Federal Register: May 6, 2010 (Volume 75, Number 87)
DOCID: fr06my10-21 FR Doc 2010-10102
ENVIRONMENTAL PROTECTION AGENCY
CFR Citation: 40 CFR Part 745
RIN ID: RIN 2070-AJ57
EPA ID: [EPA-HQ-OPPT-2005-0049; FRL-8823-5]
NOTICE: Part II
DOCUMENT ACTION: Proposed rule.
Lead; Clearance and Clearance Testing Requirements for the Renovation, Repair, and Painting Program
DATES: Comments must be received on or before July 6, 2010.
EPA is proposing several revisions to the 2008 Lead Renovation, Repair, and Painting Program (RRP) rule that established accreditation, training, certification, and recordkeeping requirements as well as work practice standards for persons performing renovations for compensation in most pre1978 housing and childoccupied facilities. EPA is particularly concerned about dustlead hazards generated by renovations because of the welldocumented toxicity of lead, especially to younger children. This proposal includes additional requirements designed to ensure that leadbased paint hazards generated by renovation work are adequately cleaned after renovation work is finished and before the work areas are reoccupied. Specifically, EPA is proposing to require dust wipe testing after many renovations covered by the RRP rule. For a subset of jobs involving demolition or removal of plaster through destructive means or the disturbance of paint using machines designed to remove paint through highspeed operation, such as power sanders or abrasive blasters, this proposal would also require the renovation firm to demonstrate, through dust wipe testing, that dustlead levels remaining in the work area are below regulatory levels.
Environmental Protection Agency
I. General Information
A. Does this action apply to me?
You may be potentially affected by this action if you perform
renovations of target housing or childoccupied facilities for
compensation, dust sampling, or dust testing. You may also be affected
by this action if you perform leadbased paint inspections, lead hazard
screens, risk assessments or abatements in target housing or child
occupied facilities or if you operate a training program for
individuals who perform any of these activities. ``Target housing'' is
defined in section 401 of TSCA as any housing constructed prior to
1978, except housing for the elderly or persons with disabilities
(unless any child under age 6 resides or is expected to reside in such
housing) or any 0bedroom dwelling. Under this rule, a childoccupied
facility is a building, or a portion of a building, constructed prior
to 1978, visited regularly by the same child, under 6 years of age, on
at least 2 different days within any week (Sunday through Saturday
period), provided that each day's visit lasts at least 3 hours and the
combined weekly visits last at least 6 hours, and the combined annual
visits last at least 60 hours. Potentiallyaffected entities may include, but are not limited to:
construction, multifamily housing construction, residential remodelers.
This listing is not intended to be exhaustive, but rather provides
a guide for readers regarding entities likely to be affected by this
action. Other types of entities not listed in this unit could also be
affected. The North American Industrial Classification System (NAICS)
codes have been provided to assist you and others in determining
whether this action might apply to certain entities. If you have any
questions regarding the applicability of this action to a particular
entity, consult the technical person listed under FOR FURTHER INFORMATION CONTACT.
B. What should I consider as I prepare my comments for EPA?
1. Submitting CBI. Do not submit this information to EPA through regulations.gov or email. Clearly mark the part or all of the information that you claim to be CBI. For CBI information in a disk or CDROM that you mail to EPA, mark the outside of the disk or CDROM that you mail to EPA, mark the outside of the disk or CDROM as CBI and then identify electronically within the disk or CDROM the specific information that is claimed as CBI. In addition to one complete version of the comment that includes information claimed as CBI, a copy of the comment that does not contain the information claimed as CBI must be submitted for inclusion in the public docket. Information so marked will not be disclosed except in accordance with procedures set forth in 40 CFR part 2.
2. Tips for preparing your comments. When submitting comments, remember to:
i. Identify the document by docket ID number and other identifying information (subject heading, Federal Register date and page number).
ii. Follow directions. The Agency may ask you to respond to specific questions or organize comments by referencing a Code of Federal Regulations (CFR) part or section number.
iii. Explain why you agree or disagree; suggest alternatives and substitute language for your requested changes.
iv. Describe any assumptions and provide any technical information and/or data that you used.
v. If you estimate potential costs or burdens, explain how you arrived at your estimate in sufficient detail to allow for it to be reproduced.
vi. Provide specific examples to illustrate your concerns and suggest alternatives.
vii. Explain your views as clearly as possible, avoiding the use of profanity or personal threats.
viii. Make sure to submit your comments by the comment period deadline identified.
A. What action is the agency taking?
EPA is proposing several revisions to the 2008 Lead Renovation, Repair, and Painting Program (RRP) rule (Ref. 1) that established accreditation, training, certification, and recordkeeping requirements as well as work practice standards for persons performing renovations for compensation in most pre1978 housing and childoccupied facilities. EPA is particularly concerned about dustlead hazards generated by renovations because of the welldocumented toxicity of lead, especially to younger children. This proposal includes additional requirements designed to ensure that leadbased paint hazards generated by renovation work are adequately cleaned after renovation work is finished and before the areas are reoccupied. Specifically, EPA is proposing to require dust wipe testing after many renovations covered by the RRP rule. For a subset of jobs involving demolition or removal of plaster through destructive means or the disturbance of paint using machines designed to remove paint through highspeed operation, such as power sanders or abrasive blasters, this proposal would also require the renovation firm to demonstrate, through dust wipe testing, that dustlead levels remaining in the work area are below regulatory levels. EPA is not, however, reopening other aspects of the work practices required by the 2008 RRP rule.
EPA is also proposing various minor amendments to the regulations concerning applications for training provider accreditation, amending accreditations, course completion certificates, record keeping, State and Tribal program requirements, and grandfathering (i.e., taking a refresher training in lieu of the initial training). In addition, the proposed amendments intend to clarify that certain requirements apply to the RRP rule as well as the LeadBased Paint Activities (abatement) regulations, that the prohibitions and restrictions on work practices in the RRP rule apply to the disturbance of any painted surface, that certified renovators need only provide onthejob training to other renovation workers in the work practices required by the rule, that a certified inspector or risk assessor can act as a dust sampling technician, which handson training topics are required for renovator and dust sampling technician courses, and requirements for States and Tribes that apply to become authorized to implement the RRP program. Again, EPA is not reopening for consideration any aspects of the existing regulations, except as provided in today's proposal. B. What is the agency's authority for taking this action?
These work practice requirements for dust wipe testing and clearance, training, certification and accreditation requirements, and State, Territorial and Tribal authorization provisions are being promulgated under the authority of sections 402(c)(3), 404, and 407 of the Toxic Substances Control Act (TSCA), 15 U.S.C. 2682(c)(3), 2684, and 2687.
1. Health effects of lead exposure. This Unit describes some of the more significant health effects of lead exposure and the routes of exposure associated with lead in paint. Much more information is available in the preamble to the 2008 Lead Renovation, Repair, and Painting (RRP) Rule (Ref. 1) and the Air Quality Criteria for Lead document (Ref. 2).
Lead has been known throughout the ages for its useful properties,
having been commonly used in the production of paint, batteries, pipes,
solder, pottery, and gasoline. Lead is also known for its ``broad array
of deleterious effects on multiple organ systems via widely diverse
mechanisms of action.'' (Ref. 2) This array of health effects includes heme biosynthesis and related
functions; neurological development and function; reproduction and physical development; kidney function; cardiovascular function; and immune function. There is also some evidence of lead carcinogenicity, primarily from animal studies, together with limited human evidence of suggestive associations.
Of particular interest to EPA during the RRP rulemaking was the delineation of lowest observed effect levels for those leadinduced effects that are most clearly associated with blood lead levels of less than 10 micrograms per deciliter ([mu]g/dL) in children and adults (Ref. 2, at 860). As is evident from the Criteria Document, neurotoxic effects in children and cardiovascular effects in adults are among those best substantiated as occurring at bloodlead concentrations as low as 5 to 10 [mu]g/dL (or possibly lower), so these categories of effects would result in the greatest public health concern. Other newly demonstrated immune and renal system effects among general population groups are also emerging as lowlevel leadexposure effects of potential public health concern (Ref. 2, at 860).
Among the wide variety of health endpoints associated with lead exposures, there is general consensus that the developing nervous system in children is among the, if not the, most sensitive. While blood lead levels in U.S. children have decreased notably since the late 1970s, newer studies have investigated and reported associations of effects on the neurodevelopment of children with these more recent blood lead levels (Ref. 2, chapter 6). Functional manifestations of lead neurotoxicity during childhood include sensory, motor, cognitive, and behavioral impacts. Numerous epidemiological studies have reported neurocognitive, neurobehavioral, sensory, and motor function effects in children with blood lead levels below 10 [mu]g/dL (Ref. 2, sections 6.2 and 8.4. [FN 7. Further, neurological effects in general include behavioral effects, such as delinquent behavior (Ref. 2, sections 6.2.6 and 188.8.131.52), sensory effects, such as those related to hearing and vision (Ref. 2, sections 6.2.7 and 184.108.40.206), and deficits in neuromotor function (Ref. 2, p. 836).] As discussed in the Criteria Document, ``extensive experimental laboratory animal evidence has been generated that (a) substantiates well the plausibility of the epidemiologic findings observed in human children and adults and (b) expands our understanding of likely mechanisms underlying the neurotoxic effects'' (Ref. 2, p. 825; section 5.3).
Cognitive effects associated with lead exposures that have been observed in epidemiological studies have included decrements in intelligence test results, such as the widely used IQ score, and in academic achievement as assessed by various standardized tests as well as by class ranking and graduation rates (Ref. 2, section 6.2.16 and pp. 829 to 830). As noted in the Criteria Document with regard to the latter, ``Associations between lead exposure and academic achievement observed in the abovenoted studies were significant even after adjusting for IQ, suggesting that leadsensitive neuropsychological processing and learning factors not reflected by global intelligence indices might contribute to reduced performance on academic tasks'' (Ref. 2, pp. 829 to 8 30).
With regard to potential implications of lead effects on IQ, the Criteria Document recognizes the ``critical'' distinction between population and individual risk, identifying issues regarding declines in IQ for an individual and for the population. The Criteria Document further states that a ``point estimate indicating a modest mean change on a health index at the individual level can have substantial implications at the population level'' (Ref. 2, p. 877). [FN 8. As an example, the Criteria Document states, ``although an increase of a few mm Hg in blood pressure might not be of concern for an individual's wellbeing, the same increase in the population mean might be associated with substantial increases in the percentages of individuals with values that are sufficiently extreme that they exceed the criteria used to diagnose hypertension'' (Ref. 2, p. 877).] A downward shift in the mean IQ value is associated with both substantial decreases in percentages achieving very high scores and substantial increases in the percentage of individuals achieving very low scores (Ref. 2, p. 881). [FN 9. For example, for a population mean IQ of 100 (and standard deviation of 15), 2.3% of the population would score above 130, but a shift of the population to a mean of 95 results in only 0.99% of the population scoring above 130 (Ref. 2, pp. 881 to 882).] For an individual functioning in the low IQ range due to the influence of developmental risk factors other than lead, a leadassociated IQ decline of several points might be sufficient to drop that individual into the range associated with increased risk of educational, vocational, and social failure (Ref. 2, p. 877).
Other cognitive effects observed in studies of children have included effects on attention, executive functions, language, memory, learning, and visuospatial processing (Ref. 2, sections 5.3.5, 6.2.5, and 220.127.116.11), with attention and executive function effects associated with lead exposures indexed by blood lead levels below 10 [mu]g/dL (Ref. 2, section 6.2.5 and pp. 830 to 831). The evidence for the role of lead in this suite of effects includes experimental animal findings (Ref. 2, section 18.104.22.168; p. 831), which provide strong biological plausibility of lead effects on learning ability, memory and attention (Ref. 2, section 5.3.5), as well as associated mechanistic findings.
The persistence of such leadinduced effects is described in the proposal and the Criteria Document (e.g., Ref. 2, sections 5.3.5, 6.2.11, and 8.5.2). The persistence or irreversibility of such effects can be the result of damage occurring without adequate repair offsets or of the persistence of lead in the body (Ref. 2, section 8.5.2). It is additionally important to note that there may be longterm consequences of such deficits over a lifetime. Poor academic skills and achievement can have ``enduring and important effects on objective parameters of success in real life,'' as well as increased risk of antisocial and delinquent behavior (Ref. 2, section 6.2.16).
Multiple epidemiologic studies of lead and child development have demonstrated inverse associations between blood lead concentrations and children's IQ and other cognitiverelated outcomes at successively lower lead exposure levels over the past 30 years (Ref. 2, section 6.2.13). For example, the overall weight of the available evidence, described in the Criteria Document, provides clear substantiation of neurocognitive decrements being associated in children with mean blood lead levels in the range of 5 to 10 [mu]g/dL, and some analyses indicate lead effects on intellectual attainment of children for which population mean blood lead levels in the analysis ranged from 2 to 8 [mu]g/dL (Ref. 2, sections 6.2, 8.4.2, and 22.214.171.124). Thus, while blood lead levels in U.S. children have decreased notably since the late 1970s, newer studies have investigated and reported associations of effects on the neurodevelopment of children with blood lead levels similar to the more recent, lower blood lead levels (Ref. 2, chapter 6).
Paint that contains lead can pose a health threat through various
routes of exposure. House dust is the most common exposure pathway
through which children are exposed to leadbased paint hazards. Dust
created during normal leadbased paint wear (especially around windows and doors)
can create an invisible film over surfaces in a house. Children, particularly younger children, are at risk for high exposures of lead based paint dust via handtomouth exposure, and may also ingest lead based paint chips from flaking paint on walls, windows, and doors. Lead from exterior house paint can flake off or leach into the soil around the outside of a home, contaminating children's play areas. Cleaning and renovation activities may actually increase the threat of lead based paint exposure by dispersing lead dust particles in the air and over accessible household surfaces. In turn, depending on the levels of lead in the dust, both adults and children can receive hazardous exposures by inhaling the dust or by ingesting leadbased paint dust during handtomouth activities.
EPA's Wisconsin Childhood BloodLead Study, described more fully in Unit III.C.1.c. of the preamble to the 2006 Proposal, provides ample evidence of a link between renovation activities and elevated blood lead levels in resident children (Ref. 3). This peerreviewed study concluded that general residential renovation and remodeling is associated with an increased risk of elevated blood lead levels in children and that specific renovation and remodeling activities are also associated with an increase in the risk of elevated blood lead levels in children. In particular, removing paint (using open flame torches, using heat guns, using chemical paint removers, and wet scraping/sanding) and preparing surfaces by sanding or scraping significantly increased the risk of elevated blood lead levels.
Three studies from New York support the findings of the Wisconsin
Childhood BloodLead Study. In 1995, the New York State Department of
Health assessed lead exposure among children resulting from home
renovation and remodeling in 19931994. A review of the health
department records of children with blood lead levels equal to or
greater than 20 [mu]g/dL identified 320, or 6.9%, with elevated blood
lead levels that were attributable to renovation and remodeling (Ref.
4). An update to that study with data from environmental investigations
conducted during 20062007 in New York State (excluding New York City)
identified renovation, repair, and painting activities as the probable
source of lead exposure in 14% of 972 children with blood lead levels
equal to or exceeding 20 [mu]g/dL (Ref. 5). The authors concluded that
children living in housing undergoing renovation, repair, and painting
that was built before 1978, and particularly before 1950, when
concentrations of lead in paint were higher, are at high risk for
elevated blood lead levels. The final study was a casecontrol study
that assessed the association between elevated blood lead levels in
children younger than 5 years and renovation or repair activities in
homes in New York City (Ref. 6). EPA notes that the authors show that
when dust and debris was reported (by respondents via telephone
interviews) to be ``everywhere'' following a renovation, the blood lead
levels were significantly higher than children at homes that did not
report remodeling work. On the other hand, when the respondent reported
either ``no visible dust and debris'' or that ``dust and debris was
limited to the work area,'' there was no statistically significant
effect on blood lead levels relative to homes that did not report remodeling work. Although the study found only a weak and
nonsignificant link between a report of any renovation activity and the likelihood that a resident child had an elevated bloodlead level, the link to the likelihood of an elevated bloodlead level was
statistically significant for surface preparation by sanding and for renovation work that spreads dust and debris beyond the work area. The researchers noted the consistency of their results with EPA's Wisconsin Childhood BloodLead Study (Ref. 6, at 509).
Children in minority populations and children whose families are poor have an increased risk of exposure to harmful lead levels (Ref. 7, at e376). Analysis of the National Health and Nutrition Examination Surveys (NHANES) data from 1988 through 2004 shows that the prevalence of blood lead levels equal to or exceeding 10 [mu]g/dL in children aged 1 to 5 years has decreased from 8.6% in 19881991 to 1.4% in 19992004, which is an 84% decline (Ref. 7, at e377). However, the NHANES data from 19992004 indicates that nonHispanic black children aged 1 to 5 years had higher percentages of blood lead levels equal to or exceeding 10 [mu]g/dL (3.4%) than white children in the same age group (1.2%) (Ref. 7). In addition, among children aged 1 to 5 years over the same period, the geometric mean blood lead level was significantly higher for nonHispanic blacks (2.8 [mu]g/dL), compared with Mexican Americans (1.9 [mu]g/dL) and nonHispanic whites (1.7 [mu]g/dL) (Ref. 7, at e377). For children aged 1 to 5 years from families with low income, the geometric mean blood lead level was 2.4 [mu]g/dL (Ref. 7, at e377). Further, the incidences of bloodlead levels greater than 10 [mu]g/dL and greater than or equal to 5 [mu]g/dL were higher for nonHspanic blacks (14% and 3.4% respectively) than for Mexican Americans (4.7% and 1.2%, respectively) and nonHispanic whites (4.4% and 1.2%, respectively). (Ref. 7, at e377). The analysis ``indicates that residence in older housing, poverty, age, and being nonHispanic black are still major risk factors for higher lead levels'' (Ref. 7, at e376).
2. Prior EPA rulemakings under TSCA Sections 402(a) and 403. TSCA section 402(a) directs EPA to promulgate regulations covering lead based paint activities, such as abatement, to ensure persons performing these activities are properly trained, that training programs are accredited, and that contractors performing these activities are certified. These regulations must contain standards for performing leadbased paint activities, taking into account reliability, effectiveness, and safety. On August 29, 1996, EPA promulgated final regulations under TSCA section 402(a) that govern leadbased paint inspections, lead hazard screens, risk assessments, and abatements in target housing and childoccupied facilities (also referred to as the Leadbased Paint Activities Regulations) (Ref. 8). These regulations, codified at 40 CFR part 745, subpart L, contain an accreditation program for training providers and training and certification requirements for leadbased paint inspectors, risk assessors, project designers, abatement supervisors, and abatement workers. Work practice standards for leadbased paint activities are included. Pursuant to TSCA section 404, provision was made for interested States, Territories, and Indian Tribes to apply for and receive authorization to administer their own leadbased paint activities programs. The regulations applicable to State, Territorial, and Tribal programs are codified at 40 CFR part 745, subpart Q.
The work practice standards for abatements in the Leadbased Paint
Activities Regulations are essentially performance standards. They give
a trained and certified abatement contractor some discretion in
determining how best to ensure that an abatement is performed safely,
so long as the contractor can demonstrate that the abatement has been
properly completed and that no leadbased paint hazards remain. Certain
high dust generating practices are prohibited and contractors are
required to prepare occupant protection plans specifically describing
the procedures to be followed on each job to protect occupants from
exposures to leadbased paint hazards. In most cases, residents relocate until the abatement has been
completed. Although these additional procedures are not specified in the regulations, abatement supervisor and worker courses provide comprehensive training in the specialized techniques these individuals can use to contain work areas, remove, enclose, or encapsulate lead based paint and leadbased paint hazards, and clean up after the job is finished. The regulations are much more detailed in describing the procedures that must be followed to ensure that the abatement has been properly completed and that the work area is ready for reoccupancy. These procedures, typically referred to as ``clearance,'' must be performed by a certified inspector or risk assessor. First, a visual inspection must be performed to determine whether deteriorated painted surfaces or visible amounts of dust, debris, or residue are still present. If so, these conditions must be eliminated before the clearance procedures may continue. An exterior abatement project is considered complete after a successful visual inspection. Following a successful visual inspection after an interior abatement project, the inspector or risk assessor must collect dust wipe samples from floors, windowsills, and window troughs in the work area and have them analyzed by a laboratory accredited under the National Lead Laboratory Accreditation Program (NLLAP) for dust lead analysis. After the sampling results are received, the inspector or risk assessor must compare them with the established clearance standards for lead in dust. If all of the samples are below the clearance standards, the abatement is complete and the area may be reoccupied. If any samples are above the standards, the components represented by those samples must be re cleaned and the clearance process must be repeated until all samples are below the clearance standards. For example, if any interior window sills fail clearance, all of the unsampled window sills, as well as the failed window sills, must be recleaned and retested. If the abatement was conducted in multiple dwelling units, and units were selected for random testing, the window sills in the unsampled units would also have to be recleaned and retested.
TSCA section 403 directs EPA to promulgate regulations that identify, for the purposes of Title X and Title IV of TSCA, dangerous levels of lead in paint, dust, and soil. These regulations were promulgated on January 5, 2001 and codified at 40 CFR part 745, subpart D (Ref. 9). These hazard standards define leadbased paint hazards in target housing and childoccupied facilities as paintlead, dustlead, and soillead hazards. A paintlead hazard is defined as any damaged or deteriorated leadbased paint, any chewable leadbased painted surface with evidence of teeth marks, or any leadbased paint on a friction surface if lead dust levels underneath the friction surface exceed the dustlead hazard standards. A dustlead hazard is surface dust that contains a massperarea concentration of lead equal to or exceeding 40 micrograms per square foot ([mu]g/ft\2\) on floors or 250 [mu]g/ft\2\ on interior windowsills based on wipe samples. A soillead hazard is bare soil that contains total lead equal to or exceeding 400 parts per million (ppm), equivalent to 400 micrograms per gram ([mu]g/g), in a play area or average of 1,200 ppm of bare soil in the rest of the yard based on soil samples.
The TSCA section 403 rulemaking also amended the Leadbased Paint Activities Regulations to incorporate new dustlead clearance standards for abatements. These standards are 40 [mu]g/ft\2\ on floors, 250 [mu]g/ft\2\ on interior windowsills, and 400 [mu]g/ft\2\ on window troughs, based on wipe samples.
On August 10, 2009, EPA received a petition requesting that EPA lower the regulatory dustlead hazard standard and modify the regulatory definition of leadbased paint. After careful consideration, EPA decided to grant the request and accordingly intends to begin the appropriate proceedings. Although EPA granted the request, the Agency did not commit to either a specific rulemaking outcome or a certain date for promulgation of a final rule. EPA's primary reason for granting the request was based on recent epidemiological studies that indicate the current hazard standards are insufficiently protective. The request was granted under section 553(e) of the Administrative Procedures Act (APA). Additionally, because the Secretary of the Department of Housing and Urban Development (HUD) was given the statutory authority to establish a lower level of lead in paint for purposes of the definition of leadbased paint in target housing, EPA plans to work with HUD on this aspect of the request.
3. The 2008 Renovation, Repair, and Painting Rule. TSCA section
402(c) addresses renovation and remodeling. Specifically, TSCA section
402(c)(2) directs EPA to study the extent to which persons engaged in
various types of renovation and remodeling activities are exposed to
lead during such activities or create a leadbased paint hazard
regularly or occasionally. EPA conducted this study in four phases.
Phase I, the Environmental Field Sampling Study (EFSS) (Ref. 10),
evaluated the amount of leaded dust released by the following activities:
Phase II, the Worker Characterization and Blood Lead Study (Ref. 11), involved collecting data on blood lead and renovation and remodeling activities from workers. Phase III, the Wisconsin Childhood Blood Lead Study (Ref. 3), was a retrospective study focused on assessing the relationship between renovation and remodeling activities and children's bloodlead levels. Phase IV, the Worker Characterization and BloodLead Study of R&R Workers Who Specialize in Renovations of Old or Historic Homes (Ref. 12), was similar to Phase II, but focused on individuals who worked primarily in old historic buildings. More information on the results of these peerreviewed studies can be found in Unit III.C.1. of the preamble to the 2006 Lead; Renovation, Repair, and Painting Program Proposed Rule (``2006 Proposal'') (Ref. 13).
TSCA section 402(c)(3) further directs EPA to revise the Leadbased Paint Activities Regulations to apply to renovation or remodeling activities that create leadbased paint hazards. Accordingly, EPA issued the 2006 Proposal, proposing to conclude that any renovation activity that disturbs leadbased paint can create significant amounts of leaded dust, that most activities created leadbased paint hazards, and that some activities can be reasonably anticipated to create lead based paint hazards (Ref. 13). This proposed finding was largely based on the results of the studies conducted under TSCA section 402(c)(2).
After the 2006 Proposal was issued, EPA conducted a field study
(Characterization of Dust Lead Levels after Renovation, Repair, and
Painting Activities) (the ``Dust Study'') to better characterize dust
lead levels resulting from various renovation, repair, and painting
activities (Ref. 14). This study, completed in January, 2007, was
designed to compare environmental lead levels at appropriate stages
after various types of renovation, repair, and painting preparation
activities were performed on the interiors and exteriors of target housing units and child
occupied facilities. The renovation activities were conducted by local professional renovation firms, using personnel who received lead safe work practices training. The activities conducted represented a range of activities that would have been permitted under the 2006 Proposal, including work practices that are restricted or prohibited under the final RRP rule. Of particular interest was the impact of using specific work practices that renovation firms would be required to use under the proposed rule, such as the use of plastic to contain the work area and a multistep cleaning protocol, as opposed to more typical work practices.
The final RRP rule was published in the Federal Register issue of April 22, 2008 (Ref. 1). The final RRP rule, codified in 40 CFR part 745, subparts E, L, and Q, addresses leadbased paint hazards created by renovation, repair, and painting activities that disturb painted surfaces in target housing and childoccupied facilities. ``Target housing'' is defined in TSCA section 401 as any housing constructed before 1978, except housing for the elderly or persons with disabilities (unless any child under age 6 resides or is expected to reside in such housing) or any 0bedroom dwelling. Under the final RRP rule, a childoccupied facility is a building, or a portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days within any week (Sunday through Saturday period), provided that each day's visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours. Child occupied facilities may be located in public or commercial buildings or in target housing.
In the final RRP rule, EPA issued its determination that renovation, repair, and painting activities that disturb leadbased paint create leadbased paint hazards. This finding was based on evidence from the TSCA section 402(c)(2) study and the Dust Study that all such activities in the presence of leadbased paint create lead based paint hazards. Having made this finding, TSCA section 402(c)(3) then directs EPA to revise the Leadbased Paint Activities regulations to apply to such renovations. In the final RRP rule, EPA did not interpret its statutory mandate to require application of the existing TSCA section 402(a) regulations to renovations without change. EPA stated its belief that Congress, by using the word ``revise,'' and creating a separate subsection of the statute for renovation, intended that EPA make revisions to those existing regulations to adapt them to a different set of actions and a very different regulated community. As discussed in the preamble to the final RRP rule, there are significant differences between renovations and abatements (Ref. 1). For example, performing abatement is a highly specialized skill that workers and supervisors must learn in accredited training courses. However, painters, plumbers and carpenters already know how to perform renovation work, so accredited renovator training courses are designed to teach renovators how to incorporate principles of lead safety into their typical work. Accordingly, the rule did not merely expand the scope of the current abatement requirements to cover renovation and remodeling activities. Instead, EPA considered the elements of the existing abatement regulations and revised them as necessary to craft a rule that is practical for renovation, remodeling and painting businesses and their customers, taking into account reliability, effectiveness, and safety as directed by TSCA section 402(a).
The final RRP rule establishes requirements for training renovators, other renovation workers, and dust sampling technicians; for certifying renovators, dust sampling technicians, and renovation firms; for accrediting providers of renovation and dust sampling technician training; for renovation work practices; and for recordkeeping. Interested States, Territories, and Indian Tribes may apply for and receive authorization to administer and enforce all of the elements of these new renovation requirements.
The final RRP rule created two new training disciplines in the field of leadbased paint: renovator and dust sampling technician. Persons who successfully complete renovator training from an accredited renovation training provider are certified renovators. Certified renovators are responsible for ensuring that renovations to which they are assigned are performed in compliance with the work practice requirements set out in 40 CFR 745.85. Persons who successfully complete dust sampling technician training from an accredited training provider are certified dust sampling technicians. Certified dust sampling technicians may be called upon to collect dust wipe samples after renovation activities have been completed. While the training disciplines, the work practice standards, and the recordkeeping requirements of the final RRP rule differ from those established in the leadbased paint activities regulations, EPA determined that the accreditation requirements imposed on persons providing leadbased paint activities training would also be effective for persons providing renovation training. Therefore, the final RRP rule amended 40 CFR 745.225 to cover persons who provide or wish to provide renovation training for the purposes of the final RRP rule.
As amended, 40 CFR 745.225 requires training providers who wish to provide leadbased paint activities or renovation training for the purposes of the EPA's leadbased paint programs to be accredited by EPA. The requirements for each course of study are described in detail at 40 CFR 745.225 as are the operational requirements for training programs and the process for obtaining accreditation.
Under the final RRP rule, covered renovations in target housing and childoccupied facilities must be performed by certified renovation firms. A certified firm must ensure that persons who perform renovations on behalf of the firm are properly trained and that the work practice requirements are followed. Renovations must be performed or directed by certified renovators, who are also responsible for compliance with the RRP rule's requirements. The final RRP rule contains a number of work practice requirements that must be followed for every covered renovation. These requirements pertain to warning signs and work area containment, the restriction or prohibition of certain practices (e.g., high heat gun, torch, power sanding, power planing), waste handling, cleaning, and postrenovation cleaning verification. In contrast, the RRP rule did not apply the same performance standard of an abatementstyle clearance requirement to demonstrate that leadbased paint hazards created by the renovation have been eliminated. Instead, the RRP rule sets forth the steps that must be taken to isolate and contain the work area before work begins and the cleaning protocol that must be followed after the renovation has been completed.
A final step in the process for interior renovations is cleaning
verification. After the RRP rule's specific cleaning protocol has been
followed, a visual inspection for visible dust and debris is performed.
If no dust or debris is found, a certified renovator must wipe the
interior windowsills and uncarpeted floors with wet disposable cleaning
cloths and compare each to a cleaning verification card developed and
distributed by EPA. If the cloth matches or is lighter than the image
on the card, the surface represented by the cloth has passed the post renovation cleaning
verification. If the cloth is darker than the image on the card, the surface represented by the cloth must be recleaned and then wiped with a new wet cloth, which is then compared to the cleaning verification card. If the cloth is still darker than the image on the card, the surface must be allowed to dry for at least an hour. At that time, the surface is wiped with a dry electrostatic cleaning cloth, which completes the cleaning verification process for that surface. When all surfaces in the work area have completed cleaning verification, the renovation has been completed and the work area may be reoccupied.
Shortly after the final RRP rule was promulgated, several petitions were filed challenging the rule. These petitions were consolidated in the Circuit Court of Appeals for the District of Columbia Circuit. On August 26, 2009, EPA signed an agreement with the environmental and children's health advocacy groups in settlement of their petitions. In this agreement EPA committed to propose several changes to the RRP rule, including the changes discussed in this notice.
Throughout this notice, EPA will use several different terms to
describe the proposed requirements. EPA will use the term ``dust wipe
testing'' to mean collecting wipe samples of dust on floors and
windowsills and in window troughs, analyzing the samples for lead
content, and reporting the results of the analysis to the owners and
occupants of the building being renovated. Although the term ``dust
wipe sampling'' was used in the settlement agreement to describe these
activities, EPA is using ``dust wipe testing'' in this notice to signal
that sample analysis may be performed offsite in a traditional
laboratory setting or onsite by a portable laboratory, so long as the
entity performing the analysis is accredited or recognized by the
National Lead Laboratory Accreditation Program (NLLAP). In this notice,
EPA will use the term ``dust wipe sampling'' to refer to the specific
activity of collecting the wipe samples, not to the analysis or
reporting of results. EPA will use the term ``clearance'' to mean
demonstrating, through dust wipe testing, that the floors, windowsills,
and window troughs in the renovation work area are below the regulatory
clearance standards that have been established for the abatement
program and codified at 40 CFR 745.227(e)(8). This includes recleaning where necessary to achieve the clearance standards.
III. Provisions of This Proposal
A. Dust Wipe Testing and Clearance
1. Background. One of the most significant issues arising out of the RRP rulemaking was the issue of how to determine whether a renovation had been properly completed. The Leadbased Paint Activities Rule requires clearance to be achieved in an abatement work area before the abatement is considered complete. As previously discussed, the abatement clearance process involves a visual inspection, dust wipe sampling of floors, windowsills, and window troughs in the work area, analysis by an NLLAPaccredited laboratory, and comparison of the results to the clearance standards. If the sample results are below the clearance standards, clearance has been achieved and the work area may be reoccupied. If the sample results are at or above the standards, the work area must be recleaned and the clearance process must begin again. For this reason, abatement projects often include coating floors with a sealant. According to the U.S. Department of Housing and Urban Development's ``Guidelines For the Evaluation and Control of LeadBased Paint Hazards in Housing'' (HUD Guidelines), the purpose of sealing floors is not to trap leaded dust underneath the sealant, but to provide a surface that can be cleaned effectively by the resident (Ref. 15). Although achieving clearance is not the main reason for sealing floors, the process typically results in a surface than can achieve clearance and be kept clean by the resident. This is a sensible approach for abatements, because the goal of abatement is to permanently eliminate leadbased paint and leadbased paint hazards. The clearance process ensures that no leadbased paint or leadbased paint hazards remain in the work area.
However, EPA recognized that there are many differences between renovations and abatements. As discussed in the preamble to the final RRP rule, renovations are different from abatements in intent, implementation, type of workforce, funding, and goal (Ref. 1). One of the biggest challenges that faced EPA in revising the TSCA section 402(a) Leadbased Paint Activities Regulations was how to effectively bridge the differences between abatement and renovation and remodeling while acknowledging that many of the activities employed in both (e.g., window replacement) are the same and generate the same amount of dust. Abatements are generally performed in three circumstances. First, abatements may be performed in the residences of children who have been found to have elevated blood lead levels. Second, abatements are performed in certain housing receiving financial assistance from HUD when required by HUD's LeadSafe Housing Rule, codified at 24 CFR part 35 (see Sec. Sec. 35.630 and 35.930(d)). Third, state and local laws and regulations may require abatements in certain situations associated with rental housing, or when abatement orders have been issued when resident young children, typically under age 6, have blood lead levels at or above specified values. Typically, when an abatement is performed, the housing is either unoccupied or the occupants are temporarily relocated to leadsafe housing until the abatement has been demonstrated to have been properly completed through dust clearance testing. Carpet in the housing is usually removed as part of the abatement because it is harder to clean. Uncarpeted floors that have not been replaced during the abatement may need to be refinished or sealed in order to achieve clearance. Abatements have only one purposeto permanently eliminate leadbased paint or leadbased paint hazards.
On the other hand, renovations are performed for myriad reasons that may have nothing to do with leadbased paint. Renovations involve activities designed to update, maintain, or modify all or part of a building. Renovations may be performed while the property is occupied or unoccupied. If the renovation is performed while the property is occupied, the occupants do not typically relocate pending the completion of the project.
EPA also recognized that dust wipe testing and clearance as required after abatements can be expensive. The costs can be attributed to two major factors: the cost of trained personnel to collect the samples and the cost of the laboratory analysis. EPA preliminarily estimated the cost of three dust wipe samples to be $160 to collect and analyze (Ref. 13). If EPA had required dust wipe testing and clearance after every renovation project, it would have made up a significant portion of the cost of smaller projects. In addition, laboratory results may not be available for several days. If EPA had required traditional abatementstyle clearance after renovations, the work area would not be able to be reoccupied while waiting for the laboratory results.
In addition, EPA was also concerned that requiring clearance after
every renovation job could, in some instances, result in the renovation
firm being held responsible for abating all dustlead hazards, including such hazards that
may have existed in the area before the renovation commenced. During the stakeholder input opportunities provided by EPA before issuing the 2006 Proposal, contractors suggested that, if postrenovation dust wipe testing were required, the contractors would have to protect themselves by collecting prerenovation dust wipe samples, to ensure that they would not be held liable for preexisting hazards.
To address these various concerns, EPA began looking for an alternative to dust wipe testing and clearance that would be quick, inexpensive, reliable, and easy to perform. EPA conducted a series of studies using commercially available disposable cleaning cloths to determine whether variations of a ``white glove'' test could serve as an effective alternative to clearance. Based on the favorable final report of these studies, entitled ``Electrostatic Cloth and Wet Cloth Field Study in Residential Housing'' (Disposable Cleaning Cloth Study) (Ref. 16), EPA's 2006 Proposal included a cleaning verification protocol using wet and dry disposable cleaning cloths.
Unlike the earlier Disposable Cleaning Cloth Study, the Dust Study was not designed specifically to evaluate the cleaning verification in isolation from the rest of the work practices. However, the Dust Study did serve as a valuable field test of the cleaning verification protocol. The Dust Study involved actual renovations performed by local renovation contractors who received instruction in how to perform cleaning verification using wet and dry disposable cleaning cloths and then were left alone to determine whether the cleaning cloths matched or were lighter than the cleaning verification card developed by the EPA. In order to maximize the information collected about cleaning verification in the Dust Study, cleaning verification was conducted after each experiment, not just those experiments that were being conducted in accordance with the proposed rule requirements for containment and cleaning.
EPA received numerous comments on this aspect of the RRP rulemaking. While some commenters supported the proposed work practices, including cleaning verification, many others thought that renovation work areas ought to be tested and cleared for reoccupancy in the same way that abatement work areas are cleared through the clearance process, including dust wipe testing. Many commenters believed that renovation firms should be required to demonstrate that no dustlead hazards had been left behind in the work area. These commenters contended that the only reliable, safe, and effective way to do this was through dust wipe testing and clearance.
These commenters contended that the unreliability of cleaning verification made it an unsuitable substitute for dust wipe testing and clearance. They pointed to the sentence in the conclusion section of EPA's Dust Study that states that the cleaning verification protocol was not always accurate in identifying the presence of levels above EPA standards for floors and sills. Some commenters also noted the Dust Study report's discussion of factors that affected the effectiveness of cleaning verification, such as floor condition, contractor performance, job type, and dust particle characteristics. One commenter observed that while all interior experiments resulted in final passed cleaning cloths for all floor zones and for all windowsills, nearly half of the experiments in the study ended with average work room floor lead levels above EPA's dustlead hazard standard for floors of 40 [micro]g/ft\2\. The Clean Air Scientific Advisory Committee, who was asked to review the underlying analysis for the estimation of the effect of the RRP rule on children's blood lead levels, stated that in the Dust Study cleaning verification did not provide sufficiently reliable results, leading to an inaccurate assessment of cleaning efficiency.
EPA agreed with the commenters who argued that cleaning verification was not a suitable substitute for dust wipe testing and clearance. EPA noted in the preamble to the final RRP rule that even though the Disposable Cleaning Cloth Study showed that the cleaning verification cloths that reached ``white glove'' were approximately 91% to 97% likely to be below the regulatory hazard standard, EPA believes the greater variability seen in the Dust Study, particularly in the experiments where the complete suite of proposed work practices were not used, does not support the characterization of cleaning verification as a direct substitute for clearance testing. Cleaning verification, in itself, is not a substitute for quantitative dust wipe testing. However, EPA continues to believe that the Dust Study supports the validity of cleaning verification as an effective component of the RRP rule's work practices. The cleaning and feedback aspects of cleaning verification are important to its contribution to the effectiveness of the work practices (Ref. 1).
In the Dust Study, for renovations not involving practices restricted or prohibited by the final RRP rule, cleaning verification in combination with the other required work practices were effective at reducing dust lead levels on surfaces to or below the dustlead hazard standards, regardless of the condition of the floor. Of the 10 experiments performed in compliance with the RRP rule's work practices, final average leadbased paint dust levels were at or below the regulatory hazard standard (taking into account the accepted level of uncertainty, i.e., within plus or minus 20%, which is the performance criteria for the National Lead Laboratory Accreditation Program). For the experiments not performed according to the RRP rule's work practices, the use of cleaning verification after cleaning reduced, often significantly, the amount of lead dust remaining. EPA determined that there is sufficient consistency in the Dust Study data to support the use of cleaning verification as an effective component of the RRP rule's work practices.
Commenters also expressed concern about the subjectivity of the cleaning verification process. They noted that the effectiveness of cleaning verification relies upon the certified renovator's understanding and application of the protocol, ability to define the floor sampling area or areas, and use of the cleaning verification card to determine whether a surface has been adequately cleaned. Some commenters speculated that the certified renovator's accuracy in comparing the cleaning cloth to the verification card could depend on factors such as his or her visual acuity, the lighting in the room, or simply differences in judgment among certified renovators. The issue of a person (i.e., the certified renovator on the project) verifying cleaning of a project that he or she has worked on also raised concerns about actual or potential conflict of interest, which might, even unconsciously, affect the person's judgment. One thought that the lack of corrections for surface conditions, the experience of the person conducting the visual assessment, or preexisting conditions might bias the results of testing.
EPA agreed that the visual comparison of a cleaning cloth to a
cleaning verification card has an element of subjectivity because the
visual comparison of cloth to card requires some exercise of judgment
on the part of the person doing the comparing. However, EPA did not
agree that this necessarily makes the comparison suspect. The Dust
Study represented a realworld test of the ability of renovators to
learn how to do cleaning verification and to apply it in the field.
Although one Dust Study participant expressed concern about subjectivity, cleaning verification was
successfully performed by the renovation contractors in all of the experiments performed in compliance with the work practices in the final RRP rule. In addition, cleaning verification was predictive of whether renovators had cleanedup the leadbased paint hazards created during the renovation activity to the dustlead standard, particularly when the proposed work practices were used. The cleaning verifications performed during the Dust Study were conducted by various persons in various lighting conditions and on various surface conditions.
Other commenters did not support dust wipe testing and clearance. One reason cited by these commenters was the cost of dust wipe testing, especially if required to be performed by independent certified inspectors or risk assessors. Some also contended that dust clearance testing is time consuming and an obstacle to completing the renovation job. One commenter noted that a major component of the cost of performing clearance is due to the fact that the portion of the premises affected by the renovation would have to remain unoccupied. Another commenter noted that it is not uncommon for the abatement clearance process to be conducted up to three times on a home to make sure that lead levels are sufficiently low. Again, commenters expressed the concern that a requirement for dust wipe testing and clearance would have the effect of holding renovation firms responsible for pre existing dustlead hazards.
Based on the weight of the evidence in the rulemaking record, primarily from the Disposable Cleaning Cloth Study and the Dust Study, EPA determined that, once certain high dust generating practices were prohibited or restricted, the full suite of work practice requirements, including containment, cleaning, and cleaning verification, was effective at minimizing exposure to leadbased paint hazards created by renovation, repair, and painting activities. At the same time, EPA recognizes that cleaning verification is an imperfect check on whether the dustlead hazard standard has been achieved. Among other things, as commenters pointed out, there is an element of subjectivity to cleaning verification, which is not present in dust wipe testing.
In the final RRP rule, EPA gave significant weight to the cost, timing, and liability concerns expressed by commenters. In balancing the various considerations, EPA concluded that cleaning verification, as part of the full suite of work practices, was an appropriate check on the effectiveness of the work practices. EPA has continued to balance these considerations in today's proposal, but has preliminarily concluded that, for certain jobs, the additional benefits of dust wipe testing, and in some cases clearance, warrant imposing these additional requirements.
2. Proposed requirements for dust wipe testing after certain renovations. This proposal contains dust wipe testing requirements for many renovations. In most of these situations, the renovation firm will only be required to provide the dust wipe testing results to the building owners and occupants. However, as discussed more fully in Unit III.A.3. of this preamble below, after two types of renovations, this proposal would also require renovation firms to achieve clearance.
EPA has evaluated the value of the information that would be available to renovation firms and building owners and occupants through such testing. EPA expects two kinds of benefits to flow from proposed dust wipe testing requirements. The first are the direct benefits of the information to the owners and occupants, the pure value of the information on dust lead levels remaining in the renovation work area, including leaded dust that may have been generated during the renovation activity. For building owners and occupants, this information is likely to improve their understanding and awareness of dustlead hazards. It will also greatly improve their ability to make further risk management decisions. This information is particularly critical where dust lead levels approach or exceed the regulatory hazard standards. One commenter on the 2008 RRP rule described the value of dust wipe testing results in this way: ``Because the white glove test does not provide a numeric result, a family is given limited information from which to make informed decisions and worse yet, may be given a false sense of security.'' (Ref. 17) The commenter then argued that, ``although the federal floor dust standard is set at 40 [mu]g/ ft\2\, there is sufficient evidence to suggest that floors well below this standard may endanger children. Property owners and residents should be provided quantitative information so they can choose what actions to take based on those levels.'' The commenter believed that in instances where floor dust wipe test results are just below the EPA regulatory standard, the owners or occupants may want to undertake additional cleaning. The value of this information has new significance in light of recent epidemiological studies that indicate the current leadbased hazard standards are insufficiently protective.
In addition, in enacting the Residential Leadbased Paint Hazard Reduction Act of 1992, Congress recognized that there is a value in providing information to property owners and occupants. Section 1018 of the Act requires the disclosure of information on leadbased paint and leadbased paint hazards to purchasers and tenants of target housing. Even if no specific information on the housing to be sold or rented is available, the seller or landlord must provide a lead hazard information pamphlet to the purchaser or tenant. Similarly, TSCA section 406(b) requires renovators or their firms to provide a lead hazard information pamphlet to the owners and occupants of target housing before beginning a renovation in the housing. The information provided by dust wipe testing after renovations is a different and more targeted benefit, i.e., a more accurate check on whether the hazard standard has been met at completion of the job, but it is in line with the broader statutory emphasis on disclosure of information related to possible leadbased paint hazards. This information is beneficial in the same way that disclosure of known leadbased paint and leadbased paint hazards is beneficial to purchasers and tenants under Section 1018.
The other benefits that EPA expects to flow from a dust wipe testing requirement are the benefits that may result from changed behavior on the part of renovation firms. EPA believes that dust wipe testing results will also provide valuable feedback to renovation firms on how well they are cleaning up after renovations. In its Evaluation of the HUD LeadBased Paint Hazard Control Grant Program (Ref. 18), HUD noted that the rate of passing initial clearance was associated with repetition of lead hazard control activities. As renovation firms become more familiar with the performance requirements for cleaning on projects covered by the RRP rule, their projects are more likely to require fewer cleaning cycles.
It is also likely that having to provide to owners and occupants
the specific dust lead levels contained in dust wipe testing results
will increase renovation firm cleaning efficiency. Renovation firms
will be incentivized to lower the dust lead levels remaining after
renovation jobs, even if the levels are at or near the regulatory
standards. In particular, firms that might otherwise be inclined to be
less than thorough in the use of the disposable cleaning cloths in
order to avoid darkening the cloths will be incentivized to perform cleaning
verification thoroughly. Because proper cleanup plays such a vital role in the minimization of dustlead hazards created by renovations, providing information on dust lead levels remaining after renovations to building owners and occupants will serve as an incentive for firms to perform postrenovation cleaning efficiently, thoroughly, and correctly so that the benefits of the RRP rule may be fully realized.
EPA is therefore proposing to require that dust wipe testing be performed after many renovation jobs. EPA has determined that dust wipe testing results will provide a valuable check on the performance of cleaning verification and the other work practices for most of the paintdisturbing renovations covered by the Dust Study (Ref. 14). In reviewing the data from the Dust Study, EPA believes that, of the jobs performed in the Dust Study, the additional safeguard of dust wipe testing is warranted where the floor dustlead levels changed markedly from prework to postcleaning to postcleaning verifications. The only jobs where this did not occur were the renovations involving cutouts, which also created significantly less dust than most other renovations.
Accordingly, today's proposal would require dust wipe testing on
uncarpeted floors, windowsills, and window troughs in the work area after the following types of interior renovations:
These jobs represent all of the experiments conducted in the Dust Study other than those involving cutouts or practices prohibited or restricted by the final RRP rule. The experiments labeled ``kitchen gut'' in the Dust Study mostly involved the removal of kitchen cabinets and kitchen fixtures. The scraping experiments involved the scraping of approximately 60 ft\2\ or more of leadbased paint, so EPA is proposing to limit the dust wipe testing requirement to renovations during which at least that much painted surface is scraped. EPA requests comment, information, or data on whether the threshold for dust wipe testing after renovations involving scraping should be lowered to 6 ft\2\, which is the minor maintenance threshold, or to some other number. Likewise, the trim and molding removal experiments all involved the removal of more than 40 ft\2\ of trim or molding, so EPA is proposing to limit the dust wipe testing requirement to renovations during which at least that much trim or molding is removed. EPA also request
FOR FURTHER INFORMATION CONTACT
For general information contact: Colby Lintner, Regulatory Coordinator, Environmental Assistance Division (7408M), Office of Pollution Prevention and Toxics, Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460 0001; telephone number: (202) 5541404; email address: TSCA Hotline@epa.gov.
For technical information contact: Cindy Wheeler, National Program Chemicals Division, Office of Pollution Prevention and Toxics, Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 204600001; telephone number: (202) 5660484; email address: firstname.lastname@example.org.