2. Remove lead-paint hazards from low-income housing built before 1960.
- HUD, EPA, and CDC should work with states and local governments to replace windows coated with lead paint, fix peeling paint, clean up contaminated dust and treat toxic soil in and around low-income homes built before 1960. HUD should also make sure that these homes remain affordable.
- The U.S. Department of Energy should encourage the replacement of lead-painted windows with new energy-efficient ones by including the benefits of preventing lead exposure under its Weatherization Assistance Program.
- The Centers for Medicare & Medicaid Services (CMS) and Title V Maternal and Child Health Services Block Grant Program should support the training of home healthcare workers and other home- based aides to identify potential lead hazards in houses with children.
- EPA and state and local governments should offer funding to schools and child-care providers to support lead paint hazard identification and mitigation.
- EPA should update its standards for lead paint, dust and soil and work with state and local governments to fund efforts to identify and mitigate lead-paint hazards in schools and child-care facilities.
3. Enforce the federal Renovation, Repair and Painting Rule, requiring contractors to control the amount of lead dust and debris created by workers.
- EPA should use its power to regulate the over 4 million renovation jobs each year and work with states and local agencies to ensure compliance. It should require that contractors perform dust testing after completing work to make sure that the home is safe.
- EPA should fund state and local agencies to support compliance and educate businesses and consumers about the hazards of unsafe renovation.
- The Occupational Safety and Health Administration (OSHA) should enhance protections for workers and their children by updating standards for lead exposure to reduce on-the-job risks and the hazards of bringing lead home from their jobsites.
4. Remove lead from food and consumer products.
- The federal government, through participation in the Codex committee, should encourage expedited reduction of international limits on lead in foods, particularly those that young children and babies are likely to consume.
5. Reduce air lead emissions.
- The Federal Aviation Administration (FAA) should expedite efforts to find suitable alternatives to leaded fuel and eliminate its use.
- EPA could help to expedite the elimination of lead in aviation fuel by using its authority under the Clean Air Act to issue an "endangerment finding," indicating that leaded aircraft fuel emissions are polluting and harmful to public health, which would then require the FAA to adopt regulations.
- EPA should implement the Children's Health Protection Advisory Committee's recommendation to reduce the National Ambient Air Quality Standard for lead to 0.02 μg/m3.
6. Clean-up contaminated soil.
- EPA and other federal agencies should collaborate with each other and businesses to remediate dangerous conditions near homes, factories and facilities that extract lead from batteries and electronics.
- EPA and states should further investigate neighborhoods near current and former lead smelter sites and other industrial and hazardous waste facilities. Findings should be shared in partnership with organizations trusted by local communities.
- EPA and HUD should coordinate Superfund efforts and lead hazard control so that when an area is treated for contaminated soil, home interiors are also made lead-safe.
7. Improve blood lead testing among children at high-risk of exposure and find and remediate the sources of their exposure.
- CDC should work with the American Academy of Pediatrics and other professional organizations to determine the factors that contribute to the lack of appropriate testing of high-risk children.
- CMS should work with state Medicaid agencies to increase the number of states that include blood lead testing at ages 1 and 2 for Medicaid-enrolled children as a Healthcare Effectiveness Data and Information Set (HEDIS) measure. HEDIS monitors and incentivizes improvements in the performance of more than 90 percent of America’s health insurance plans.
- The U.S. Department of Health and Human Services (HHS) and CDC should assist state and local health agencies in upgrading and improving blood lead surveillance at the state and local levels.
8. Ensure access to developmental and neuropsychological assessments and appropriate high-quality programs for lead-exposed children.
- HHS and the U.S. Department of Education should work with state agencies to improve access to high-quality early and middle childhood education programs for children with a history of lead exposure.
- CMS should provide adequate reimbursement for comprehensive follow-up services for children affected by lead, including lead hazard remediation and developmental and neuropsychological assessments.
9. Improve public access to local data.
- CDC should work with community organizations, local health agencies and private philanthropy, to collect census tract level data on blood lead level results; the presence of leaded drinking water pipes; and lead in water, dust, paint and soil of homes, schools, child-care facilities and other places children spend time.
- CDC should use data to produce culturally competent and accessible community reports on sources of lead and prevalence rates that are broadly disseminated to healthcare providers, school administrators and child-care operators.
10. Fill gaps in research to better target state and local prevention and response efforts.
- The federal government should support a national survey of children's blood lead levels and sources of environmental exposure.
- EPA should develop and validate a standardized method for sampling water for homes, schools and child-care facilities that can be implemented in the field by environmental health professionals.
- EPA should identify barriers to optimal corrosion control and methods to overcome them, including widespread education of the public and water utilities.
- HUD should work with EPA to design and implement a study of water from a representative sample of housing to estimate how much lead is getting into water systems and undertake large-scale studies to test the effect of soil treatments over time to inform cleanup programs.
- HUD should research the effectiveness of various lead hazard control treatments in preventing blood lead level increases.
- Federal, state and local agencies and philanthropy should conduct small-area population-based studies to identify relative risks among communities compared to the general population.
- The National Institute for Environmental Health Sciences should fund studies on the relationship between prenatal and early childhood lead and high-incidence adult conditions, including hypertension, cardiac disease and stroke.
b. What obstacles should be considered in determining which actions to include in the strategy? What obstacles pertain to one or more goals, objectives, or actions? Please be specific about the anticipated impact of the obstacles.
- Obstacles that should be considered include the following:
Inadequate awareness and prioritization of lead as an ongoing problem among the public and policymakers;
- Industry opposition to tighter standards for air, food, water, gasoline, and consumer products and industry concerns about costs and regulatory burden;
- Budget constraints at federal, state, and local levels for significant infrastructure investments in housing and water systems; and
- The current siloed nature of investments in and strategies for lead prevention and mitigation.
c. How can the obstacles be overcome? What effect, if any, would the effort to overcome these obstacles have on the ability to achieve the goals of the strategy?
To increase awareness of lead exposure as a significant, ongoing public health threat, the federal government and its partners in state and local government and the private sector could pursue a number of strategies. First, the crisis in Flint, Michigan, demonstrated to the public, policymakers, and even health leaders that LSLs pose a substantial threat to health and safety in diverse communities across the country. While lead pant hazards are concentrated in older industrial cities in the Northeast, LSLs are present in towns big and small, urban and rural. This offers an opportunity to further engage parents, schools, water utilities, elected officials, pediatricians, hospitals, and health insurers in advocating for and investing in solutions. (We offer specific messaging strategies in response to question 3a.) Second, lead prevention should be framed as a challenge that is winnable and able to generate benefits for children and families, government, and taxpayers. As our report demonstrates, replacing LSLs and removing lead paint hazards saves money and helps achieve other societal goods, such as improved school performance and lower criminal justice involvement.
To address potential industry opposition, the federal government and its partners in state and local government should develop incentives to accelerate the reduction of lead in the environment. For high-performing companies or industries (i.e. those that lead efforts to dramatically curtail lead in the environment), these incentives could include tax credits and other financial inducements, regulatory relief, and opportunities to advance corporate social responsibility objectives. The report details a number of incentives-based strategies for moving industry to act, particularly on lead paint hazard remediation. For example, Massachusetts offers income tax credits and low interest loans to assist property owners to remove or securely cover lead paint hazards in homes built before 1978 and occupied by a child under 6.
Budget constraints and siloed investments could be addressed simultaneously by promoting cross-sector efforts that reduce costs, combining funds creatively from multiple agencies and levels of government, and generating new revenues from public and private sources. To replace LSLs, communities have leveraged EPA’s Drinking Water State Revolving Loan Fund (DWSRLD)—a federal fund offering grants to states that provide a 20% match—and higher local water service fees, while identifying more cost-efficient ways of doing the work. Lansing, MI, for example, has replaced more than 12,000 LSLs since 2004 through a novel process that cut costs and time from 8 hours and $9,000 per replacement to 4 hours and $3,600. The Green and Healthy Homes initiative, with 17 sites across the country, has developed a model for blending lead hazard reduction, weatherization, and home remediation funds to address health risks holistically.3 Additionally, communities have found ways to finance remediation of lead paint and other environmental lead hazards through fees on emitters and regulatory enforcement actions.
At the federal level, the Children’s Health Insurance Program (CHIP) offers matching funds to states for certain non-coverage-related expenditures, including lead remediation. In November 2016, CMS authorized an amendment to allow Michigan’s CHIP to pay for the replacement of water pipes and fixtures in the homes of low-income families with children who are covered by CHIP or Medicaid. Properties in Flint with contaminated water received first priority. Other federal strategies to consider include: making it easier for communities to braid or blend funds from multiple programs (e.g., Superfund, DWSRLD, lead hazard control) and enabling savings in one federal account that result from investments in another to serve as a credit to the account that made the initial investment. For example, savings in special education in the federal budget resulting from lead hazard control could be directed to additional lead exposure reduction efforts.