Sep
11
Proposed Administrative Rules: Joe Kelly
ByHere is an e-mail from Rita Gergely concerning proposed administrative rules, some of which may be of interest to some of the membership. If you have any comments or questions about these proposed rules, please contact Rita, whose contact information is listed below.
Joe Kelly
________________________________________________________________________________________________
Joe,
I believe that you were present when we discussed this during the legislative session. This has to do with extending the requirements of our Chapter 69 to child-occupied facilities, which does include some parts of schools. Per our discussions at that time, we have specifically stated that the notification to parents can be done by posting a sign (this addresses concerns of the Department of Education). At that time, we also discussed whether a notification to parents needed to be done for work done on school vacations, etc. We didn’t get much guidance from EPA on this issue, except that work done over a weekend couldn’t be exempt. Therefore, we have proposed that a notification to parents doesn’t need to be done if the work can be started and completed during a time when students are absent from the building for at least seven consecutive days. We welcome any comments on this issue, but I doubt that we can convince EPA that a period of less than 7 days is acceptable.
This also includes changes to Chapter 70 that will require landlords, maintenance crews, and contractors who work in target housing and child-occupied facilities to be trained and certified and to follow certain work practice standards when doing the work (landlords who have rental properties that are subsidized by HUD must already have this training). There isn’t a lot of flexibility in these requirements because they must be as stringent as EPA requirements, but we still welcome comments and questions and will do whatever we can to work with child-occupied facilities, contractors, and landlords through the implementation of these requirements.
A draft of the proposed changes is now at the following link on our web site:
We do not yet know how soon these will be filed as official Notices of Intended Action. However, we wanted to get the rules out there so that people could have a chance to ask questions or make comments in advance. We may not be able to make any changes right now based on those questions or comments, but it will still be useful for us to know what type of comments and questions we can expect when they are filed as official Notices of Intended Action.
Would it be possible for you to forward this to the appropriate representatives of the Iowa Landlords Association and Landlords of Iowa? If I should instead it directly to the organizations, I would be glad to do that if you could give me their contact information.
If you or any members of the organizations have comments or questions, please send them to me. Thank you for your help.
Rita M. Gergely, Chief
Bureau of Lead Poisoning Prevention
Division of Environmental Health
Iowa Department of Public Health
321 East 12th Street
Des Moines, IA 50319-0075
Phone: 800-972-2026
Fax: 515-281-4529
