The EPA has issued a framework for an approach to identifying, evaluating, and regulating lead-paint hazards in public and commercial buildings (P&CB) where renovation, repair, and painting is occurring.  The scenari-specific approach described in the framework is designed to account for the variable amounts of time people spend in P&CBs, the broad heterogeneity in building sizes and configurations, and the short-term nature of the exposure resulting from renovation activities to assess risk. 
The Toxic Substances Control Act (TSCA) directs the Agency to issue regulations to address activities in P&CBs that create lead-based paint hazards. 

The framework’s approach differs from the one-size-fits-all standard the Agency used to identify hazards in residences and child-occupied facilities (COF).  In that case, the EPA defined a level of lead as a persistent condition in various media (i.e., dust, soil, paint) the Agency would consider dangerous.  Specifically, the EPA residential and COF hazard standards were developed to provide a relatively low chance that an individual child would experience a blood lead level at or above 10 micrograms per deciliter (µg/dL).

Risk by building type

In contrast, under the scenario-based or tailored approach for P&CBs, the EPA would model exposure to lead resulting from various renovation activities in a wide distribution of building types.  Modeling would consider the different age groups of occupants and the varied exposure times that might occur.  This distribution of activities would allow the EPA to characterize risk across all the possible exposure conditions and situations.

Next, the EPA would review the modeling results, including estimates of blood lead changes and appropriate health endpoints, such as IQ decrements for young children.  To inform the hazard finding, the EPA would consider the magnitude of any predicted deleterious health effects as well as how frequently that exposure situation is likely to occur.

“This approach allows EPA the ability to take into account the varied exposure times for individuals, and the variability in buildings and renovations when characterizing risks,” says the Agency.  “This tailored approach would provide the ability to apply any regulatory requirements to only those situations that most closely resemble those modeled scenarios in which the probabilistic modeling predicted that an adverse health effect would occur.  This allows EPA the ability to limit the scope of any regulatory intervention in a way not possible when relying on a uniform hazard standard.” 

The result, according to the Agency, is that regulated entities will not be forced to follow a uniform standard that in some cases may be less protective than necessary and more protective than necessary in other cases. 

Mitigation measures

The framework outlines technical elements of the scenario-specific approach the EPA would use to model hazards inside P&CBs.  According to the Agency, the approach allows a more-targeted way to evaluate the effects of a variety of mitigation measures in reducing exposures that occur inside P&CBs.  For example, the approach can examine the effectiveness of potential regulatory requirements, such as preventing occupants of P&CBs from being present in the work space during the renovation, the use of plastic barriers, prohibiting certain work practices and requiring the use of HEPA dust capture systems on equipment, and cleaning requirements to contain or otherwise limit exposure to leaded dust.

Framework for Identifying and Evaluating Lead-Based Paint Hazards from Renovation, Repair, and Painting Activities in Public and Commercial Buildings