Lead Paint

National policy changes end “lead poisoning” era

American Council on Science and Health:
Lead poisoning is “not a widespread
public health threat.”

U.S. Center for Disease Control:
End universal screening of children
for lead poisoning.

U.S. Environmental Protection Agency:
No lead paint needs to be abated unless
it “is in poor condition.”

But some states, including Massachusetts,
still plug the old ways:

  • Dangerous scraping of intact lead paint in every home with a child
  • Universal screening of all children at taxpayer expense
  • Scare brochures calling lead “the nation’s number one environmental health problem for children”

EPA:“The regulations would not require private property owners to undertake hazard control... Instead, the EPA expects owners to take action voluntarily.”

American Council on Science and Health:“Exposure to lead can be successfully eliminated or minimized through adjustments to personal habits, public education, and improvements in living conditions, particularly among certain population groups.”


      Less than a year ago, we reported comments by two mainstream national experts on lead poisoning and concluded: Abatement Is Dying.
      Now we can report another, major turn of events. The costly, hazardous, ill-conceived procedure of lead paint abatement, following the fate of asbestos removal, is much closer to death.
      Two top federal agencies and one respected independent national council have all announced a major shift in approaches to lead poisoning and its prevention.
      These shifts reflect a growing awareness that:

  • Lead poisoning is now quite rare.
  • The risk of getting poisoned from undisturbed, intact lead paint in the home is zero.
  • Removing lead paint is itself very hazardous and not effective in reducing risk.
  • Teaching parents about clean habits with their children is effective and sufficient.

Let’s take a closer look at these major policy shifts.

Environmental Protection Agency
      In June, the EPA, one of the strongest federal watchdog agencies, proposed a new standard for lead hazard control that is mild, to say the least, compared to the abatement model followed in Massachusetts and other states. (See references below.)
      The first notable change is that the EPA’s goal is to reduce lead hazards, not eliminate lead in the home environment, an important distinction that Congress itself wrote into the 1992 Act known as Title X.

Lead paint
      The EPA now wants to define a lead paint hazard not in terms of the presence of lead paint anywhere, but quite simply as “paint in poor condition.” “Poor condition” is defined as more than 10 square feet of deteriorated paint on the exterior of a house and more than two square feet of deteriorated paint on the interior.
      As a result,intact lead paint is not a hazard, and nothing needs to be done to it. This standard would eliminate 90% of the deleading and abatement work required in Massachusetts and some other states.
      The EPA then says that small amounts of hazardous lead paint “can be addressed by repairing deteriorated paint.” That’s a simple handyman job, and almost all houses in half-good shape can be kept in satisfactory condition with ordinary on-going maintenance no matter how much lead paint an inspector finds in the house.
      Larger amounts of deteriorated paint need to be abated. But only deteriorated paint, not intact paint. That greatly reduces the total amount of deleading compared to the standard abatement model used in Massachusetts.

Soil lead
      Similarly with soil. The EPA abandons its Superfund standard of 400 parts per million (ppm) lead concentration in soil and defines 2,000 ppm as the point at which soil lead becomes a “hazard.” Moreover, the 2,000 ppm is a yard-wide average measurement, not the maximum or peak concentration found in the yard. That is a great relaxation of the soil standard.
      Below the new 2,000 ppm, some lead in soil may be considered a cause for “concern,” which the EPA says “should be communicated to the public.” But the EPA “would impose no legally recognizable requirements on any person or entities.” Instead, it “recommends low-cost measures” as “sufficient to reduce exposure” voluntarily.
      Those low-cost measures (you’ve heard them before because this newsletter talked about them a long time ago) are:

  • covering bare soil,
  • using doormats,
  • more frequent washing of children’s hands and toys, and
  • limiting access to areas of the yard where lead is more concentrated.

New awareness on lead paint
      This dramatic easing-up on lead paint reflects a new understanding at the EPA that lead paint — intact or deteriorated — is not nearly as risky as once supposed. One very good reason to make this conclusion is that blood lead levels declined dramatically all across the nation, among adults and children, over the last two decades — a result almost entirely of removing lead from gasoline (see the chart).


This chart, reproduced from the American Council report, shows that lead in the blood of Americans dropped by a third in four short years, in very close track with plummeting use of lead in gasoline. Lead paint, once thought so important, is not a factor.


      The snail’s pace of lead paint abatement over the same time period demonstrates that lead from paint was never a big component in blood lead levels. Out of 100 million dwelling units in the country, 64 million still have lead paint in them, but that did not stop the dramatic decline in blood lead levels.
      Now average lead levels are so low (for children, the average is 2.9 micrograms per deciliter, down from about 15 micrograms in 1970) that no known health risks are associated with them. Any further reduction can come only in tiny increments at great cost. The cost may be too high for the benefit.
      For the same reason, the EPA is easing up on lead in soil. The lead is still there, it does not dissipate, but it had no role in the dramatic decline in national lead levels.

Lead dust
      When it comes to household lead dust, however, the EPA’s proposed standards stay fairly strict: a hazard exists if the lead in dust exceeds 50 micrograms per square foot on bare floors or 250 micrograms per square foot on interior window sills. This rather strict standard reflects the latest view that lead dust, coming from a variety of sources, is the real culprit whenever some children get elevated blood levels noticeably above the new low average.
      In the EPA’s words: “Ingestion of lead-contaminated dust and soil through normal hand-to-mouth activity appears to be the primary pathway of lead exposure to U.S. children under 6 years of age.”

Easy clean-up
     v But the remedy for lead dust is extremely simple: just clean it up. The only EPA advice is: “Lead dust hazards should be addressed though intensive cleaning.” And it goes on to say: “If household surfaces are smooth and cleanable, regular household cleaning can probably maintain acceptably low levels of lead in dust.”
      So there it is, straight out of the EPA. The best solution to the worst problem in lead poisoning — lead dust — can be done simply by the housekeeper or, in the worst cases, such as after remodeling, by a handyman. Installing smooth, cleanable surfaces — like window-well liners — is also a handyman job.
      Professional abatement contractors appear to be unnecessary in all preventive hazard reduction (but not when a child is identified with elevated blood lead levels). The incentive would seem to be: owners, take care of the hazard while it’s easy, before it becomes much more serious trouble.

All voluntary
      The final coup de grace: it’s all voluntary! The EPA states: “The regulations would not require private property owners to undertake hazard control actions when hazards are identified. Instead, the EPA expects that concern about children’s health, liability exposure and other market forces will provide incentive for property owners to take action voluntarily.”
      Abatement bureaucrats: pack up your bags, the party’s over!

Center for Disease Control
      Another major shift comes from the federal agency that deals on the medical side of the problem. In 1991, the CDC had recommended virtually universal screening of all children up to six years old. Seeing the overall decline in blood lead levels, however, the CDC revised its views just last year and announced targeted screening of at-risk children only.
      In other words, test only those kids who we know are likely to get higher levels of lead in their blood. It’s a waste of time and money to test kids we are pretty sure have an extremely low risk of exposure.
      So who are those at-risk kids? They have become abundantly clear in the last 10 years from a series of national studies called the NHANES studies. They are not white, middle-class kids. They are considerably less than 5% of all kids. They are a numerically small, very definite group located in known “pockets”: children of minority families living in lower-income, inner-city neighborhoods in marginal, older housing.

The cost problem
      Now we see the shape of the real problem with lead paint abatement. The middle-class families whose children don’t get poisoned can afford the costly, Massachusetts-style paint abatement procedures that have been held up in the past as the only acceptable approach. But the poor families whose children do get poisoned can’t afford it. When harsh abatement laws come cracking down on these poor families and their landlords, the result is often abandoned housing and displaced families.
      That was the key observation a year ago of the national housing expert we reported on. She saw a lot of abandoned housing across the country that was in pretty good shape when it was abandoned, whose owners had fled from the cost of lead paint abatement that their poor tenants could never pay for. Abatement done the costly way was ruining lower-income neighborhoods.
      Of course, one workable way to do that costly, old-style abatement for poor families is with massive public spending. But that’s something that won’t find favor in today’s political climate.
      Fortunately, just when the CDC recognizes that the problem is only with poor inner-city children, the EPA comes up with a much more reasonable, low-cost approach — “lead paint hazard reduction” instead of costly, take-it-all-out abatement.

American Council on Science and Health
      But are these policy shifts by the EPA and the CDC just compromises forced by the politics of funding aid to low-income families? Will children, especially poor children, get short-changed by the new standards?
      The answer is no. And it comes from the American Council on Science and Health, a respected group of scientists and doctors that studies the nation’s health policies and refuses to accept any funds with strings attached. Nine months ago, it came out with its report “Lead and Human Health” (available on the Internet; see references below).
      The basic answer in the American Council report is:

  • real poisoning, with established health effects, is extremely rare everywhere,
  • government agencies and activists exaggerate the remaining health risks,
  • health risks of low levels of lead in children are miniscule or non-existent,
  • lead paint abatement is not usually effective anyway, and
  • simple cleanliness habits and public education will work effectively to control what little risk remains.

A public health victory
      The American Council report clearly announces the end of lead poisoning in children. That is, real lead poisoning where negative health effects are known.
      The report’s one-page summary says: “Symptomatic childhood lead ’poisoning,’ seen often until the 1970s, has essentially disappeared.” It goes on to say: “Such lead poisoning no longer constitutes a widespread public health threat in the U.S., [but] problems in localized areas continue to exist.” The report twice quotes and supports the CDC statement that childhood lead poisoning “is not a major environmental health problem in the United States, but remains a disease of the poor and underprivileged.”
      About 95% of all young children in the U.S. currently have blood lead levels under 10 micrograms per deciliter, the latest and lowest cut-off point marking a “level of concern” (far below a “poisoning” level). The average for all Americans is now a very low 2.3 micrograms per deciliter, down from around 20 micrograms two decades ago. This great public health success comes, the report says, from getting rid of lead from gasoline and from consumer products like lead-soldered food cans.
      But the American people still believe in “lead poisoning.”

Bias and confusion
      The American Council complains that the “general public remains confused.” It blames the confusion on “conflicting and often biased information disseminated by government agencies, industries, and activist groups.” It also blames the news media for failing “to distinguish real environmental health hazards from minor, perceived human health risks.” In simple words: scare tactics are keeping a lot of people employed.

No real health risks
      The confusion remains because all the possible effects of high-level poisoning, though it rarely occurs, can be listed to scare people. Meanwhile, middle-level “poisoning” has a few mild effects that disappear if it’s treated, and it only happens sometimes in those inner-city pockets of poverty. Finally, low-level lead, while it’s more widespread, is probably completely harmless, even though researchers are trying like the dickens to find detectable health effects.
      Here’s what the American Council, in careful scientific language, says about these three different levels of lead in the blood.
      (1) At 60 micrograms per deciliter or higher, lead can produce recognized health effects on nerve function, kidney function and fertility — that’s all that’s clearly known. Moreover, if the high levels are reduced quickly enough, these health effects often go completely away. Other possible health effects — on the bones, metabolism, cancer, and blood pressure — have been studied extensively, but according to the American Council, the findings are not clear-cut. There is often little or no proven health effect.
      (2) At 25 to 50 micrograms per deciliter, lead is not considered a problem for adults, and the focus is on children. Researchers have been trying hard to detect subtle effects on the nervous system, effects like lower IQ, hyperactivity, and short attention span. The American Council reports that a lot of studies have been done at this blood level, but it accepts only one as valid. That one finds “an association” between lead and IQ, but only at “moderate to high blood lead levels, typically in excess of 30 to 40 micrograms per deciliter.” That’s it, folks. The American Council report finds no good evidence for any other adverse health effects at this moderate level — and that “moderate to high” level is going to be fairly rare even in those inner-city pockets.
      (3) At levels below 20 micrograms per deciliter — almost everyone is now very far below 20 — there is “controversial” evidence that this low-level lead exposure may cause “a small IQ deficit” in children. The American Council, however, seriously questions whether there is any real truth to the evidence. Here are its reasons:
      The cause could be the reverse.It’s entirely possible, the Council says, that children with lower IQs get themselves exposed to more lead. The lower IQs could be causing the higher lead levels, not the other way around. It’s also been suggested that low levels of lead cause hyperactivity and short attention span. But here, also, it could be the other way around. Hyperactivity and short attention span could, the Council says, make kids “more likely to ignore warnings” about eating lead-contaminated dirt, for example. None of the studies were designed to correct this causality problem.
      Other factors could be the cause.Maybe it’s not the lead but something else that’s causing the “small IQ deficit.” Researchers always try to eliminate such “confounding” factors, but the American Council says “there are many additional variables that remain uncontrolled in most of these studies.” Here are some of those other factors that could be causing “the small IQ deficit.” Most of them, by the way, will be found much more often in those inner-city pockets of poverty.

  • Ear infections, which are known to lower verbal IQ scores, weren’t controlled for in the studies.
  • Low parental IQ, which everyone agrees has a big hereditary and environmental effect on a child, “is almost always discounted or ignored” in the studies, says the Council.
  • Poor nutrition is known to lower IQ in children, and good nutritional supplements are known to increase IQ “substantially,” not just a little bit. Yet nutrition is “seldom considered an important variable” in the studies. The Council zeroes in on iron deficiency in particular. It’s well known that iron deficiency reduces mental functioning in children. It’s also well known that iron deficiency increases the body’s absorption of lead. Iron deficiency could easily cause both lower IQs and higher lead levels, the Council says, but the studies don’t check it out.
  • Low socioeconomic status, childhood disease, and poor parenting skills are other possible causes that the American Council says the studies don’t correct for. Of course, these factors, like the others, predominate inthe inner city and could be the real cause of both lower IQs and higher lead levels.

      There are just too many other plausible causes, the American Council says, to accept the idea that a low level of lead causes “a small IQ deficit.”

What is safe?
      Over and over again, the American Council warns against the assumption that if high levels of lead are known to be toxic, any amount of lead must be toxic. It points to studies that show trace amounts of lead are found “in virtually all foods.” It calls small amounts of lead “toxicologically irrelevant.” It says that some “measurable effect” of lead on the body does not mean that the effect is toxic. It warns against any further lowering of lead level guidelines until there is “clear, unequivocal” evidence of negative effects. The danger, it says, is that “attention may mistakenly be focused” on children with no problems, meanwhile ignoring “those subpopulations truly in need of intervention” — children in the inner-city pockets.

Simple solutions
      The American Council also warns against standard lead paint abatement programs which have “become popular” and mandated in some states. “We have learned from past experience, such as asbestos, that in many situations abatement is either ineffective or may actually increase health risk by dispersing the substance. There is often no need to renovate, strip, or raze a home merely because it contains lead paint. If the paint is intact and not peeling, and there is no evidence of lead dusting, then costly and disruptive [abatement] activities may not be advisable.”
      The American Council says abatement should be “considered” only if an elevated lead level is confirmed, the level is high enough that a health risk is “probable,” and only if abatement can effectively reduce the risk. It quotes one comprehensive study that says abatement is, at best, “only partially effective.”
      In the end, the American Council recommends only some “simple” practical strategies — and doesn’t even mention standard lead-paint abatement as one of them.
      For personal strategies, it recommends careful control of peeling or flaking paint, control of children around dirt, frequent hand-washing, and good nutrition.
      At the public level, it recommends programs to identify high-risk individuals. “Exposure to lead can be successfully eliminated or minimized through adjustments to personal habits, public education, and improvements in living conditions, particularly among certain population groups.”
      Once again noting that the country has gotten off track on the subject of lead, the American Council concludes that we need to “place into perspective other known environmental health hazards that deserve equal or greater attention.”

References:

1. Environmental Protection Agency, “Lead; Identification of Dangerous Levels of Lead; Proposed Rule,” Federal Register, Vol. 63, No. 106, pp. 30301-30355, June 3, 1998.

2. Center for Disease Control and Prevention (CDC), “Screening Young Children for Lead Poisoning: Guidance for State and Local Public Health Officials,” U.S. Department of Health and Human Services, 1997.

3. American Council on Science and Health, “Lead and Human Health,” December 1997. Published on the Internet at: http://www.acsh.org.

CLPPP protests new EPA rules
      As a measure of just how radical the proposed new EPA rules on lead poisoning are, the Massachusetts Childhood Lead Poisoning Prevention Program (CLPPP) sent the EPA a five-page memorandum registering their “grave concern” that the new rules are “not protective of childrenâs health.”
      As reported in the October newsletter, the EPA is proposing new guidelines on lead paint abatement that would require no abatement at all if lead paint is intact, and no professional abatement unless non-intact lead paint exceeds 10 square feet on the exterior or two square feet on the interior. Primary stress is laid on educating parents about cleanliness in the home. Yet more radical, the EPA proposed no mandatory requirements on property owners, saying that voluntary compliance with the new guidelines could be expected from simple concern for childrenâs health, liability exposure, and other market forces.
      The EPAâs proposed rules, if enacted, would likely end most state programs of lead paint abatement, especially invasive ones like Massachusettsâ.
      Defending its program, CLPPP claimed that it has been “highly successful in substantially reducing the incidence of childhood lead poisoning in this state,” citing a 74% decline in poisoning from 1987 to 1998. CLPPP attributed its success to universal screening (no longer recommended by the U.S. Center for Disease Control), environmental intervention, required residential lead abatement, case management of poisoned children, early intervention for high-risk children, and public awareness through education.
      What CLPPP did not mention is the removal of lead in gasoline, which all experts agree has been the single most important factor in reducing blood lead levels dramatically across the nation. Of course, bureaucrats whose jobs are at stake are not be able to evaluate the scientific evidence objectively.