For some organizations, requiring training for in-house personnel, who have minimal or no direct involvement in a project, would be an economic burden and unnecessary. The OSHA training should suffice. Some may be safe with the proper controls. Cutting torches are a problem, but there is no alternative technology and this deserves some study re appropriate practices to reduce hazards. No activity should be prohibited if the appropriate full protection of the workers, public and environment are provided.
Industry can comply with limits and controls that are set.
Currently, those companies that use non-silica products because they have voluntarily responded to avoid these potential risks, are at a competitive disadvantage with companies that continue to use silica. The State of Virginia was concerned about the confusion between abatement activities versus remodeling. Accordingly, in their statute, if an area is tested and it contains lead that will be disturbed, then the project is considered abatement and is covered by the appropriate regulations. 44625 of EPA's Federal Register notice refers to both individuals and firms. There were suggestions that EPA clarify the distinction between contractors, firms or individuals employed by a firm.