Dust Study

Respirable Dust—with the objective of providing improvements for protecting miners from exposure to respirable coal mine dust. Study areas have included (a) dust formation fb) dust control, and (c) dust measurement. Tests have included the infusion of water into coal beds for control of respirable dust the use of water-based, high-expansion foaming systems in conjunction with continuous mining machines, to reduce dust at the face the use of roam systems for dust suppression on conveyors and transfer points and the use of prototype dust meters. See also Pneumokonioses. 

Emond MJ, Lanphear BP, Watts A, Eberly S, and Members of the Rochester Lead-in-Dust Study Group (1997) Measurement error and its impact on the estimated relationship between dust lead and children s blood lead. Environmental Research, 72(1) 82-92. 

Prospero.J. M., 1968 Atmospheric dust studies on Barbados. Bull. Amer. Meteorol. Soc. 49,645-652. Pruchniewicz, P. G, 1973 The average tropospheric ozone content and its variation with season and latitude as a result of the global ozone circulation. Pure and Appl. Geophys. 103-108, 1058-1073. 

Phase II was the Worker Characterization and Blood Lead Study, which from the title had to do with the PbB levels of renovation and repair workers, while Phase III of the field data gathering evaluated children s PbB levels associated with repairs and renovations in units, the Wisconsin Childhood Blood Lead Study. The final Phase IV segment concerned blood lead data gathering in workers doing repairs and renovations in old, historic homes. In the Dust Study, 12 interior and 12 exterior renovation activities were carried out in vacant units in Ohio. 

This regulatory action was supported by the Dust Study just discussed. Therefore, EPA conducted a peer review in accordance with the Final Information Quality Bulletin for Peer Review of the U.S. Office of Management and Budget (OMB). EPA requested this review from the Clean Air Scientific Advisory Committee (CASAC) Lead Review Panel. The CASAC, which is comprised of seven members appointed by the EPA Administrator, was established under the Clean Air Act as an independent scientific advisory committee. The CASAC s comments on the Dust Study, along with EPA s responses, have been placed into the public docket for this action. More information on the CASAC consultation process, along with background documents, is available on EPA s website at www.epa.gov/lead/pubs/casac.htm. 

The Dust Study was reasonably well designed, considering the complexity of the problem, and that the report provided information not available from any other source. The study indicated that the rule cleaning procedures reduced the residual lead (Pb) remaining after a renovation more than did the baseline cleaning procedures. Another positive aspect of the Dust Study was that it described deviations from the protocol when they occurred. 

A major purpose of the Dust Study was to assess the proposed work practices. A statistically valid sample of housing at the national level is not needed to assess the work practices. If anything, the Dust Study is conservative with respect to the age of housing because it studied older houses and therefore is appropriate for assessing the effectiveness of the work practices. 

In addition to the Dust Study, which directly supported this regulatory action, several other studies are discussed that may or may not have been peer reviewed. 

EPA knows of no reason why this interpretation should be changed. In fact, contrary to the assertions of some commenters, the Dust Study found that window replacement was one of the more hazardous jobs. The geometric mean of the lead content of floor dust samples taken in the work area after the window replacement projects was 3003 J.g/ft. In addition, EPA does not believe that window replacement is within the common understanding of the meaning of either minor repair or maintenance. EPA has specifically included language in the definition of minor repair and maintenance activities to make it clear that window replacements cannot qualify. 

In particular, the Dust Study found that renovation activities involving power planing and high temperature heat gun resulted in higher post-job renovation dust lead levels than activities using other practices. The geometric mean post-work, precleaning... 

Based on the results of the Dust Study and in response to the voluminous persuasive public comments, this final rule prohibits or restricts the use of the following practices during renovation, repair, and painting activities that are subject to the work practice requirements of this rule ... 

This final rule does not prohibit or restrict the use of dry hand scraping. EPA has concluded based primarily on the Dust Study as corroborated by other data described below that it is not necessary to prohibit or restrict dry scraping because the containment, cleaning, and cleaning verification requirements of this rule are effective at minimizing exposure to lead-based paint hazards created by renovations and the migration of dust-lead hazards beyond the work area when dry hand scraping is employed. 

The Dust Study evaluated dry hand scraping, which is restricted under EPA s lead abatement program. In contrast to the results of the activities using power planing and high temperature heat gun, average post-job dust lead levels in the two experiments in which paint was disturbed by dry hand scraping... 

The Dust Study, which is described elsewhere in the preamble, assessed the proposed work practices. As one component of the proposed work practices, the cleaning verification was evaluated in the Dust Study. It should be noted that the Dust Study was not designed specifically to evaluate the cleaning verification in isolation of the rest of the work practices. Unlike the earlier Disposable Cleaning Cloth Study that was intended to test the effectiveness of the use of the white glove test in isolation, the Dust Study was meant to evaluate the effectiveness of the proposed work practices, including cleaning verification. 

Cleaning verification, when used apart from the other work practices, is not as reliable a test for determining whether the hazard standard has been achieved as clearance testing. However, the Dust Study supports the validity of cleaning verification as an effective component of the work practices. The cleaning and feedback aspects of cleaning verification are important to its contribution to the effectiveness of the work practices. 

Based on a review of the Dust Study and the Disposable Cleaning Cloth Study, EPA concluded that if the practices prohibited in this final rule are avoided and the required work practices are followed, then cleaning verification is an effective component of the work practices. EPA believes that the suite of work practices as a whole are effective at addressing the lead-paint dust that is generated during renovation, repair, and painting preparation activities. 

Dust Study data on containment and information on the effectiveness of HEPA vacuums show that the use of containment and post-renovation cleaning with HEPA vacuums to remove the lead-based paint dust potentially deposited on the carpets... 

The Environmental Protection Agency received comments prior to the 2007 reqnest for comments on the proposed work practices in light of the Dnst Stndy. Those pre-Dust Study comments are summarized in the following paragraphs. 

EPA disagrees with these commenters. The Dust Study did provide a real-world practical setting in which to assess the use of cleaning verification. Local renovation contractors performed actual renovations for each experiment in the study. The contractors performed cleaning verification on floors of wood, vinyl, or tile, in good, fair, or poor condition. The Dust Study used the protocols that were consistent with those in the 2006 Proposal. 

In response to the comment that the Disposable Cleaning Cloth Study used professional inspectors or other highly trained individuals following specified protocols, EPA intends to include cleaning verification in its training course for renovators and will use the results of the Dust Study and the agency s observations on the experience of the contractors in the study in its development of this course. 

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