EDF Health

EPA reaffirms Lead-Safe Renovation, Repair, and Painting Rule, citing 150% to 500% payback

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: May 10, 2018

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

In April 2018, the Environmental Protection Agency (EPA) completed a thorough review of its Lead-Safe Renovation, Repair, and Painting Rule (RRP) promulgated a decade ago. This rule requires contractors and landlords to use lead-safe work practices when more than minor amounts of lead-based paint in homes built before 1978 are disturbed. It also applies to pre-1978 child-occupied facilities. This review was conducted pursuant to Section 610 of the Regulatory Flexibility Act because of RRP’s significant impact on more than 300,000 small businesses that perform more than 4 million affected projects each year.

EPA concluded that RRP, including several post-2008 amendments, “should remain unchanged without any actions to amend or rescind it.” As part of the review, the agency updated its economic analysis and found that the estimated annual societal benefits, primarily in improved children’s IQ, of $1.5 to $5 billion exceeds the $1 billion in estimated annual compliance costs. Those estimates translate into an impressive annual payback of 150% to 500%. Keep in mind that these benefits do not include the lower risk of premature cardiovascular deaths attributed to adult lead exposure in a March 2018 report in Lancet.

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Lead in water at child care facilities: Preliminary results from EDF’s pilot

By Lindsay McCormick / Published: April 26, 2018

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

When choosing a child care facility, parents weigh numerous factors – like cost, distance to their home, comfort with the staff – with the goal of providing safe care to their child. Unfortunately, it’s not always easy to know if the facility where the child care program is located itself may present health risks – like lead in the drinking water.

The vast majority of schools and child care facilities are not required to test their drinking water for lead under federal requirements. While much of the attention has been on schools, we find that childcare is relatively overlooked, even though water is the most significant source of lead for formula fed infants. In earlier blogs, we talked about state and local testing requirements and levels in hot water.

[pullquote]We tested at 11 child care facilities and found lead in drinking water in at least one sample at seven facilities above our 3.8 ppb action level, three facilities above 20 ppb, and two facilities above 80 ppb.[/pullquote]

To explore lead in drinking water at child care facilities further, EDF conducted a pilot project to investigate new approaches for lead in water testing and remediation in childcare settings.  Our pilot utilized and expanded on EPA’s 3Ts for Reducing Lead in Drinking Water.

We will be releasing a report that will detail our full process, results, and recommendations for addressing lead in water in child care settings. In the meantime, we wanted to share our preliminary takeaways and recommendations below as well as a fact sheet on our project. Read More »

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FDA details its new push on heavy metals in food

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

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

In May 2017, the US Food and Drug Administration (FDA) Center for Food Safety and Nutrition (CFSAN) announced it had “established a Toxic Elements Working Group whose mission in part is to develop a strategy for prioritizing and modernizing the Center’s activities with respect to food/toxic element combinations using a risk-based approach.” FDA set a goal of limiting lead “to the greatest extent feasible.”

In April 2018, FDA released an interview with the Working Group’s chair, Conrad Choiniere, providing an update on its activities. An overarching point expressed by Choiniere during the interview is that “these metals [lead, arsenic, cadmium and mercury] can have effects on children’s neurological development.” This affirmation of scientific evidence is a welcome sign from the agency. FDA’s key statements are:

  • Initial scope: Children’s exposure to “metals like lead, arsenic, cadmium, and mercury in foods, cosmetics, and dietary supplements.”
  • Approach: “Looking at all the metals across all foods rather than one contaminant, one food at a time.”
  • Initial findings: “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.”
  • Next steps:
    • “Finalizing the draft guidance that sets an action-level for the presence of inorganic arsenic in infant rice cereals and apple juice.”
    • “Begin reevaluating the specific lead levels that FDA has set for a variety of foods.”

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New Study Says Lead – Even at Low Levels – is Associated with Risk of Premature Death

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: March 15, 2018

Dr. Ananya Roy is Health Scientist and Tom Neltner, J.D. is Chemicals Policy Director

This week, a team of researchers led by Dr. Bruce Lanphear published an important new study on the deadly impact of lead exposure for adults. The researchers examined data on more than 14,000 adults and found that an increase of 1 to 6.7 micrograms of lead per deciliter of blood (µg/dL) was significantly associated with an increase in mortality of 37% for all-causes, 70% for cardiovascular, and 108% for ischemic heart disease. The findings remained significant even after they considered and accounted for other factors that could have explained this effect.

This research fills a gap identified by the National Toxicology Program in 2011 in our understanding of the risk of lead exposure at low levels in adults. And it goes further by providing a quantitative relationship crucial to better evaluating the potential economic benefits of various policy options.

The study also had startling estimates about how many people are hurt by lead exposure. The authors estimated that over 400,000 Americans every year die from lead related illnesses – ten times higher than previous assessments. That’s on par with deaths from smoking cigarettes.

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FDA on Lead in Grape Juice: Too Late, and Way Too Little Improvement

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: March 5, 2018

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

Update on May 12, 2018: Despite the concerns raised, the Codex Committee on Contaminants in Foods decided that lowering the limit for grape juice from 50 ppb to 40 ppb was sufficient.  The fill Commission will make a final decision at its July 2018 meeting.

On March 12, the Food and Drug Administration (FDA) will be leading the U.S. delegation in the Netherlands proposing that the Codex Alimentarius Commission adopt a maximum lead limit of 40 parts per billion (ppb) in grape juice. The current limit, set by Codex in the 1980s, is 50 ppb. While a small step in the right direction, FDA’s proposal falls woefully short of adequately protecting children from lead.

For context, the 40 ppb proposed Codex limit would be 2.6 times greater than the 15 ppb lead action level established for drinking water by the Environmental Protection Agency (EPA) in 1991 and 8 times FDA’s limit of 5 ppb for bottled water. In addition, a child drinking a single 8-ounce serving of juice with a lead concentration of 40 ppb will be exposed to 160% of FDA’s maximum daily intake level of 6 micrograms of lead per day. This level, set in 1993, should be much lower because it does not reflect scientific discoveries of the past 25 years showing harm to children at lower levels.

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Lead in hot water – an issue worth testing

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: February 26, 2018

[pullquote]Preliminary testing results: 50% (7 of 14) of water heater tanks tested in child care centers had levels over 50 ppb with one at 2,680 ppb. For all but one of these, flushing through the tank drain significantly reduced the lead levels in the water heater. At the hot water tap, only 4 of 161 (2%) samples were above EDF’s action level (3.8 ppb). Water heaters may function as “lead traps,” but more investigation is needed. Best to avoid using hot water for cooking or drinking.[/pullquote]

Tom Neltner, J.D., is Chemicals Policy Director. Analysis conducted by Lindsay McCormick, Project Manager.

Last March, I was giving a talk on lead and drinking water at the National Lead and Healthy Housing Conference. A questioner from a state health department asked me why the standard lead testing methods only sample cold water when experience suggests that people use hot water when making infant formula, dissolving powered drinks, and cooking food. After mumbling for a few minutes that people are supposed to drink cold water, I realized that I really didn’t know the answer – but should.

When risk assessment ignores real life, we are bound to miss something important. For hot water, I think we may be.

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