EDF Health

Progress takes vigilance to reduce children’s exposure to lead

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: April 21, 2017

Tom Neltner, J.D., is Chemicals Policy Director

The United States has made significant progress over the past fifteen years towards reducing children’s exposure to lead. While much more needs to be done to eliminate the more than $50 billion a year in societal costs from lead, the progress is good news for children since it is well known that there is no safe level of lead in children, and it can impair their brain development, contribute to learning and behavioral problems, and lower IQs.

Achieving this progress has required a diligent and ongoing commitment from all levels of government. If we expect to continue to make progress – and not backslide – the federal government needs to remain committed to reducing sources of lead exposure. So far what we’ve seen from the Trump Administration raises serious concerns about any real commitment to protecting children’s health, including from lead.

Lead has a toxic legacy from decades of extensive use in paint, gasoline, and water pipes. As long as lead is in the paint, pipes, and soil where we live, work and play, progress is far from inevitable. Protecting children from lead takes constant vigilance, especially when the paint or plumbing is disturbed. Flint provided a tragic example of what happens when we turn away. Without vigilance, the positive trends we have seen in blood lead levels could all too easily reverse course and go up. That is why the proposed cuts to the Environmental Protection Agency’s (EPA) budget, which would eliminate the agency’s lead-based paint programs, are yet another indication that this Administration is turning its back on protecting children’s health.

Mean blood lead levels in young children dropped 56% from 1999 to 2014

Data from the Centers for Disease Control and Prevention (CDC) demonstrates that from 1999 to 2014 the levels of lead in children’s blood or “blood lead levels” (BLL) dropped preciptiously. Average BLLs in young children declined by 56% during that period with the rate of decline increasing after 2010. For children with a BLL greater than 5 micrograms of lead per deciliter (µg/dL), the reduction was an impressive 86%. Read More »

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EPA’s Children’s Health Protection Advisory Committee recommends four top priorities for EPA to protect kids from lead

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: April 17, 2017

Tom Neltner, J.D., is Chemicals Policy Director

For the past 20 years, the Children’s Health Protection Advisory Committee (CHPAC), with its diverse members that include pediatricians and industry toxicologists, has been responding to requests for guidance from Environmental Protection Agency (EPA) administrators. In December 2016, EPA’s Administrator asked CHPAC to provide the agency with its “highest priority advice” on lead. Citing the children’s health risks posed by lead, the economic and racial disparities and the demonstrated effectiveness of national leadership on the issue, on April 6, CHPAC sent the new administrator, Scott Pruitt, a letter with its four recommended priorities:

  1. Strengthen the Agency’s Lead-Based Paint Hazards Standard for lead in paint, dust, and soil. CHPAC stated that the “best evidence shows that a young child living in a home meeting the current lead dust standard still has a 50% chance of exceeding the CDC reference level for blood lead.” The EPA standard is so insufficient and outdated that on February 1, 2017, the Department of Housing and Urban Development said it would require its lead hazard control grantees to meet a more protective level that is one-fourth of EPA’s standard.
  1. Revise the Lead and Copper Rule to reduce lead in drinking water. CHPAC highlighted several high profile incidents of high levels of lead in drinking water and called for EPA to overhaul its 1991 Lead and Copper Rule to better protect children, especially infants dependent on formula for nutrition. CHPAC recommended the revisions be consistent with the recommendations from the agency’s National Drinking Water Advisory Committee and the lessons from recent water system lead contaminations.
  1. Improve risk communication efforts to provide clarity and consistency. CHPAC asked that EPA revise its “Protect Your Family from Lead In Your Home” booklet that is given to every family buying or renting a home built before 1978 so that it more effectively helps families make decisions regarding the risks posed by lead. The committee cited three problems with the booklet, it:
    • “insufficiently describes other important lead sources including, but not limited to, drinking water faucets, plumbing, traditional and cultural products, and take-home exposures from work”;
    • “treats all homes built before 1978 as equal and does not explain that the likelihood of having lead-based paint varies dramatically based on the age of the home”; and
    • “relies heavily on text rather than graphics making it less effective for some audiences.”
  1. Encourage the Administration’s infrastructure investment program to support healthy housing, childcare facilities, and schools, and safe drinking water. CHPAC recommended that EPA work closely with other federal partners on the President’s Task Force on Environmental Health Risks and Safety Risks to Children to help ensure that all Administration infrastructure investment programs make housing, childcare facilities, and schools healthier, and drinking water safer.

The letter was sent a day after the Washington Post reported on a leaked March 21, 2017 agency memo that details how EPA plans to execute the 31% cuts to its overall budget called for in the President’s proposed budget. The article’s headline says it all: “Trump’s EPA moves to dismantle programs that protect kids from lead paint.” If Congress goes along with these cuts, it is difficult to imagine how the agency could fulfill its basic responsibilities much less implement CHPAC’s recommendations to protect kids from lead.

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Lead service lines on private property – 3 states’ approaches to the challenge

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: April 14, 2017

Tom Neltner, J.D., is Chemicals Policy Director

After the tragedy in Flint, Michigan, there is broad agreement that lead service lines (LSLs) need to be replaced. While corrosion control is essential, it isn’t a fail-safe, long-term solution. With the risks posed by lead to children’s brain development, we must eliminate LSLs – which currently account for an estimated 50 to 75% of the lead in drinking water.

One of the most significant challenges is determining who pays for replacing the portion of a LSL on private property and how it can be done in a way that does not leave low-income residents behind. Most utilities consider service lines on private property to be the responsibility of the property owner. They see replacing customer-owned portions of LSLs as improvements to private property and are typically restricted from using funds collected from all customers to fund an upgrade that benefits only a few. States often impose restrictions as well.

The interpretation that customers are responsible for LSLs on their property is ironic in communities such as Chicago, which mandated the use of LSLs until Congress banned them in 1986.  Given that they had a hand in creating the problem, it seems that they have at least some responsibility in fixing it. The threat posed by lead was well known for decades before Congress acted. Cities such as Cincinnati banned the use of lead pipes in 1927 and Boston in the 1930s.

It is difficult to put responsibility solely on the homeowner since they are unlikely to have been told they have a LSL by the seller. Even if they were aware that their home is serviced by an LSL, the risk a LSL poses to their family’s health is only now becoming clear.

Without support, low-income residents often cannot afford to pay for their portion of the LSL replacement, even if they get zero- or low-interest loans. However, wealthy residents have more options to make the investment than their low-income neighbors and landlords should be making the investment as part of their business.

In December 2016, Congress weighed in and authorized EPA “to establish a $300 million grant program to replace lead service lines on residential property in disadvantaged communities.”[1] It is up to Congress to appropriate the funds as part of its infrastructure investments and ensure that the grant program will not be a hollow promise.

But many states are not waiting on Congress. Three states, Indiana, Pennsylvania, and Wisconsin, have been wrestling with whether to allow communities to use a portion of rates paid by customers to pay for LSL replacements. Collectively, these states have an estimated 690,000 LSLs, 11% of the national estimate. In this blog, we will explore these three state approaches. Read More »

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Report: Grading the nation on lead pipe disclosure policies

By Lindsay McCormick / Published: March 14, 2017

Lindsay McCormick is a Project Manager.  

When purchasing a home, buyers expect to be informed about deficiencies, defects, or environmental hazards on the property. Since 1996, there have been federal policies to alert buyers about lead in paint. However, the likelihood that a buyer will be told their prospective home has lead pipes, including a lead service line, depends on the state in which they live.

Lead service lines (LSLs) – the lead pipes connecting water mains under the street to homes and other buildings – are the primary source of lead in drinking water. Up to 10 million homes across the nation continue to receive water through LSLs, putting millions at risk of lead exposure. Homebuyers deserve to know about this liability when they choose a home and negotiate a price. When done properly, removing the full LSL significantly reduces the risk of lead exposure.

Environmental Defense Fund (EDF) analyzed and graded the housing disclosure policies of all U.S. states and the District of Columbia according to their ability to help homebuyers make informed decisions about LSLs before they sign a sales contract by assessing state disclosure laws, required disclosure forms, and voluntary disclosure forms.  We did not address the extent to which LSLs are actively being disclosed under each policy. Read More »

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EDF’s assessment of a health-based benchmark for lead in drinking water

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: February 28, 2017

Tom Neltner, J.D., is Chemicals Policy Director

Health professionals periodically ask me how they should advise parents who ask about what constitutes a dangerous level of lead in drinking water. They want a number similar to the one developed by the Environmental Protection Agency (EPA) for lead in dust and soil (which is the primary source of elevated blood lead levels in young children). I usually remind them that EPA’s 15 parts per billion (ppb) Lead Action Level is based on the effectiveness of treating water to reduce corrosion and the leaching of lead from plumbing; it has no relation to health. Then I tell them that EPA is working on one and to hold tight. Admittedly, that is not very satisfying to someone who must answer a parent’s questions about the results of water tests today.

On January 12, EPA released a draft report for public comment and external peer review that provides scientific models that the agency may use to develop potential health-based benchmarks for lead in drinking water. In a blog last month, I explained the various approaches and options for benchmarks that ranged from 3 to 56 ppb. In another blog, I described how EPA’s analysis provides insight into the amounts of lead in food, water, air, dust and soil to which infants and toddlers may be exposed. In this blog, I provide our assessment of numbers that health professionals could use to answer a parent’s questions. Because the numbers are only a start, I also suggest how health professionals can use the health-based benchmarks to help parents take action when water tests exceed those levels.

EDF’s read on an appropriate health-based benchmark for individual action on lead in drinking water

When it comes to children’s brain development, EDF is cautious. So we drew from the agency’s estimates calculated by its model to result in a 1% increase in the probability of a child having a blood lead level (BLL) of 3.5 micrograms of lead per deciliter of blood (µg/dL).

EDF’s assessment of a health-based benchmark for individual action on lead in drinking water
Age of child in home and type of exposure Houses built before 1950¹ Houses built 1950 to 1978² Tests show no lead in dust or soil³
Formula-fed infant 3.8 ppb 8.2 ppb 11.3 ppb
Other children 7 years or younger 5.9 ppb 12.9 ppb 27.3 ppb

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EPA to consider perchlorate risks from degradation of hypochlorite bleach

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: February 3, 2017

Tom Neltner, J.D., is Chemicals Policy Director and Maricel Maffini, Ph.D., Consultant

Virtually all types of food contain measurable amounts of perchlorate. Young children are the most highly exposed, and they consume levels that may be unsafe. Reducing exposure to perchlorate is of public health importance because it presents a risk to children’s brain development

One potentially significant source of the toxic chemical in food is hypochlorite bleach that, when not well managed, degrades to perchlorate. Bleach is used to sanitize food manufacturing equipment or to wash or peel fruits and vegetables. Thanks to a recent decision by Environmental Protection Agency’s (EPA) Office of Pesticide Programs, we will better understand the risk posed by perchlorate-contaminated bleach and whether standards are needed to improve the management of bleach.

Reduce perchlorate exposure by improving bleach management

In 2011, an excellent report by the American Water Works Association (AWWA) and the Water Research Foundation documented that hypochlorite bleach degrades into perchlorate. The report also included guidelines on better management of hypochlorite to preserve its effectiveness for drinking water utilities using it to disinfect water.

Most of AWWA’s recommendations are equally relevant to food manufacturers and anyone using bleach to disinfect food contact surfaces. The key recommendations are:

  • Dilute hypochlorite solutions on delivery. Cutting the concentration in half decreases the degradation rate by a factor of 7.
  • Store hypochlorite solutions at lower temperatures. Reducing temperature by 5oC decreases degradation rate by a factor of 2.
  • Keep pH between 11 and 13 even after dilution.
  • Avoid extended storage times, and use fresh hypochlorite solutions when possible.

The objective is not to reduce the use of bleach. Rather it is to preserve its effectiveness by preventing degradation to perchlorate through careful management.

Bleach: a food additive and a pesticide

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