EDF Health

EDF considers potential health equity impacts of partial lead service line replacement

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: January 10, 2019

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

[pullquote]“LSL replacement initiatives should address barriers to participation so that consumers served by LSLs can benefit equitably, regardless of income, race or ethnicity.”

– A founding principle of the Lead Service Line Replacement Collaborative[/pullquote]States and communities across the country are taking important steps to accelerate replacement of lead service lines (LSLs) – lead pipes connecting the water main under the street to homes and other buildings. As part of this progress, many programs have strictly limited the standard practice of partial LSL replacement – replacing only the portion of the LSL on public property, which commonly arises when rehabilitating the main and reconnecting the existing line. Partial replacement is likely to increase, at least temporarily, lead levels in drinking water in homes and may not reduce lead exposure in the long run.

The default approach for most water utilities rehabilitating their main has been to simply alert property owners to the risk of partial replacement and advise them to hire a contractor to voluntarily replace the remaining portion of the LSL on their property.

Other utilities have rejected this approach and gone further to protect residents. For example, Washington, DC offers to coordinate private side and public side replacement to reduce costs and make participation easier but still expects the property owner to pay for the private side. Others, such as Cincinnati, OH, have required full LSL replacement, providing a significant subsidy to the homeowner and allowing the cost to be spread over ten years through a property tax assessment. Indiana American Water and Philadelphia, PA go even further and pay for the cost of full LSL replacement out of ratepayer or capital improvement funds. States are acting too, with Michigan requiring utilities to pay the cost of replacement on private property and Wisconsin requiring cost sharing. For more examples, see our webpages recognizing communities and states that are leading the way.

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Also posted in Drinking water, Health policy, Lead / Tagged , , , , | Comments are closed

From villages to states, significant progress on lead service line replacement in 2018

By Sam Lovell / Published: January 7, 2019

Sam Lovell, Project Specialist and Tom Neltner, J.D., Chemicals Policy Director

We recently finished a round of updates to our webpages recognizing states and communities leading the way in efforts to accelerate lead service line (LSL) replacement across the country. As we start the New Year, we wanted to summarize the good news from 2018 and highlight some opportunities for more success.

Ninety-five communities are leading the way on LSL replacement programs:[1]

  • 6 communities have publicly announced that they have completely replaced all known LSLs.
  • 53 communities have publicly set a goal of eliminating LSLs on public and private property, totaling more than 300,000 LSLs. Ten of the communities are in Wisconsin; Indiana has one investor-owned utility, American Water, which operates 27 separate community water systems; Michigan has four communities; Colorado and Ohio have two; and Arkansas, Massachusetts, Pennsylvania and Washington have one.
  • 36 communities are publicly taking steps to replace LSLs but have not yet set a goal of full replacement. One third of these communities are from Wisconsin; seven from Illinois; and five or fewer from New York, Massachusetts, Michigan, Pennsylvania, Rhode Island, Iowa, and Kentucky.

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Also posted in Health policy, Lead / Tagged , , , , | Comments are closed

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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Also posted in FDA, Lead / Tagged , , | Authors: / Comments are closed

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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Also posted in Health policy, Lead, Regulation / Tagged , , , | Read 2 Responses

FDA-approved PFAS: A serious breakdown in assessing food additive safety

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: November 4, 2018

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

This blog is the fourth in a series describing information we discovered in reviewing thousands of pages from the Food and Drug Administration’s (FDA) response to our Freedom of Information Act (FOIA) of the agency’s approval of 31 Food Contact Substance Notifications (FCNs) from 2002 to 2016 submitted by six companies for 19 distinct chemical mixtures of per- and poly-fluorinated substances (PFAS).

In this blog, we identify one company’s serious breach of its obligation to provide FDA with all relevant toxicology data. While hindsight is 20/20, we have reason to believe that if FDA had had all relevant information, it would have demanded more studies potentially revealing risks that are only now coming to light with related chemicals. Though we have not completed a similar review for the other companies, we think this inadequate approach to chemical safety is not unique to a single company, and FDA should reassess all its reviews given what is now known about PFAS chemicals.

Safety assessment requirements for food additives – including food contact substances

When a company seeks FDA’s approval of food additives (including food contact substances), it is required to provide the agency with all relevant chemistry, toxicology and environmental data so it can conduct a safety assessment. While the agency typically conducts a literature search of its own and of public databases, the company that is claiming the chemical’s use is safe is obligated to include any data that is inconsistent with the company’s conclusion.

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Also posted in Drinking water, FDA, Food, Health policy, PFAS, Regulation / Tagged , , , , | Read 1 Response

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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Also posted in FDA, Food, Health policy, Health science, Lead, Regulation / Tagged , , , | Authors: / Comments are closed