Is it time to rethink “lead-safe” and “lead-free”?

By Tom Neltner, Senior Director, Safer Chemicals Initiative, Environmental Defense Fund and Charlotte Brody, National Director, Healthy Babies Bright Futures

Key Message

The scientific consensus is that there is no known safe level of lead exposure, and that no environment or home is truly free of lead.

With a few exceptions, we think it is time to retire the terms “lead-safe” and “lead-free” from our vocabulary. It sends conflicting messages to the public, consumers, and decision-makers. And it may undermine our efforts to reduce children’s exposure to lead from any source.

Rationale

Collectively, we have dedicated over a half-century to protecting children from lead. During that time, we and other advocates have used different terms to communicate our goals. Often, we drew our terms from the federal government. For example:

• “Lead-free” has been used by Congress since 1986 to define drinking water pipes with no more than 80,000 parts per million (ppm) of lead. It kept the term in 2014 when it changed the level from 80,000 to 2,500 ppm. Similarly, FDA issued guidance in 2010 allowing a “lead-free” label on pottery if it meets the agency’s limits on lead.
• “Lead-safe” is in the title for HUD’s 1999 rule to reduce lead-based paint exposure in federally assisted EPA also refers to “lead-safe work practices” in its 2008 renovation, repair and painting (RRP) rule for residential property. In addition, EPA created a “lead-safe” logo in 2010 for certified RRP firms. And HUD, EPA, and CPSC use the term in their pamphlet given to millions of families renting or buying homes built before 1978.

As a result, terms like “lead-safe” and “lead-free” have been commonly used to describe community-wide initiatives, label houses on maps, describe the state of a house after remediation, and much more.

What does lead-free mean? It depends on who you’re asking and what you’re asking about. A contractor may understand the term to mean that a house meets the EPA definition of not having a lead hazard, but does the average resident understand the term the same way? Is it accurate to describe a house as lead-free if there is still lead in the drinking water? Or in the spices in the cabinets?

These terms made sense at the time and still have meaning in specific contexts. They have helped the field move forward at key moments. But are these terms still the best way for us to describe and achieve our vision? Are there alternatives that more accurately and effectively communicate our ambition to eradicate ALL preventable lead exposure?

Over time a scientific consensus has emerged that even low levels of lead in blood can negatively affect a child’s intelligence, ability to pay attention, and academic achievement. In 2012, CDC concluded that “no safe blood lead level in children has been identified.” There is a similar consensus regarding blood lead levels in adults and cardiovascular disease.

Recognizing that any ingested lead may cause harm, the advocacy community’s collective attention has shifted to preventing children’s exposure to lead from all sources – whether from paint, dust, soil, food, air, water, or consumer products – before children are exposed and harmed. This focus has resulted in steady progress driving down blood lead levels and narrowing racial and ethnic disparities, although those disparities stubbornly persist.

Unfortunately, our terminology has been slow to catch up. We cling to terms like “lead-safe” even though we know that there is no safe level of exposure to lead. We say “lead-free” despite knowing that it is impossible to eliminate lead from our environment, our communities, or our homes.

We often use these terms to communicate our ambition of creating environments completely free of lead hazards for children to grow and thrive in. But we must also recognize how they inadvertently undermine that goal. Removing paint and soil hazards from in and around a home is an enormous step forward in reducing a child’s overall risk of lead exposure – but declaring that home lead-free without knowing anything about the potential for lead in their drinking water, food, cultural products, or toys risks leaving that family with a false sense of security.

Further, even the application of the term “lead-free” can reflect only a snapshot in time unless the hazards are permanently abated (e.g., untreated surfaces or treated surfaces that aren’t maintained appropriately). Yes, the term lead-free is simple, but in the vast majority of cases, it isn’t accurate.

With a few exceptions, we think it is time to retire the terms “lead-safe” and “lead-free” from our vocabulary.[1] It sends conflicting messages to the public, consumers, and decision-makers. It may undermine our efforts to reduce children’s exposure to lead from any source.

Rather than a bright line, we should be thinking about continually driving down exposures. We should talk about “safer” as a goal for food, water, homes, and communities and have a collective expectation that we will continue to push for technological innovations and investments that will make it feasible to achieve lower and lower thresholds over time.

This is not a call to abandon the goal of striving to remove as much lead as we can from our children’s environments. It isn’t even a commentary on our current standards for identifying how much lead is too much whether in blood, dust, paint, soil, water, or food, and which are important tools for the practical business of removing as much lead as is feasible from our environments. Nor is it an attempt to undermine the considerable progress our field has made over the last five decades of using these terms. But if we are serious about finishing this fight, we need to challenge the idea that what has served us in the past is still serving us today.

Instead of “lead-safe” and “lead-free,” we suggest two recent alternatives as a starting point for conversation:

• FDA’s “Closer to Zero” Initiative was launched in April 2021 to “reduce dietary exposure to contaminants to as low as possible, while maintaining access to nutritious foods.” The effort prioritizes lead contamination of food intended for babies and young children as well as cadmium, mercury, and inorganic arsenic. The term “Closer to Zero” is grounded in the understanding that there is no safe level of lead in food, but that, at least at present, it cannot be eliminated and reductions may come at the price of limiting children’s access to nutritious food. The agency says it is committed, through a cycle of continual improvement, to progressively reducing contamination with an iterative approach to reducing action levels that industry must meet.
• Biden Administration’s “Get the Lead Out” Partnership was launched in January 2023 to “help accelerate the Administration’s goal of accelerating the replacement of 100 percent of the Nation’s lead service lines in 10 years.” The focus is on specific actions that address lead pipe replacement, the most significant source of lead in drinking water. It does not promise the water will be lead-safe or lead-free but it will take a major step in reducing lead exposure.

While no term is perfect, we encourage those striving to protect children – and adults – from the harmful impacts of lead exposure to consider using “Closer to Zero” or “Get the Lead Out” to describe their efforts.

The lead poisoning prevention community is skilled at sharing and spreading best practices. We encourage thoughtful exchange about what messaging is working so that we can grow our collective understanding and capacity to communicate effectively with residents, decision-makers, and each other over time.

We recognize that old habits are hard to shake. Change will take time, especially with the terms that are defined in laws and rules. We will be starting within our own organizations and applaud those who do the same.

[1] For example, the authors note that the term lead-safe, when applied to work practices, is meaningful and accurately conveys the intention to practice safety.