Trump Administration’s lead action plan is a missed opportunity to protect kids from lead

Tom Neltner, J.D., Chemicals Policy Director

Yesterday, the President’s Task Force on Environmental Health Risks and Safety Risks to Children released its long-delayed Federal Action Plan to Reduce Childhood Lead Exposures and Associated Health Impacts (Lead Action Plan). A year ago the Task Force described this document as a federal lead strategy that would identify clear goals and objectives to “serve as a ‘roadmap’ for federal agencies on actions to take to reduce childhood lead exposure.” It requested feedback on the approach and received over 700 public comments.

The Trump Administration’s Lead Action Plan falls far short of what was promised. To understand what the Plan is and what it is not, we compared it to two earlier documents from the Task Force: 1) A federal lead strategy released in February 2000 by the Clinton Administration focused on reducing exposure to lead-based paint; and 2) An inventory of key federal programs released in November 2016 by the Obama Administration summarizing the activities of the 17 federal agencies and departments with responsibilities to protect children from lead.

A repackaging of the 2016 Key Federal Programs Report

The Lead Action Plan is essentially a repackaged and updated version of the 2016 report. The new Plan describes programs that were largely underway during the Obama Administration. The new activities noted in the document are generally related to directives from courts or from Congress, especially for lead in paint and in drinking water. Little has changed other than the window-dressing: instead of grouping the work by each federal agency, the plan bundles it under four ambiguous goals: 1) Reduce children’s exposure to lead sources; 2) Identify lead-exposed children and improve their health outcomes; 3) Communicate more effectively with stakeholders; and 4) Support and conduct critical research to inform efforts to reduce lead exposures and related health risks.

A retreat from the 2000 Federal Lead Strategy

The 2000 Federal Lead Strategy set two goals to achieve by 2010: 1) eliminate lead paint hazards in housing where children under six live; and 2) eliminate elevated blood lead levels in children. The Strategy identified steps and funding needed to achieve those goals and how its progress would be measured. While the Strategy was never fully funded and, therefore, not fully achieved, it was useful to justify funding increases and helped shape the progress made in the past 18 years in reducing children’s exposure to lead.

In contrast, the Trump Administration’s Lead Action Plan retreats from these goals. Instead of eliminating lead paint hazards where young children live within ten years, the Plan says the objective is to “Reduce Children’s Exposure in Homes and Child-Occupied Facilities with Lead-Based Paint Hazards,” and provides no deadline or measures of success or failure. While the 2000 Strategy sought to eliminate elevated blood lead levels in children within ten years, the new Lead Action Plan sets no numerical goals for reductions in children’s blood lead levels.

Ignoring a rigorous analysis of costs of lead and benefits from specific policy solutions

One of the more frustrating aspect of the Lead Action Plan is that the Trump Administration appears to have ignored an August 2017 report from the Pew Charitable Trust and Robert Wood Johnson Foundation (Pew/RWJF Report) that would have provided them with a solid foundation for an effective strategy.[1] The Pew/RWJF Report estimated the overall costs of lead to society and calculated that for the babies born in 2018, if blood lead levels were kept to zero, the benefits would amount to $84 billion, excluding the cost of intervening. It provided a rigorous assessment of the costs and benefits of various approaches to reduce the harm caused by lead, made five key findings showing a significant economic benefit for several approaches, and recommended ten policy solutions.

The rigorous analysis and policy recommendations from the Pew/RWJF report could have helped shape and solidify many parts of the Plan. For example, the Lead Action Plan says it will “increase the number (or percentage) of certified renovation firms capable of providing lead-safe renovation, repair and painting [RRP] services through targeted outreach campaigns to contractors.” However, the Plan does not appear to consider whether there is much demand for certified firms. Without the threat of enforcement to ensure compliance with Environmental Protection Agency’s (EPA) Lead-Safe RRP Rule, firms have little interest in becoming certified. For these reasons, the Pew/RWJF report recommended that the federal government ensure compliance with the Lead-Safe RRP rule and estimated that the effort would “provide future benefits of $4.5 billion, or about $3.10 per dollar spent.”

A lost opportunity to protect children

Early in 2018, former EPA Administrator Scott Pruitt, a co-chair of the Task Force, convened the Task Force to discuss steps to update the federal lead strategy. He also declared a “war on lead” and promised to “eliminate lead in drinking water in 10 years.” This goal is not in the Lead Action Plan.  And the anticipated strategy has been downgraded to an action plan that does little to advance lead poisoning prevention beyond work already underway.

The Trump Administration likely recognized that the Lead Action Plan fell short of its promise. The release of the plan just before the holidays and a possible government shutdown indicates that they are far from proud of their work. Our country continues to have a toxic legacy of lead: over 6 million homes get water from lead service lines; 24 million homes have lead hazards in paint, dust, or soil; and nearly half a million children have elevated levels of lead in their blood. Making meaningful progress in tackling sources of exposure will require an aggressive, comprehensive, and practical strategy – which is not what the Trump Administration put out yesterday. For decades, we’ve made real progress reducing lead in our society, but the new Lead Action Plan is a missed opportunity to advance those efforts.

[1] The Action Plan does not reference the Pew/RWJF Report.