EDF Health

Lead in hair dye – one company considers it safe

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: January 4, 2019

Tom Neltner, J.D., Chemicals Policy Director

In October 2018, the Food and Drug Administration (FDA) banned the use of lead acetate in hair dyes in response to a March 2017 color additive petition from EDF and other health advocates. In December, we learned that Combe, Inc., the maker of the lead-acetate based hair dye Grecian Formula, objected to FDA’s decision, requested a formal evidentiary public hearing to review the decision, and claimed the use is safe. The objection puts the FDA’s decision on hold awaiting a process that may take years to resolve. Apparently, the company thinks it is safe for men to slather skin-soluble lead on their head every couple of days and to risk exposing their families to a heavy metal for which no safe level of exposure has been identified.

Combe’s action was somewhat surprising because the company told CBS News that it removed lead acetate from its Grecian Formula “quite a long time ago,” but was unable to provide an exact date. Presumably, someone in the know updated the product’s Wikipedia page, which says Grecian Formula does not contain lead acetate as of July 2018, although an earlier version of the page said April 2018.

Whatever the date it was reformulated, why would Combe block FDA’s decision when it has long sold a lead-free brand – Just For Men – and had already reportedly removed lead from Grecian Formula? From a market standpoint, objecting to FDA’s decision benefits Youthair, Combe’s main competitor, which continues to sell a leaded-version of progressive hair dye.

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

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: December 20, 2018

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.

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California Water Board makes misleading claim that only four water systems have lead lines

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: December 7, 2018

Tom Neltner, J.D., Chemicals Policy Director

[Update 12/14/18: The California Water Boards added a webpage providing more background for customers on the inventory requirement, including the clarification that “user service line” does not include the service line on private property. This clarification was also added to the Status Map webpage.]

The California Water Board posted the results of its statewide inventory of lead service lines (LSLs) in community water systems (CWSs) yesterday. They also became the first in the nation to post the results in an interactive online map. We are pleased to see the state take this important step, but are disappointed that the press release it sent out to announce the map’s launch undermines its efforts with misleading and confusing statements.

The central problem is that the press release fails to be clear that the inventory does not cover the portion of the service line between the meter and the home or building.  As a result, a CWS that removed all of the lead pipes between the main under the street and the meter but left them on private property was listed as having no LSLs. A customer would justifiably – but mistakenly – assume that LSLs were not an issue in their community.

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Lead from a new “lead-free” brass faucet? More common than you’d hope

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: November 6, 2018

Tom Neltner, J.D. is the Chemicals Policy Director and Lindsay McCormick is a Project Manager.

[pullquote]Until NSF/ANSI 61 standard is updated to reduce or eliminate lead leaching, users must extensively clean and flush new brass fixtures before use and make a short flush standard practice for older fixtures.[/pullquote]

During this past year, we undertook a pilot project to tackle the problem of lead in drinking water at child care facilities. As part of the effort, we collected 250 mL samples (about 8 ounces of water) from every drinking water fixture, as recommended in the Environmental Protection Agency’s (EPA) 3Ts guidance for schools and child care facilities. We replaced 26 faucets that exceeded our action level with new brass faucets that were labeled “lead-free” and complied with NSF/ANSI 61 standard for drinking water system components.[1] To our surprise, when we sampled the faucets a few days after replacement, the lead levels were higher– between 9 and 10 ppb – on three of the new faucets.

The increase left us scratching our heads. Federal law allows a drinking water fixture to be labeled “lead-free” if the amount of lead in wetted surfaces[2] averages less than 0.25% (down from the 8% limit between 1986 and 2014). However, it isn’t clear how much this amount might contribute to levels of lead in water. To explore this issue, we contacted the supplier who said its product was certified under NSF/ANSI 61 and, therefore, not likely the source. The supplier suggested the source could be from existing upstream valves or from disturbing the plumbing. We could not rule these other possibilities out.

A study by Virginia Tech’s Jeff Parks on three models of new NSF/ANSI 61 certified brass faucets found similar results and concluded that even newly manufactured “lead-free” faucets may not meet the 1 ppb limit that the American Academy of Pediatrics (AAP) recommends for schools.

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FDA reduces maximum daily limit for lead in children’s food by half

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: October 25, 2018

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

On September 27, 2018, the Food and Drug Administration (FDA) reduced the maximum allowed daily intake of lead for children from 6 to 3 micrograms per day (µg/day). It has also set a limit for adults of 12.5 µg/day, to protect against possible fetal exposure in women who are unaware they are pregnant and to reduce infant exposure during nursing. The agency now refers to these limits as the “Interim Reference Level” to match the Centers for Disease Control and Prevention’s (CDC) terminology for elevated blood lead levels that warrant action. FDA reports that the new level for children is the amount of lead in food expected to result in a blood lead level of 5 µg/deciliter, with a 10-fold safety factor to account for differences across the population.

This change is a major step in FDA’s new push to limit heavy metals in food to protect children’s neurological development. In April 2018, FDA explained that its Toxic Elements Working Group is “looking at all the [heavy] metals across all foods rather than one contaminant, one food at a time,” and that “even though the level of a metal in any particular food is low, our overall exposure adds up because many of the foods we eat contain them in small amounts.”

As the agency indicated earlier this year, the next step for the Working Group is to “begin reevaluating the specific lead levels that FDA has set for a variety of foods.”

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EPA Updates its 3Ts Guidance for Reducing Lead in Drinking Water

By Lindsay McCormick / Published: October 16, 2018

Lindsay McCormick, is a Project Manager. Tom Neltner, J.D., is the Chemicals Policy Director.

Earlier this month, EPA released its updated 3Ts for Reducing Lead in Drinking Water Toolkit, which provides guidance for schools and child care facilities seeking to ensure children are safe from lead in water.  The new 3Ts – an update to the agency’s 2006 guidance – is now a web-based toolkit that includes modules, customizable templates, and factsheets.

Overall, the new toolkit is an improvement.  While the protocol itself is largely the same, the new toolkit is more user friendly and written for the non-technical audience, making it more likely that school and child care staff will use it.  EPA has also reframed the toolkit from “Training, Testing, and Telling” to “Training, Testing, and Taking Action” – placing more emphasis on the critical step of addressing lead sources than the previous version.  “Telling” is now integrated throughout the entire toolkit to highlight the importance of communication at every step. The agency has also developed a helpful flushing best practices factsheet, which is a topic that often causes considerable confusion.

In EDF’s June 2018 report on our pilot of 11 child care facilities, “Tackling lead in water at child care facilities,” we recommended EPA update its 2006 guidance to address four key gaps.  The agency has made progress on the two most important of those but leaves the other two unresolved. The most important change to the guidance is that the agency has removed the 20 parts per billion (ppb) action level and instead recommends action whenever there are “elevated lead levels.” While EPA does not define an elevated lead level, a deep dive into the appendix suggests that levels over 5 ppb warrant follow-up. The updated guidance also puts a greater emphasis on the identification of lead service lines (LSLs) and includes LSL replacement as a permanent control measure, though not as an explicit recommendation. Further, the agency did not update the protocol to deal with challenges posed by aerator cleaning and hot water heaters.  Below we explore each of these issues in further detail. Read More »

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