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

For the past 20 years, the Children’s Health Protection Advisory Committee (CHPAC), with its diverse members that include pediatricians and industry toxicologists, has been responding to requests for guidance from Environmental Protection Agency (EPA) administrators. In December 2016, EPA’s Administrator asked CHPAC to provide the agency with its “highest priority advice” on lead. Citing the children’s health risks posed by lead, the economic and racial disparities and the demonstrated effectiveness of national leadership on the issue, on April 6, CHPAC sent the new administrator, Scott Pruitt, a letter with its four recommended priorities:

1. Strengthen the Agency’s Lead-Based Paint Hazards Standard for lead in paint, dust, and soil. CHPAC stated that the “best evidence shows that a young child living in a home meeting the current lead dust standard still has a 50% chance of exceeding the CDC reference level for blood lead.” The EPA standard is so insufficient and outdated that on February 1, 2017, the Department of Housing and Urban Development said it would require its lead hazard control grantees to meet a more protective level that is one-fourth of EPA’s standard.

2. Revise the Lead and Copper Rule to reduce lead in drinking water. CHPAC highlighted several high profile incidents of high levels of lead in drinking water and called for EPA to overhaul its 1991 Lead and Copper Rule to better protect children, especially infants dependent on formula for nutrition. CHPAC recommended the revisions be consistent with the recommendations from the agency’s National Drinking Water Advisory Committee and the lessons from recent water system lead contaminations.

3. Improve risk communication efforts to provide clarity and consistency. CHPAC asked that EPA revise its “Protect Your Family from Lead In Your Home” booklet that is given to every family buying or renting a home built before 1978 so that it more effectively helps families make decisions regarding the risks posed by lead. The committee cited three problems with the booklet, it:
   • “insufficiently describes other important lead sources including, but not limited to, drinking water faucets, plumbing, traditional and cultural products, and take-home exposures from work”;
   • “treats all homes built before 1978 as equal and does not explain that the likelihood of having lead-based paint varies dramatically based on the age of the home”; and
   • “relies heavily on text rather than graphics making it less effective for some audiences.”

4. Encourage the Administration’s infrastructure investment program to support healthy housing, childcare facilities, and schools, and safe drinking water. CHPAC recommended that EPA work closely with other federal partners on the President’s Task Force on Environmental Health Risks and Safety Risks to Children to help ensure that all Administration infrastructure investment programs make housing, childcare facilities, and schools healthier, and drinking water safer.

The letter was sent a day after the Washington Post reported on a leaked March 21, 2017 agency memo that details how EPA plans to execute the 31% cuts to its overall budget called for in the President’s proposed budget. The article’s headline says it all: “Trump’s EPA moves to dismantle programs that protect kids from lead paint.” If Congress goes along with these cuts, it is difficult to imagine how the agency could fulfill its basic responsibilities much less implement CHPAC’s recommendations to protect kids from lead.