)  This conversation is ASYNCHRONOUS – each of the comments is in response to the audio track which was recorded by a court reporter (not in response to the comment in writing before it necessarily.)  As soon as I get the document from the EPA (of the transcript for the audio for the event) I will share that here as well.


meet the EPA criteria – how far off are the results from the criteria?

Raymond Kennedy: A. No

Janice Yglesias: Yes, thank you.

Janice Yglesias: What was the second percentage given?

Christina Wadlington: 22%

Janice Yglesias: thank you

Christina Wadlington: False positive

Christina Wadlington: Your welcome

Christina Wadlington: *you’re

Christina Wadlington: Speaking:  David Cox from Quantech

bob golledge: Is EPA considering lowering the existing lead standard?

Diana: my screen has “Lead Test Kit Questions” showing…. are there other slides I should be seeing?

Christina Wadlington: Bob, if you could hold questions that aren’t specific to the current commentor that would be great.

Tamara Rubin: To protect the health of a child there is no paradigm under which a lead test kit can (under any circumstances) be considered too sensitive.

Christina Wadlington: Diana, no.  They are provided for the commenters

Steve Landfield: God point Tamara.

Robert Ford: Is this dilution methodology realistic for Certifed Renovators to perform on-site?

Christina Wadlington: Robert, is this question for David?

Robert Ford: Yes

Christina Wadlington: Ok

Tamara Rubin: The minute we begin considering less sensitive kits, we have let down all o our children – now and for future generations.

Christina Wadlington: Robert, I will pass your question to Dave and he can address your question after the comment period.

Robert Ford: Thanks…and maybe EPA could comment on the kit dillution issue also…just doesn’t seem the renovators could do this accurately.

Christina Wadlington: Speaking Bob Handbury

Christina Wadlington: Robert,  we will have Toiya get back to you on your question on behalf of EPA

Robert Ford: OK

Tamara Rubin: HUD standards for what is considered “Lead Based Paint” for the purpose of intervention to protect a child needs to be changed to paint that is 600 ppm or lower.

James Blake: I agree with Robert.  We use many test kits annually, and I am concerned with the ability of Renovators to use a more complicated test kit.

Tamara Rubin: The “Less than 1” milligram per cm squared standard for a negative determiation leaves children at risk.

Christina Wadlington: Thanks James and Robert, did you want to speak and address the room with your thoughts

Raymond Kennedy: Accurate LBP Testing has been available in the market for a while with the XRF

Christina Wadlington: I can add anyone to the speaker list if desired

James Blake: Not at this time, just listening and assimilating information at this time.

Steve Landfield: I agree as a Principal RRP Instructor up here in New York City. When I teach RRP Renewal classes and see what Certified Renovators think the right way is to use Lead checks I am shocked.

Ralph Summers / Apex Lead Solutions: Free Contractors from the need for testing and assume that Lead paint is present in all homes and target facilities built before Jan. 1, 1978

Christina Wadlington: Ralph, did you want me to add you to the speaker list so you may provide your thoughts  to the room?

Tamara Rubin: #GoRalph! You’re terriic Ralph.  Love you and the stand you take.  Thank you.

Robert Ford: I could call in if you think it would be beneficial, but I think you can see the concern in the discussion stream and would be comfortable asking the questions for me.

Ralph Summers / Apex Lead Solutions: I don’t have audio.  Can only respond through chat

Christina Wadlington: Robert, it’s your decision.  Just want to make sure we have an accurate record of your thoughts.

Christina Wadlington: Speaking:  Robert McKinney

Christina Wadlington: Ralph,  ok thank you.  I will capture your thoughts in this chat.

Christina Wadlington: Can everyone place their phones on mute?

Angela Oler: sounds like hold music

Christina Wadlington: If you are on hold, please place your phone on mute.

Dan Taddei (NARI): Promote the speaker to presentor then mute the rest

Christina Wadlington: Tamara, 2 1/5 min warning

Christina Wadlington: Thanks Dan, the telephone is through a seperate system.

Christina Wadlington: Tamara, 1 min warning

Christina Wadlington: Tamara, please wrap up.

bob golledge: So is EPA considering lowering standard to 600ppm?

Ralph Summers / Apex Lead Solutions: Evaluation of chemical test kits have shown that Lead Check swabs are 95% effective in measuring lead in paint at levels of 0.70 mg/cm3.  Ask Wisconsin & Kentucky who have cited internal documents.

Christina Wadlington: Bob,  600ppm is a CPSC standard.  I can further address your questions after the meeting.

Christina Wadlington: Speaking:  Tom Neltner

Robert Ford: “Non-residentail housing”…what does that mean??

ESCA Tech: Wisconsin has recognized the D-Lead Test Kit for lead in paint at 0.7 mg/sqcm

Fabrizzio: the new CPSC standar is 90 PPM. am I correct?

Fabrizzio: sorry standard

Christina Wadlington: Robert, the statute defines residental housing and target housing (places where child are).  There currently not a definition of what is non-residential.  However, in genreal terms, I believe Tom means non-homes.

Tamara Rubin: Robert – I expect he meant non-child occupied

Christina Wadlington: Yes, Fabrizzio, the CSPC standard for new household paint is 90 ppm.

Christina Wadlington: Speaking:  Lee Wazzerman

Robert Ford: Christina/Tamera…THANKS!!

Peter Faulkner: I want to add to this commentary. Test kits provide only a qualitative. The use of certain XRF lead based Paint analyzers (Thermo Scientific Niton), which are quantitative devices, ensures NO false negative or NO positives on any substrate and in most cases is less expensive per test/measurement than test kits including the capital depreciation. The xrf device threshold level may be adjusted to any level. It also provides the consumer with a more reliable result and subsequent costs involved in remediation. XRF is also already approved by HUD. EPA may wish to review the requirements for RRP use and relax regulatory requirements for xrf analyzer operators.

Christina Wadlington: Peter,  did you want time to provide your comment to the room?

Christina Wadlington: Or Peter did you want me to read your comment?

Heather R. Forgione: When you post the presentation slides, can you also provide us with the chat comments? Some of them are very useful/informative…

Tamara Rubin: I have to go, catch a flight to Los Angeles – for my #HealthyHousing twitter chat with Ed Begley, Jr.  I will post more of my thoughts on my blog:

Tamara Rubin: Note: XRFs can be misused by operators as well

Peter Faulkner: I suggest you just read my statement

Ralph Summers / Apex Lead Solutions: The cheapest alternative for window replacement is the current requirement you assume that lead is present in homes and target facilities built before Jan. 1, 1978

Steve Landfield: Wow, this speaker needs to join the real world and get out of Washington. Adding $350 to a home renovation bill DOES matter.

Tamara Rubin: But I think the two tools are complementary… Once someone finds a positive with a test kit, they generally call a hazard assessor to follow up.

Christina Wadlington: I will have to see how we can capture this discussion, I strongly recommend that either I or guests speak for the record

Ralph Summers / Apex Lead Solutions: State of OHIO will not even recognize D-Lead unless you are an accredited lab.

ESCA Tech: XRF is not 100% accurate.  The most accurate is still lead paint chip analysis in the laboratory.

Steve Landfield: And I teach a lot of solo renovators and small companies. It’s hard enough to get them to buy test kits for $20-30, forget about an XRF.

Christina Wadlington: Speaking:  Ben Gan

Tamara Rubin: Lee Wasserman

ESCA Tech: Please explain the OHIO comment.  That is not what OHIO has told us.

Tamara Rubin: Steve Landfield (and others) please be in touch  I would love to publish your thoughts, concerns and feedback to this conversation on the blog

Steve Landfield: Definitely Tamara

Christina Wadlington: We are nearing the end of the speaking list.  Does anyone in the group want to speak before we wrap up?

Christina Wadlington: Peter , I will read your statement next

ESCA Tech: Has EPA re-evaluated their estimate of the number of tests performed annually?

Steve Landfield: Christina, I may make written comments and honestly, I am learning as more from our chat list as from the speakers.

Christina Wadlington: Steve, sounds good.  You can submit your comment to the docket if you need more time.

Ralph Summers / Apex Lead Solutions: Interpretative GuidanceFor Chapter 3701-32 and 3701-82 of theOhio Administrative CodeRenovation, Repair and Painting Rule (RRP) Lead-Safe RenovationQuestion 7. In Ohio, can a certified Renovator take paint chip samples to determine the presence or absence of lead-based paint?No. A certified renovator cannot take paint chip samples to determine the presence of lead. Only licensed Risk Assessors or Inspectors can take paint chip samples. A certified renovator can use a U.S. EPA recognized test kit that does not require the removal of paint to determine the presence of lead. Currently only the LeadCheck® swab fits that criterion.

Tamara Rubin: Christina, Please let me know if I can help with any of the follow up.  I have to run.

Fabrizzio: same here Steve, glad we have this chatroom

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