True War on Lead Must Be Comprehensive

Environmental Protection Agency Acting Administrator Andrew Wheeler, and Housing and Urban Development Secretary Ben Carson today released an action plan to reduce childhood lead exposure.

The following is a statement from Erik Olson, senior director of Health and Food for the Natural Resources Defense Council:

"Talk is fine, but we need action. Lead is one of our most toxic pollutants, and it's in our air, waters and lands. And children are our most vulnerable population. Given this administration's abysmal track record on protecting public health, we remain skeptical."

Specifically:

• NRDC welcomes the recognition that lead remains an extraordinary threat to public health. However, this plan does not actually promise to take specific regulatory or enforcement action within any specific time. Feel-good promises to "consider" and "evaluate" actions, without time frames or commitments to take specified regulatory or enforcement action, won't protect children.
• The agencies say they will "consider" revisions to lead hazard standards from paint, as appropriate. PLEASE NOTE: EPA is under a court order to do so by July 2019. "Considering" complying with a court order doesn't cut it. EPA's July 2018 proposal on this subject did tighten the dust standards (though not as much as the public health community recommended) and completely failed to update the lead paint clearance standards, meaning that after cleanup, levels could remain the same as required in the old extremely weak standards.
• The agencies say they will revise (with no deadline) the EPA Lead and Copper Rule based on comments "from state, tribal, and local partners," without mention of public health, environmental groups and others. State and locals have fought against significant strengthening, such as mandatory replacement by a date certain of all lead service lines. EPA previously said it would propose a strengthened Lead and Copper Rule by December 2017, then changed that to February 2019. Now, it has no deadline.
• The agencies say they will assist schools and child care centers with the 3Ts approach (Training, Testing and Taking Action) on lead in school tap water. But they recently updated their approach by eliminating the recommendation that any fountain serving over 20 ppb lead should be taken out of service--there is now no recommended maximum.
• The agencies say they will "evaluate updating" the clearly inadequate blood lead reference value of 5 ug/dL, but they admit the data would dictate a 3.5 ug/dL level.
• The agencies say they will "evaluate" the impacts of continued use of lead in aviation fuel, with no promise of even proposing action as recommended by public health experts.
• The agencies say they will "reevaluate" the provisional tolerable total dietary intake level for lead in food, and will "consider" increased monitoring and will "consider whether to establish maximum lead levels in foods," without even promising to propose rules or guidelines or giving any dates for action. Meanwhile, the 1993 intake level is woefully out of date, and recent EPA data shows about 1 million kids are over current the FDA limit.