Tom Neltner, J.D., Chemicals Policy Director
[pullquote]EPA needs to estimate reduced heart disease deaths when it evaluates the merits of four upcoming rules addressing lead in water, paint, and air.[/pullquote]
In 2018, we blogged on a study by Lanphear et al. that linked adult blood lead to a jaw-dropping 400,000 heart disease deaths annually. We called on federal regulatory agencies to give serious consideration to this and similar studies to develop a model they can use to quantify the socioeconomic benefits of potential regulatory changes designed to reduce adult exposure to lead. In June, 2019, the Environmental Protection Agency (EPA) successfully completed the necessary peer review of a model. The review was completed too late to be incorporated into the agency’s proposed revisions to its Lead and Copper Rule (released October 2019), but we applied the analysis to estimate that replacing all lead service lines in the nation over ten years would provide societal benefits of more than $205 billion – and called on EPA to consider the benefits when finalizing the rule.
Last week, Abt Associates, EPA’s contractor[1] who developed the initial peer-reviewed model, published a refined model in Environmental Health Perspectives and used it to estimate that between 34,000 and 99,000 cardiovascular disease (CVD)-related deaths were avoided in 2014 due to reduced adult blood lead levels from 1999 to 2014. The analysis reports that between 16% and 46% of the overall reduced CVD deaths during those 15 years was attributable to reduced lead in adult blood.
Abt’s model builds on a 2012 conclusion by the National Toxicology Program (a part of the National Institute of Environmental Health Sciences) that found “sufficient evidence that blood Pb levels <10 [micrograms of lead per deciliter of blood or μg/dL] in adults are associated with adverse effects on cardiovascular function.” The Abt model is based on models in four studies: Menke et al. 2006, Aoki et al. 2016, Ruiz-Hernandez et al. 2017, and Lanphear et al. 2018.
The Abt model allows the socioeconomic benefits of different policy options that reduce adult exposure to lead to be quantified. Models that quantify the benefits of various policy options are critical because they allow decisionmakers to more fully evaluate the benefits of the options and balance them against the cost. Since President Clinton’s 1993 Executive Order 12866, this type of cost-benefit analysis has become a staple of rulemaking. To date, for rulemaking designed to reduce exposure to lead, the analysis has largely focused on neurological benefits to children in terms of improved IQ score. Abt’s new study is important because it moves us one step closer to including adult CVD benefits into the cost-benefit analysis of these rules. We think EPA must consider these benefits when it:
- Finalizes the Lead and Copper Rule later this year;
- Reassesses the need to tighten its National Ambient Air Quality Standards for lead;
- Finalizes its proposed lead-based paint clearance standards next year; and
- Fix its flawed lead-based paint hazard standards for dust, paint, and soil.
[1] Although EPA funded the underlying research described in the study, the manuscript was not subject to Agency review. Abt Associates acknowledged in the EHP article that RESOLVE provided funding to prepare the EHP manuscript; the organization did not review the article prior to publication.