Petition to DNREC regarding Dry Abrasive Sandblasting of Lead Paint
Exposure to lead paint chips, grit and dust from dry abrasive sandblasting is dangerous to public health. Ingesting lead causes neurological damage, behavioral and learning disabilities among children, as well as anemia, high blood pressure, kidney damage and reproductive effects (including miscarriage, stillbirths and premature births) among adults. There are no safe levels of exposure to lead and there is no way to reverse the damage caused by lead exposure.

As the Delaware Department of Natural Resources and Environmental Control (DNREC) moves forward in preparing regulations for the dry abrasive sand blasting of lead paint from outdoor structures, we the undersigned petition DNREC to protect the health and wellbeing of Delawareans by adopting the following considerations:

1) Regulation requirements should include all types of outdoor structures, including but not limited to:
a. Water Towers
b. Bridges
c. Utility structures and poles
d. Playground equipment
e. Fire hydrants

2) DNREC should specify notification requirements to the surrounding community:
a. Delivered by certified mail to all residences, childcare providers and schools or potentially impacted facilities within 1000 feet of sandblasting
b. Clearly written to state the health risks to life and property of lead exposure and all health hazards associated with its exposure, personal precautions that can be taken, and person to contact for questions/concerns at DNREC/Delaware Division of Public Health
c. In a format that serves a multilingual community
d. Consistent with all American with Disabilities Act (ADA) requirements
e. Confirming that notification has been obtained by resident/occupant (both renters and owners)

3) SSPC (The Society for Protective Coatings) guidelines must be enforced by DNREC, including but not limited to:
a. Emergency Plan and Response (SSPC - Guide 7 - Section 5.5.2)
b. Personnel Training including hazardous materials training with employer maintaining records of training for each employee with an employee annual review requirement (SSPC - Guide 7 - Section 5.5.3)
c. Sampling Plan: “A sampling plan must be developed prior to beginning work. The sampling plan should include who will be responsible for the sampling, how often samples will be taken, how the samples will be obtained, where the samples will be taken, and how the samples will be handled.” (SSPC - Guide 7 - Section 5.6.1)
d. In addition to initial sampling (SSPC - Guide 7 - Section 5.6.4), Representative Samples (SSPC - Guide 7 - Section 5.6.2) should be obtained and analyzed

4) Testing and Data Collection Requirements:
a. Ambient air monitoring performed by a certified independent lab; any data collected by 3rd parties needs to also be bound by same contractual rules (transparency, accountability to DNREC, Freedom of Information Act (FOIA) if applicable)
b. DNREC receiving all results as part of permit/oversight
c. Non-compliance resulting in enforcement and appropriate follow up by DNREC and Delaware Division of Public Health
d. Pre-sample soil testing as well as post-sampling
e. Proactive efforts to identify if paint chips, grit or dust leaves the containment area (routine inspections)

5) Contractual obligations:
a. Contractor/contract requirements should be enforceable through DNREC in regards to environment and public health
b. Contracts should specify emergency response procedures and cleanup procedures, who is responsible for which aspects of the project and potential containment breaches

6) Containment Breach Procedures:
1. Emergency response procedures (response plan must be in place to acquire a permit)
a. Community notification when breaches occur
b. Blood testing, paid for by the company for specific period of time, for notification area and/or affected perimeter around outdoor structure
c. Certifications for workers handling equipment and waste
d. Determining scope and extent of contamination
e. Required response timeline

2. Long-term cleanup procedures
a. Cleanup plan approval process
b. Certifications for workers
c. Required cleanup timeline

7) Prohibitions on:
1. Liability waivers and non-disclosure agreements with property owners; the public should never be asked to waive their rights

2. Extended delays in emergency response or cleanup; DNREC must outline what time period is reasonable for cleanup and at what point should DNREC take over cleanup.

8) Additional provisions:
1. Prohibition on applying lead paint on any outdoor structures in Delaware (new projects and rehabilitative projects)

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