EDF Health

Latest available national data shows increase in blood lead levels for at least 2 million kids

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: April 15, 2019

Tom Neltner, J.D., Chemicals Policy Director

In February, the Centers for Disease Control and Prevention (CDC) released a report summarizing the biomonitoring data from its National Health and Nutrition Examination Survey (NHANES). Given EDF’s focus on protecting children from lead exposure, we went straight to the most recent blood lead monitoring results. The results are disturbing. As shown in Figure 1 below, after years of progress, in 2015-16 the blood lead levels (BLLs) of more than 2 million young children[1] increased:

  • Average child BLL: 48% BLL decrease from 2007-8 to 2013-14 but only a 3% decrease in 2015-16.
  • 75th percentile BLL (75% of children are below this level): 51% decrease from 2007-8 to 2013-14 but a 2% increase in 2015-16.
  • 90th percentile BLL: 51% decrease from 2007-8 to 2013-14 but an 18% increase in 2015-16.
  • 95th percentile BLL: 45% decrease from 2007-8 to 2013-14 but a 23% increase in 2015-16.

As with the smaller uptick in 2007-08 (which may have been related to the housing crises), it may only be short-term setback, nonetheless it bears careful examination.

Even more disturbing is the Trump Administration’s response to this information. The Administration:

  • Ignored the data in the rosy picture of progress it painted in its recent Lead Action Plan; and
  • Appears to be repeating mistakes of the past by proposing to slash CDC’s childhood lead poisoning prevention budget in half.

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PART 3: Busting more industry-perpetrated myths about new chemicals and worker protection under TSCA

By / Published: April 3, 2019

Richard Denison, Ph.D., is a Lead Senior Scientist.

Part 1          Part 2         Part 3

I have been blogging in the last few weeks about myths the chemical industry is perpetrating about the adequacy and legality of the Environmental Protection Agency’s (EPA) recent reviews of the risks that chemicals just entering the market may present to workers.  In this post, I address another such myth that, unfortunately, EPA has swallowed hook, line, and sinker.  This myth was laid out by one of the industry witnesses at the March 13 House Energy & Commerce Committee hearing on EPA’s failures to protect workers from chemical risks.[pullquote]One wonders when EPA will start doing what Congress told it to do, first in 1976 and then again, with renewed vigor in 2016:  Protect workers under TSCA – using TSCA’s authorities to meet TSCA’s health standard, not OSHA’s.[/pullquote]

I’ll get to this third myth in a moment.  But let me first try to crystallize what is at stake in this debate.  While the Toxic Substances Control Act (TSCA) has always given EPA authority to regulate workplace risks, the 2016 amendments to TSCA strengthened EPA’s authority and mandate to protect workers.  TSCA now expressly identifies workers as a “potentially exposed or susceptible subpopulation.”  See the definition of that term in paragraph 12 here.  TSCA then requires EPA to identify and assess potential risks to such subpopulations when reviewing both new and existing chemicals.  Finally, it requires EPA to use its TSCA authorities to impose restrictions on any chemical found to present an “unreasonable risk” – which is TSCA’s health standard – to any such subpopulation.

In a word, TSCA requires EPA to protect workers under TSCA – using TSCA’s authorities to meet TSCA’s health standard, not OSHA’s.

Both before and after the 2016 TSCA amendments, the chemical industry has sought to compel or convince EPA not to regulate workplaces under TSCA, and instead to defer to OSHA.  Industry wants this because OSHA’s authority and capacity are severely limited and its legal requirements for regulating toxic substances (“health standards” in OSHA parlance) allow vastly greater risks to workers than do TSCA’s (see my previous post).

Sadly, under the Trump EPA, industry is getting its wish.  At industry’s urging, EPA is acting in a manner that is wholly contrary to TSCA – and is less health-protective than even under TSCA before the 2016 reforms.

Now let’s get back to more myth-busting.   Read More »

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EDF to OMB: Ban on methylene chloride in paint strippers must protect workers in addition to consumers

By Lindsay McCormick / Published: February 7, 2019

Lindsay McCormick, Project Manager, and Joanna Slaney, Legislative Director

[pullquote]

Over 11,000 concerned Americans have sent messages to Members of Congress over the last two weeks to urge EPA and OMB to protect workers – the population at most risk – from methylene chloride in paint strippers.

[/pullquote]Today, EDF met with the White House Office of Management and Budget (OMB) about the Environmental Protection Agency’s (EPA) draft final rule on methylene chloride-based paint strippers. We urged the office to ensure the ban on methylene chloride-based paint and coating removers covers both consumer and most commercial uses – as the agency originally proposed.

Removing these deadly products from stores, workplaces, and homes is a critical step to protecting public health. Methylene chloride is acutely lethal. Exposure to the chemical has led to over 50 reported worker deaths since the mid-1980s, more than 40 of which are attributed to use of methylene chloride-based paint strippers. Many more deaths have likely gone unreported. The chemical is also associated with a host of other serious health effects, including neurotoxicity, cancer, and liver impairment.

Despite the facts that workers represent the vast majority of reported deaths and face the highest risks of other health effects, it appears that EPA is poised to finalize a rule that excludes a ban on commercial uses entirely – and will instead merely initiate a lengthy, uncertain process that may lead to certification and training approaches EPA had already considered and rejected as inadequate to protect workers.

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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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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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Paint-lead hazard standard – A reconsideration

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

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

After 20 years working on lead poisoning prevention, it has become almost second nature for me to object when someone suggests that children eating paint chips is a significant route of exposure. All too often, the claim implies that the blame rests with parents who are not conscientious enough to clean or maintain their home or to properly care for their children. The implication is demeaning to the parents and distracts from the often – invisible lead dust hazards on floors that pose the greatest risk to children. So when I hear that idea, I quickly respond that dust is the key route of exposure.

However, a discussion with Hannah Chang at Earthjustice over my blog on the Environmental Protection Agency’s (EPA) July 2, 2018 proposed rule helped me realize that I was misguided with regards to defining the hazards of lead-based paints. She is the main attorney for the organizations that convinced a panel of judges in the Ninth Circuit Court of Appeals to order the EPA to update its lead-based paint hazard standard.

Hannah Chang told me I missed the most compelling point when I pointed out in my previous blog that “EPA did not appear to have considered HUD’s 2007 American Healthy Housing Survey, which should provide a solid basis for identifying the relationship between lead in paint and lead in dust.”  She was right; my logic was too focused on dust as the primary source of exposure. Here is my reasoning; it may be helpful to those planning to submit comments to EPA by the August 16 deadline on the proposed rule.

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