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

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

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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Posted in EPA, Health Policy, lead, Public Health, Regulation / Also tagged , | Read 2 Responses

EPA undermines its own proposal for more protective dust-lead hazard standards

Tom Neltner, J.D.is Chemicals Policy Director

On July 2, 2018, in response to a court order, the Environmental Protection Agency (EPA) published a proposed rule[1] tightening its standards for lead in dust on floors and window sills for housing and child-occupied facilities built before 1978. The agency declined to lower the standard for lead in paint – citing insufficient information – and did not consider tightening the standards for lead in soil. While the proposed rule is a tentative step forward for lead poisoning prevention, as explained below, it will create unnecessary confusion and falls far short of what the science and the law demands. Comments are due by August 16, 2018. Pursuant to an order from the Ninth Circuit Court of Appeals, EPA must finalize the rule by July 1, 2019.

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

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

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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Posted in Emerging Science, EPA, Health Policy, Health Science, lead, Regulation / Also tagged , , | Read 1 Response

Federal court of appeals gives EPA one year to update lead-based paint standards

Tom Neltner, J.D.is Chemicals Policy Director

Update: On July 2, 2018, EPA issued the proposed rule after the court gave it a 90-day extension. The agency has one year – until July 1, 2019 – to issue a final rule. Blog clarified on timing.

This week, the federal Ninth Circuit Court of Appeals directed the Environmental Protection Agency (EPA) to update its regulations defining lead-based paint and how much lead in dust represents a hazard. The court gave EPA 90 days to issue a proposed rule and one year later to publish a final rule with an option to convince the court that it needs additional time. The court said the agency had unreasonably delayed action on a citizen’s petition submitted in 2009. The science showing the need for action has only become more compelling in the eight years since EPA acknowledged the shortcoming of its rules. Rather than drag out this litigation, the agency should move quickly to revise its lead-based paint hazard standards to better protect children’s health.

EPA set the dust-lead hazard standard in 2001 after determining that a child living in a home with those levels had only a 1 to 5% chance of having an elevated blood lead level (EBLL) as defined by the Centers for Disease Control and Prevention (CDC). The scientific evidence now shows that the risk is greater than previously estimated. In addition, CDC has tightened its definition of an EBLL. As a result, according to the American Academy of Pediatrics, the risk to a child of having an EBLL in a home that meets EPA’s current dust-lead hazard standard is more than 50%.

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