Primary Prevention Strategies Handbook: Conceptual Outline Comment (Draft)
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October 1, 1991
38 pages
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Case Files, Matthews v. Kizer Hardbacks. Primary Prevention Strategies Handbook: Conceptual Outline Comment (Draft), 1991. 354ddbaf-5c40-f011-b4cb-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/19ec9250-34c3-49b6-9ee9-6c5199a306b9/primary-prevention-strategies-handbook-conceptual-outline-comment-draft. Accessed November 23, 2025.
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PRIMARY
PREVENTION STRATEGIES
HANDBOOK
CONCEPTUAL OUTLINE
Comment Draft
October 1991
ALLIANCE TO END CHILDHOOD LEAD POISONING
600 Pennsylvania Ave., S.E., Suite 100
Washington, D.C. 20003
PRIMARY PREVENTION STRATEGIES HANDBOOK
CONCEPTUAL OUTLINE
TABLE OF CONTENTS
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Key "Concepts «=. oi Be’ oi cis eins niintin ‘sila cet n- 9 # wo o%8
Screening a. yin oil At dy he Tes Ne 2
1ead Hazard ReQUCLION ovis v's wis vivid v vin. 17
Intervention Criteria Chart and Instructions C-1
RESON CER or ob het vl ei i, Ee SB Sel Tet
Legislation +. 0. vk ni. LE, hie ee 27
Education/Community Outreach /, , . 0 av wide 230
PRIMARY PREVENTION STRATEGIES HANDBOOK
CONCEPTUAL OUTLINE
INTRODUCTION
PURPOSE
The purpose of this conceptual outline is two-fold: 1) to provide
a framework for the Primary Prevention Strategies Handbook and 2)
to provide an opportunity for public comment and solicit
suggestions on the final form and content of the Handbook.
PUBLIC COMMENT REQUESTED
The Alliance encourages public comment on this draft of the
Conceptual Outline. PLEASE REVIEW AND SUBMIT YOUR COMMENTS TO
THE ALLIANCE IN THE SELF ADDRESSED ENVELOPE PROVIDED.
PRIMARY PREVENTION STRATEGIES (PPS) PROJECT
The Conceptual Outline is a key intermediate point in the PPS
project. This two-year project has been funded by a grant from
the U.S. Environmental Protection Agency. The project will
result in the preparation of a "Primary Prevention Strategies
Handbook" at the end of next September (1992). The purpose of
the project is to define a primary prevention strategy and make
recommendations for its active and effective incorporation into
comprehensive childhood lead poisoning prevention programs at the
state and local levels.
The project arose out of the need to devise a new paradigm for
childhood lead poisoning prevention based on the need to respond
to the greatly increased number of children identified at risk by
revisions to the Centers for Disease Control guidelines. Most
local programs are already overstretched in attempting to deal
with lead poisoning poisoning and will be hard pressed to respond
to additional cases. The project intends to devise primary
prevention strategies that take into account the limitations of
existing resources and programs and at the same time provide the
basis for establishing and implementing effective and
comprehensive childhood lead poisoning programs oriented toward
prevention.
PRIMARY PREVENTION STRATEGIES HANDBOOK
SUMMARY OF PURPOSE
The Handbook is specifically intended to serve as a "cookbook"
for designing and implementing local primary prevention programs
to reduce and eliminate childhood lead poisoning. It will offer
new productive approaches for effectively responding to the
greatly increased numbers of children identified at risk by
current research and revisions to the CDC guidelines. The
Handbook will outline the critical elements of comprehensive
model action programs for state and local governments. Recogniz-
ing the reality of resources limitations and existing program
gaps, the Handbook will identify initial steps to launch effec-
tive programs and will provide practical guidance on setting
priorities and allocating resources for maximum risk reduction
and public health benefit. :
TARGET AUDIENCE
Primary Audience - State and Local decision-makers (e.g., mayors
and city council members; governors and legislators).
Secondary Audience - State and local program officials;
interested public (community groups; energized individuals);
health care professionals; Federal officials and decision-makers;
other potentially interested professionals and business people
(e.g., lead abatement contractors, lawyers, lenders, insurers,
realtors).
ORGANIZATION AND FORMAT
Keeping its primary audience of state and local decision-makers
in mind, as currently conceived the Handbook will be in three
different sections or three separate volumes
The first part of the Handbook - which evolved from the idea of
an executive summary of the contents of the entire Handbook -
will be designed to highlight in succinct and dramatic form the
nature of the childhood lead poisoning problem, the urgent need
to devise solutions, and an outline of what form a comprehensive
childhood lead poisoning prevention should take. This part of
the Handbook needs to have compelling illustrations and forceful
arguments succintly expressed in order to grab the attention and
spark the imagination of the decision-makers.
The heart of the Handbook will be an elaborated outline of the
elements of a Comprehensive CLP primary prevention program and
how they should operate in coordination with one another.
The final part of the Handbook will be a resources guide. It
will refer to the best available literature and material on
various aspects of CLP prevention - e.g., education materials,
basic information about the nature of the problem, techniques and
protocol for lead hazard reduction, etc. ad infinitum.!
FORMAT OF THE CONCEPTUAL OUTLINE
This conceptual outline consists of four basic elements that
serve as organizing principles for the Handbook: 1) consensus
principles; 2) innovative ideas; 3) success stories; and 4)
program incorporation.
Consensus:
During the course of the development of the Handbook so far,
there seemed to be a great need to articulate the consensus
of a enlightened opinion about the causes of and solutions
to childhood lead poisoning. It should be emphasized that
this is not a wane distillation of the status quo, but is
rather intended to move solutions forward by serving as a
guide to the most current and enlightened thinking on the
subject.
Innovation
Innovation is at the heart of the Handbook, because we need
to devise new approaches to take account of the greatly
lowered threshold of concern for childhood lead poisoning.
Innovation is not intended to mean something no one has ever
thought of before, but rather to identify those approaches
that have been proposed but never implemented, or that
represent extensions of or revisions to existing practice.
1*The best explanation for the format might be a description
of a process by which a CLP prevention is established. The
decision maker becomes aware of the problem and is convinced of
the need to take effective action to combat it and subsequently
ask the staff to prepare the details of a program, which would
then be enacted and implemented. The resources guide part of the
Handbook is in essence an efficient way to make sure that the
voluminous amount of material reviewed during the Handbook
preparation process is not lost. The purpose of the Handbook is
not to produce original material on all aspects of childhood lead
poisoning, e.g., innovative and educational materials. However,
it would be helpful to have some basic resource for the best
available material at the time of publication.
Success Stories
The thrust of the Handbook is intended to be constructive
and positive. Despite a cyclical failure to deal with child-
hood lead poisoning and an historic limitation of resources,
the Handbook operates on the assumption that it is possible
to effectively achieve childhood lead poisoning prevention.
As part of its approach, the Handbook intends to interject
examples of successful programs or approaches to combating
childhood lead poisoning. The success stories can be "small"
and include individual or highly local efforts. The
"Success Stories" are designed to illustrate specific
textual points and will be placed in blocks within the text
near the relevant points that they support. An example of
the format will be:
Program Incorporation
Programmatic incorporation is essential to the Handbook. It
encompasses suggestions about how to take primary prevention
strategy elements and integrate them effectively into a
workable program.
We especially solicit the reader's nomination of success stories
and resources materials.
PROCESS OF PREPARING THE HANDBOOK
Public comment on the conceptual outline is an important part of
the Alliance's preparation of the Handbook. The development
process has emphasized collegial discussion and opinion sharing.
As part of the process, six informal technical advisory
committees (TAC's) were formed made up of knowledgeable people in
particular fields. The TAC's are: Abatement; Education/
Community Outreach; Model Law; Resources (how to find the re-
sources to accomplish lead hazard reduction); Screening; and
Local Government. Consistent with the interdisciplinary approach
to CLP that forms the core of the Handbook, it is expected that
4
the different TAC's will cross-fertilize, and comment
collectively on the draft sections of the Handbook as they are
produced.
PRIMARY PREVENTION STRATEGIES HANDBOOK
CONCEPTUAL OUTLINE
KEY CONCEPTS
In the attempt to devise a "new paradigm" for primary prevention
and in the course of the technical advisory meetings, several key
concepts repeatedly emerged as leitmotifs. Although this
Conceptual Outline proposes a Handbook organization that is
divided into the elements of a primary prevention strategies
program -- screening, lead hazard reduction, resources, and so
forth -- the nature of CLP prevention requires organization along
interdisciplinary, synthetic, cross-categorical lines. As a
result, the "key concepts" section of the handbook, should form
its core and contain the basic ideas that should pervasively
inform the development and implementation of primary prevention
strategy programs. :
PRIMARY PREVENTION
o Primary prevention is the animating principle of the PPS
Handbook. The Handbook represents an attempt to develop new
programs and remove existing CLPP programs away from the
circular approach of tracking and medical case management to
a genuinely preventive effort focused on lead hazard
reduction, and prevention of exposure in the first place.
o History has demonstrated how very difficult it is to
incorporate true primary prevention as a pervasive working
concept in the ongoing operation of most CLP programs. Both
because of resource constraints (and praiseworthy concern
about treating existing cases of childhood lead poisoning as
a first priority), and lack of coordination among different
agencies and departments, the objective of prevention tends
to get lost in the day-to-day operation of programs. The
relationship of screening to prevention also raises
difficult issues that must be addressed philosophically and
programmatically. As discussed in the Screening chapter,
below, while screening is by strict definition secondary
prevention, it is an essential element of a primary
prevention program. However, the screening elements of a
program must be coordinated with the other elements - most
notably, lead hazard reduction- to make sure that screening
is used as an indicator and guide to lead hazard reduction
actions.
INTERDISCIPLINARY
Oo Another informing concept of the PPS Handbook is the
interdisciplinary focus necessary to effectively solve CLP.
Few problems span as many fields and disciplines - medicine;
housing; public health; environment; social action. As a
result, the problem tends to be compartmentalized: housing
advocates may see CLP as an environmental problem,
environmentalist may see it as a poverty problem, public
health officials may see it as a housing problem, etc., etc.
in a circular definition. The lack of agency coordination
sometimes seen in CLP prevention programs ultimately
reflects a lack of interdisciplinary perspective. It is not
uncommon, for example, for a (separate) municipal housing
department to give very low or no priority to requests for
lead-based paint inspections requested by the health
department in cases where lead poisoned children have been
identified. It is very rare -- to take another example --
for local environmental departments to be at all involved in
lead poisoning prevention (for example, soil inspection).
Screening itself is a primary example of the typical lack of
interdisciplinary focus since it is rarely linked with any
degree of directness or effectiveness to lead hazard
reduction activities.
REGULATION-DRIVEN
Oo Effective solution of CLP depends in the first instance on
existing laws, regulations, and sustained program
development. Even though education, catalyzed communities,
and the private sector all have key roles in the effort to
eliminate childhood lead poisoning, an enforceable
regulatory program is required to persuade - and in some
instances, coerce- people to take action to prevent, reduce,
or eliminate lead hazards. In the course of developing this
Conceptual Outline, we have been unable to identify any
instance where "pure" private sector involvement based on
the operation of market forces occurred to achieve lead
hazard reduction absent a basic regulatory program.
One key issue raised when the problem of lead poisoning is
viewed through the prism of an ongoing regulatory program is
the degree to which one assigns responsibility and liability
for the problem. The obligation to reduce lead hazards on a
continuing and effective basis may, as a practical matter,
be too much of a burden to place on already overburdened or
dysfunctional families. The assumption of public
responsibility through legal, regulatory, and program
requirements is both ethically and practically necessary to
the solution of the CLP problem.
DELIVERY SYSTEMS
oO Even assuming a populous that is well-informed about lead
issues, lead abatement and prevention cannot be accomplished
unless effective delivery systems are in-place and
operating. The idea of delivery systems encompasses the
legal and regulatory bases of programs (see Regulation-
Driven above) and also includes procedures for achieving
lead hazard reduction and mandating screening of children.
OPPORTUNITY POINTS
Oo It is important that CLP programs take advantage of all
available opportunities to reduce hazards. This Conceptual
outline recommends various opportunities or transaction
points that should be integrated into an effective CLP
prevention program. Inspection and lead hazard activities
can be most easily accomplished, for example, when a unit is
vacated. Thus a requirement of inspection and rigorous lead
hazard reduction should be mandated when vacancies occur or
when real estate is sold. To take another example, lead
hazard reduction must be incorporated into normal housing
transactions as recommended in the Resources chapter.
MAKING LEAD ABATEMENT POSITIVE AND VALUABLE
oO Although eliminating CLP depends in the first instance upon
a legally authorized regulatory base, lead hazard reduction
also needs to be presented as a positive action that will
increase the economic and amenity value of property, as well
as protect children. Lead hazard reduction, for example,
might be tied into weatherization and energy improvement
efforts, as well as more general home improvement and
rehabilitation activities. As housing consumers become
better informed, the marketplace should reflect the added
value of lead-safe housing.
SOCIETY'S SELF-INTEREST
oO Another positive aspect of eliminating childhood lead
poisoning is the fact that from even the hardest and most
calculatory perspective it is essential for the U.S. to
eliminate childhood lead poisoning prevention in order to
increase its national productivity. The nature of CLP is
such that it affects --often in subtle ways-- the
intellectual growth of children. In effect, CLP reduces the
stock of intelligence and potential productivity in the
nation as a whole.
HEALTHY COMMUNITY
Oo Ultimately, removing the hazard of lead from a community is
part of building a healthy and empowered community. It has
been suggested that some definition or vision of a "healthy
community" is essential to inspiring local groups -
especially in impoverished areas - to tackle lead hazard
reduction as part of an overall improvement program.
Lead hazard reduction should tie into a larger survey and
profile of a community's needs and (often hidden) resources.
It also is desirable to use outreach workers from the
community itself, have the program use its resources to
train them, and send them back into the community as a
resource.
Examples of programs that tie into the idea of the
development of a "healthy community" are community
reinvestment and employing and training community workers to
undertake lead hazard reduction in their localities.
COMMON LANGUAGE
Oo One of the most important things the Handbook can do is to
help formulate a common language to use in addressing
childhood lead poisoning. In the Lead Hazard Reduction
chapter, we have tried to define terms carefully so as not
to imply that every situation requires a equivalent (and
expensive) response or immediate full abatement. In
conjunction with this calculated redefinition of abatement,
we have also proposed use of the term "bioavailability" as
an indication that the mere presence of lead is not the
operative event, but rather the risk it presents in a
particular situation. ;
Careful definition in the course of establishing a common
language should lead to common criteria. Again using the
lead hazard reduction principles as an example, a definition
of hazard that accommodates a hierarchy of response efforts
can qualify both the nature of the problem and the
effectiveness of the response.
LEVERAGING RESOURCES
oO Another key concept in the development of the Handbook is
the idea of leveraging resources. This has several
dimensions. In its program aspect, it could mean, for
example, utilizing outreach workers with maximum utility by
making them a "one stop" source of information about various
social programs.
Another example of leveraging resources is the incorporation
of lead inspections into overall municipal and state
inspection programs. Thus, when a housing or environmental
inspector goes to a house or a site, inspection for lead
should be a part of his inspection procedures.
One further example of leveraging resources is public/
private partnerships to obtain the necessary resources to
achieve effective lead reduction.
SETTING PRIORITIES
o Lead-based paint and other lead sources are widespread, but
resources are limited. Monies for lead hazard reduction
must come from all available sources - federal, state, and
local governments; the private sector; communities; "sweat
equity" and so forth. Programs will succeed only to the
i0
extent they successfully marshall resources, establish
priorities, and make "common sense" investments and
commitments.
11
PRIMARY PREVENTION STRATEGIES Handbook
CONCEPTIONAL OUTLINE
SCREENING PRINCIPLES
1. SCREENING IS AN ESSENTIAL ELEMENT OF PRIMARY PREVENTION, EVEN
THOUGH STRICTLY SPEAKING IT FALLS OUTSIDE THE DEFINITION OF
"PRIMARY PREVENTION"
Oo Primary prevention means prevention of exposure to
lead. Secondary prevention means treatment of people
who have been poisoned by lead and prevention of
further exposure. Under these definitions, screening
is secondary prevention because its goal is to diagnose
cases of lead poisoning and provide a remedial
response.
Screening must be included in a lead prevention program
for the following reasons:
0 Screening data can help target areas for priority
lead hazard reduction.
0 Screening data can raise public consciousness of
the childhood lead poisoning problem and move
public policy toward establishment of comprehen-
sive childhood lead poisoning prevention programs.
0 Environmental intervention and lead hazard reduc-
tion triggered by screening can prevent future
cases of lead poisoning, both in the immediate
family circle, in future occupants, and in wider
geographical areas.
"Anticipatory guidance" must be made a routine part of
screening. A child's screening appointment should be
viewed as an opportunity for education of the family
about lead poisoning, its causes, preventive measures,
and existing programs and resources.
2. SCREENING MUST BE DIRECTLY RELATED TO LEAD HAZARD REDUCTION
IN A COMPREHENSIVE AND COORDINATED CHILDHOOD LEAD POISONING
PREVENTION PROGRAM
oO Past screening programs have sometimes amounted to
little more than medical "tracking" systems in which
diagnoses of childhood lead poisoning were repeatedly
and routinely confirmed. The link between screening
and lead hazard reduction is the key to incorporating
12
screening into an effective primary prevention program
and breaking the cycle of childhood lead poisoning in
the individual case management system.
Environmental intervention and lead hazard reduction
should take place in every case. Cases of lead
poisoned children should be traced "outward" to
friends, relative, and places visited where exposure
might have taken place. An appropriate level of lead
hazard reduction should be mandated and enforced in
every case where blood lead levels exceed CDC levels of
concern.
3. ANALYSIS MUST BE INTRINSIC TO THE SCREENING PROGRAM
Oo Analysis of screening data has three basic aspects:
o Surveillance (collection and collation of screen-
ing data on a routine basis).
o Reporting data back.
o Linking data to ongoing lead hazard reduction.
actions and activities.
Reporting of all screening data - whether from private
physicians or public programs =- should be legally man-
dated.
o The data should be reported to central reposi-
tories at the state and local levels and also
forwarded to CDC for surveillance programs.
0 Data from screening should be available in
accessible form to the community, as well as to
the persons affected. In addition, there should be
a state and national data base that incorporates
information generated by screening.
0 Laboratory reporting of screening data is
essential.
All negative results of blood lead level screening
should be reported as well as positive results. In
addition, the data reporting sheet should contain basic
information on the child tested, including area of
residence, age, sex, and ethnic identity.
Data collection and reporting systems should be compu-
terized and standardized.
I
0 Data collected by screening must be fed into the
inspection and lead hazard reduction components of a
comprehensive CLP prevention program on a systematic
basis.
0 Modern methods of statistical analysis should be
brought into play. Screening data should be correlated
with other data related to childhood lead poisoning
such as age and condition of housing stock, soil,
water, and ambient levels of lead in the vicinity, and
any known environmental problems such as hazard waste
sites.
4. UNIVERSAL SCREENING MUST BE MANDATED AS PART OF A PRIMARY
PREVENTION PROGRAM
0 All children 6 years old and under should be screened.
Mandatory screening should take place as detailed in
CDC guidelines. In addition to children 6 and under,
other priority categories of potential lead poisoning
victims should be tested. These categories would
include pregnant women and adults who are likely to
secondarily expose children (e.g., adults who bring
lead home in their work clothing).
o In screening, venous blood samples should be used
instead of EP (erythrocyte protoporphyrin) tests.
5. SCREENING SHOULD BE REQUIRED AT APPROPRIATE OPPORTUNITY
POINTS
o Screening should be required as a condition for entry
to kindergarten, pre-daycare, or daycare.
o Screening should be incorporated into a standard of
care that mandates screening at specified age intervals
recommended by CDC.
6. SCREENING SHOULD BE USER FRIENDLY AND PROVIDE SUPPORT AND
EDUCATION FOR PERSONS UNDERGOING SCREENING
0 Education about childhood lead poisoning and individual
counseling for lead poisoned children should be an
integral part of the screening process.
0 Health care insurers should be legally required to
reimburse health care providers for screening.
14
0 Outreach workers who do screening of families should
also give out information about other social programs
available and be alert to other social problems of the
families involved.
7. FOLLOW-UP SCREENING NEEDS TO BE DONE ON A SYSTEMATIC BASIS TO
CHECK THE EFFECTIVENESS OF LEAD HAZARD REDUCTION STEPS.
8. SCREENING SHOULD BE MESHED AND INTEGRATED WITH PRIVATE
MEDICAL CARE
0 Medical practitioners are the gatekeepers to health
care and source identification. There is currently a
lack of screening by private doctors.
0 Medical practitioners should be legally required to
screen children according to a universal screening
schedule.
o There is a great need for medical education and train-
ing concerning childhood lead poisoning.
9. EXISTING SCREENING PROGRAMS CAN BE USED AS A BASE OR
"BUILDING BLOCK" FOR MAKING THE TRANSITION TO PRIMARY PREVENTION
PROGRAMS
0 Coordination of data collection in ongoing screening
programs can define high risk areas for intensive
primary prevention activities.
0 Retraining of screening program personnel can effect
primary prevention strategies by learning how to
address low level toxicity and focusing on dust as the
primary transmittal agent for childhood lead poisoning.
10. LABORATORIES SHOULD BE SUBJECT TO STANDARDIZED REPORTING
REQUIREMENTS AND SHOULD BE REQUIRED TO SUBMIT A QUALITY
ASSURANCE/ QUALITY CONTROL PROTOCOL AND FOLLOW IT
o Third party testing should be discouraged. In cases of
third party testing, split samples should be taken and
a sample submitted to the public laboratory.
11. FURTHER RESEARCH IS NEEDED IN DEVELOPING DEVICES THAT MAKE
SCREENING EASIER, MORE EFFICIENT, AND LESS EXPENSIVE
15
o A portable testing device for screening should be a
priority for development.
ie
PRIMARY PREVENTION STRATEGIES HANDBOOK
CONCEPTIONAL OUTLINE
LEAD HAZARD REDUCTION
1. LEAD HAZARD REDUCTION IS THE LINCHPIN OF PRIMARY PREVENTION
AND ALL PROGRAM ELEMENTS MUST BE RELATED TO ACHIEVING IT
o The elements of the lead hazard reduction component of a
childhood lead poisoning prevention program include:
o Source identification
o Problem (hazard) definition
0 Lead hazard reduction
- Worker protection
- Proper disposal
0 Monitoring and clearance testing
0 Follow-up monitoring
o The core abatement and lead hazard reduction program
elements should be directly linked to all other program
elements. Links to screening and education are particularly
important.
oO Data from screening that indicates a high incidence of
CLP in particular areas or localities should be
correlated with housing stock (age, condition) and
environmental conditions (soil, air, water, hazardous
waste dumps) to serve as the trigger for systematic
surveys, inspections, and lead hazard reduction
activities.
Education should be regarded as active intervention and
in the broadest sense should range from information
distribution to actual training.
2. LEAD HAZARD REDUCTION ACTIVITIES SHOULD BE CONDUCTED
ACCORDING TO A PRIORITY-BASED SYSTEM THAT FACTORS DEGREE OF RISK,
EFFICIENT OPPORTUNITY, AND COST AND RESOURCES INTO ACCOUNT
®) The mere presence of lead-based paint (LBP) does not
always constitute an actionable hazard
The goal of a CLP prevention program should be a lead
safe house, not necessarily a lead free one.
Inspections and lead hazard reduction should take into
account the fact that LBP and dust are typically the
primary source of intensive lead exposures; however,
other sources can contribute to lead poisoning (such as
lead in soil, drinking water, ambient air, ceramics,
and secondary occupational exposures).
17
The most common cause of childhood lead poisoning is
the ingestion of dust that has been contaminated with
lead usually from lead-based paint.
The definition of what constitutes risk from lead-based
paint and other sources is critical to designing and
implementing a priority-based CLP prevention program.
3. ACTIVE INTERVENTION - EVEN IF IT FALLS SHORT OF COMPLETE
ABATEMENT - IS NECESSARY IN EVERY CASE OF ACTUAL OR POTENTIAL
CHILDHOOD LEAD POISONING
oO
The Intervention Criteria Chart at the end of this
section attempts to graphically depict the progression
of decision-making points and the criteria that lead to
lead hazard reduction decisions. The chart contains its
own explanation and illustrative guide to its use.
4. INSPECTIONS TO IDENTIFY LEAD HAZARDS IN HOUSING ARE A CRITI-
CAL COMPONENT OF PRIMARY PREVENTION STRATEGIES AND SHOULD BE THE
PRIMARY TRIGGER FOR LEAD HAZARD REDUCTION ACTIONS
(eo) Inspections play key roles in various stages of the
process (initial inspections, re-inspections, and post
abatement clearance inspections).
Lead hazard inspections should be made an integral part
of all municipal housing, health, and environmental
inspection programs.
Given limited resources, lead inspections should be
based on a priority system which favors units with high
generic risk factors, such as age and condition of
housing stock, the geographical concentration of lead
poisoning cases, and other relevant factors.
The identification of a child at significant risk
requires top priority action to identify the source or
sources of significant lead exposures (from various
media and various sites) and to eliminate such expo-
sures as soon as possible.
Every effort should be made to take advantage of oppor-
tunity points to achieve inspections, such as permits
for renovation projects, code violations and annual
inspections for subsidy programs and occupancy permits.
Change of ownership and change of tenancy provide
special opportunities for complete inspection and
effective lead hazard reduction.
At a bare minimum, inspections should always include an
assessment of bioavailable lead based on surface dust-
wipe samples, as well as visual inspection for
deteriorated interior and exterior painted surfaces,
18
with special attention to abradable surfaces such as
windows.
Based on knowledge of background risk factors and the
findings of the site examination, additional tests of
bioavailable lead in exposed paint, soil, drinking
water and other media should be conducted.
When triggered by appropriate circumstances (either
environmental risk factors or points of opportunity,
such as housing transactions and permits), full inspec-
tions should be conducted.
In addition to the components of a "basic inspection,"
full lead hazard inspections should include reference
to historical inspection information, other inspections
and code violations, and tests to identify the presence
of lead in paint and other media.
An integral part of the inspection program is a system
for assuring the accuracy and validity of laboratory
and other tests.
Inspectors need to be licensed and free of conflicts of
interest with cleanup contractors.
S. 2A PRIORITY-BASED SYSTEM OF INSPECTION AND LEAD HAZARD
REDUCTION REQUIRES A HIERARCHY OF RESPONSE
Oo The term "abatement" should be used to describe
measures that permanently eliminate human exposures to
specified sources of lead. Interim measures (variously
called "preventive maintenance"; "in-place management";
and interim containment”) include those steps short of
abatement that effectively control or stabilize the
situation to reduce lead exposures to acceptable levels
in the short to mid-term.
Because steps to reduce lead exposures differ as a
function of circumstances and resources, the term "lead
hazard reduction" should be used as a general descrip-
tion for all cleanup efforts.
Measures to address lead hazards may take a variety of
forms depending on the circumstances. The response may
range from interim risk reduction steps to abatement.
The primary objective of lead hazard reduction efforts
is to reduce lead dust on surfaces and to eliminate the
sources of lead in such dust.
In general, interim measures should include the
provision of smooth and cleanable surfaces.
19
Interim measures must never be considered permanent
solutions.
The appropriate method of lead hazard reduction should
be commensurate with the hazard.
In cases is which interim measures are employed,
periodic ongoing monitoring must be required as an
integral part of the intervention.
Some situations will present levels of risk significant
enough to require immediate abatement, instead of
interim measures.
The concentration of lead in paint is only one factor
in assessing lead paint hazards: the condition,
accessibility, and potential for disturbance or damage
of lead painted surfaces, are the other controlling
criteria. :
To the extent practicable, the selection of abatement
techniques should minimize the generation of lead dust.
Abatement/interim measure specifications and project
design should take into account cleanability, energy
conservation, long term maintenance, and increase in
building value. Cost calculation should be done on the
bases of life cycle costing.
6. TRAINING AND CERTIFICATION ARE ESSENTIAL AND SHOULD BE
MANDATED FOR EVERYONE ENGAGED IN LBP ABATEMENT
o Lead hazard abatement activities are usually complex
and inherently dangerous. Efforts to abate lead paint
hazards without proper methods and training often
exacerbate, rather than alleviate, the problem.
Everyone engaged in LBP hazard abatement projects must
at all times wear proper protective equipment, includ-
ing a respirator.
A cleanup using HEPA vacuums and trisodium phosphate
(TSP) washes must be conducted as part of every LBP
abatement project.
A LBP hazard abatement project is not complete until
the work site is inspected and passes a post-abatement
clearance test.
Occupants of homes undergoing significant abatement
activities should be relocated until the home is found
to be lead-safe through post-abatement clearance test-
ing.
0 The provision of relocation housing is an integral part
of a comprehensive lead hazard reduction program.
o Anyone -- contractors, supervisors, workers, property
owners, occupants, etc. -- who undertakes lead hazard
reduction activities must be adequately trained and
certified. This training should include at least:
identifying lead hazards; worker protection; occupant
habits and protection; abatement techniques, materials
and procedures.
8. THE SUCCESS OF ANY CLP PREVENTION PROGRAM IS CONTINGENT ON
THE EXISTENCE AND EFFECTIVENESS OF THE DELIVERY SYSTEMS
0 Regulations, funding, resources and education programs are
futile if there are not delivery systems in place that are
appropriate to specific populations and needs.
o The delivery mechanism should be as decentralized as
possible. At the same time economies of scale make it
logical to centralize some program components, e.g., testing
laboratories, shared purchasing, expensive equipment, and
training facilities.
0 Following are some specific examples of delivery sys-
tems:
- Neighborhood-based maintenance projects
- Consortium structure
- Agency inspectors
- Municipal clean-up crews
- Private inspectors and contractors
- Specialized crews
el
PURPOSE: This chart is an instrument DRAFT: This chart is a first draft. It is on computer
for focusing a discussion about lead intervention; disk so changes can be made for a particular program or place.
planning a program; for a particular house, an For changes call or write Alex G. Mendoza, 3104 Grindon Ave.,
institution or a focused program. Baltimore, MD 21214. (301) 426-3671. There will be a small fee
for these changes.
INTERVENTION CRITERIA CHART
EDUCATION
Circle which tests will be
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EDUCATION PROGRAMS APPLICATION PROCESS MONITORING PROGRAM
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“PERMANENT” MATERIALPLUS 2 & 1.
«= THRESHOLD
HEPA-VAC / PHOSPHATE WASH ALL SURFACES, WET SCRAPE,
PAINT ALL FLAKING PAINT.
ALLIANCE To END CHILDHOOD LEAD POISONING
PRIMARY PREVENTION STRATEGIES HANDBOOK
CONCEPTUAL OUTLINE
1.
RESOURCES
THE PROVISION OF RESOURCES FOR LEAD HAZARD REDUCTION IS AN
ESSENTIAL PART OF A COMPREHENSIVE CHILDHOOD LEAD POISONING
PREVENTION PROGRAM
Oo
2.
In order to achieve lead hazard reduction all appropriate
financial, human, organizational, and social resources must
be marshalled.
A comprehensive program should link LBP education and abate-
ment to other more broadly recognized programs and goals--
such as low-income housing development, job training, neigh-
borhood revitalization, and social investment policies.
PROVISON OF RESOURCES FOR LEAD HAZARD REDUCTION RESTS ON A
FOUNDATION OF STATUTORY REQUIREMENTS, REGULATORY STANDARDS, AND
PROGRAM GUIDELINES
Oo A comprehensive lead law and regulations should serve as the
backdrop for all lead poisoning prevention activities:
childhood lead screening, property inspection, assignment of
liability, and initiatives to secure abatement funding. The
regulatory regime should include requirements directly
related to resources such as licensing and training require-
ments for inspectors and abatement contractors.
Standards and requirements need to be spelled out before
property owners, lenders, insurance companies, realtors, or
other private housing sector actors take positive steps
toward lead inspection and abatement. Articulated require-
ments provide some basis for certainity and action. In
addition, mandated lead hazard reduction and abatement
serves as the fundamental incentive for marshalling resourc-
es -- especially private resources -- to achieve lead abate-
ment.
0 Authorizing legislation for CLP prevention programs
should include incentives for public/private partner-
ships and public sector participation in lead abate-
ment.
22
3. STATE AND LOCAL LEAD POISONING PREVENTION PROGRAMS SHOULD BE
BUILT UPON EXISTING CAPACITY IN THE PUBLIC AND PRIVATE SECTORS
o There is substantial public sector capacity in many states
and localities. The following are examples of public sector
capacity.
Oo
Incorporating IBP policies into financial assistance
and code enforcement programs. Many public agencies --
particularly at the local level-- have operating resi-
dential loan and grant programs and code enforcement
efforts. There are at least three ways in which LBP-
related issues can be integrated into government pro-
grams: (1) providing information to homebuyers, land-
lords, residents, and contractors on LBP hazards and
legal requirements; (2) requiring LBP testing and
abatement as a condition of obtaining financial assis-
tance, direct services, or permits; and (3) providing
incentives for abatement -- for example, making abate-
ment an eligible activity of a loan or grant program,
providing direct inspection services, and supervising
abatement work.
Role of state and local HFA's. State and local housing
finance authorities can issue tax-exempt (and, in some
cases, taxable) bonds, the proceeds of which could be
used to purchase below-market interest loans originated
by private lenders. HFA's could make LBP abatement an
eligible activity in a home improvement or acquisition-
rehabilitation loan. Furthermore, HFA's and other
agencies which subsidize housing development and home-
ownership could require LBP testing and abatement as a
condition of assistance.
Dedicated revenues. Certain non-traditional methods of
financing could be made accessible to lead abatement.
Such sources include transaction fees, idle public
funds and bond reserves, and escrow funds. Another
potential dedicated revenue source would be state taxes
on the lead industry or the use of lead.
Other incentives for LBP abatement. Local governments
could provide other financial and technical support to
encourage abatement and the development of a private
industry -- for example: tax breaks, fee forgiveness,
priority use of Community Development Block Grants, and
direction of employment/job training programs to LBP-
related trade. Local public housing authorities
(PHA's) could target Family Self Sufficiency programs
(using rental assistance) to employment training in
LBP-related trades -- as a means of developing a labor
force and achieving economic empowerment goals.
23
4.
There is a need for private sector capacity to undertake LBP
inspections and abatement. To accomplish the volume of LBP
abatement finance and work needed, a private sector industry
must emerge. Furthermore, other actors in the housing world
need to be familiar with LBP-related issues--for example,
lenders, realtors, insurance firms, property appraisers, and
property managers. The following are examples of how
private sector capacity can be built and utilized.
0 Private lenders. There may be some self-interest in
lenders making abatement loans: prevention of
liability in the case of properties which fall into
delinquency, conservatorship, or lender ownership
through foreclosure.
o Creating a private inspection and abatement industry.
There is too much housing with LBP for governmental
agencies to inspect and perform abatement directly in
all units. Every community has small and medium-sized
businesses that when properly trained and certified
could perform inspection and abatement services.
0 Reinsurance. As a backstop to private insurance
companies, the government could establish a reinsurance
or insurance guarantee fund.
o Community Reinvestment Act. State governments could
amend their banking laws to place financing for LBP
abatement among eligible activities that count toward a
lender's community reinvestment goals. Regulatory
agencies could require lenders to keep records of
abatement financing activity.
LEAD-RELATED ISSUES SHOULD BE INTEGRATED IN NORMAL HOUSING
TRANSACTIONS
Oo There are many decision points in housing transactions.
They provide opportunities for addressing lead hazards.
Examples of housing transaction decision points are:
property inspections, loan applications, property transfers,
permit applications, and leasing.
Most housing transactions involve private sector actors--
lenders, insurance companies, appraisers, and realtors.
Advocates or public officials could seek voluntary
agreements with these private sector actors to incorporate
LBP education and abatement work into housing transactions.
Alternatively, and perhaps more effectively, public policies
could be formulated that require the incorporation of LBP-
related aspects in housing transactions, including:
24
S.
0 Marketing. Real estate agencies could provide LBP
information to potential homebuyers and renters. In
certain rental markets, it may be an effective strategy
to advertise available units as "lead safe" or having a
certificate of compliance.
0 Purchase and sales agreements. Such agreements could
contain a clause making the sale contingent on the
results of an LBP inspection.
0 Lending. Private lenders could provide consumer
information on the risks of lead exposure and a
description of how their available loan financing
might be used for abatement.
0 Appraisal. Property value appraisers could develop
standards for distinguishing properties with and
without hazardous lead conditions.
COMMUNITY RESOURCES MUST BE ENLISTED TO STRENGTHEN CHILDHOOD
LEAD POISONING PREVENTION PROGRAMS
Oo
6.
Community-based resources should be enlisted in the effort
to obtain concerted governmental action on LBP or to
encourage private sector institutions to help finance
abatement. For example, there are still approximately 2,000
community action agencies based in localities and
neighborhoods. In addition, community outreach programs
should include the encouragement and development of
community resources for lead hazard reduction.
THE EDUCATION/COMMUNITY OUTREACH COMPONENT OF A CLP PRIMARY
PREVENTION PROGRAM SHOULD INCLUDE RAISING CONSUMER CONSCIOUSNESS
oO Raising consumer consciousness is an important part of
securing the commitment of public officials and private
lending institutions to provide and increase abatement
resources in the public and private sectors and for the
development of delivery systems and community-based programs
to achieve lead hazard reduction generally.
o Homeowners, renters, and investment property owners may
actively seek public and private resources for lead
abatement once they appreciate the dangers of childhood
lead poisoning. Consumer consciousness is an essential
element of making the market value a lead abated home.
Private sector institutions --like banks-- may be
inclined to provide financing for abatement if they
become aware of sufficient consumer demand.
25
7. THE ECONOMIC BENEFITS OF ABATEMENT SHOULD BE PROGRAMMATICALLY
TIED INTO THE BROADER POSITIVE VALUES OF LEAD HAZARD REDUCTION
SUCH AS ENERGY EFFICIENCY AND HOME IMPROVEMENT.
o The economic value of lead hazard reduction is emphasized
when abatement activities include a replacement of
substandard or energy inefficient windows, doors, or other
painted surfaces and other home improvement steps and
procedures.
26
PRIMARY PREVENTION STRATEGIES HANDBOOK
CONCEPTUAL OUTLINE
LEGISLATION
1. CHILDHOOD LEAD POISONING PROGRAMS MUST BE BASED ON MANDATES
CONTAINED IN LEGISLATION
o Even though there have been examples of successful CLP
programs at the local level established absent any legisla-
tion and even though mere enactment of legislation does not
guarantee its effective implementation, statutory require-
ments that mandate the development and implementation of a
comprehensive childhood lead poisoning prevention program
are the best guarantees for the continued effectiveness of
CLP prevention efforts.
2. CLP PREVENTION LEGISLATION MUST IDENTIFY THE ESSENTIAL
ELEMENTS OF A PRIMARY PREVENTION STRATEGY AND MANDATE THEIR
INTEGRATED IMPLEMENTATION
o CLP prevention legislation should explicitly identify all
elements of a primary prevention-based childhood lead poi-
soning program and should mandate that they operate together
in an effective and integrated manner. In effect, the law
should institutionalize the interdisciplinary approach
necessary to solve CLP.
o The law should take into account existing programs and,
where necessary, provide the basis for augmenting and "up-
grading" them into genuine primary prevention programs.
3. THE CLP PREVENTION LAW SHOULD BE ENACTED AT THE STATE LEVEL
o The CLP law should be promulgated at the state level in
order to establish a minimum uniformity of CLP prevention
program requirements at the local level and to retain a
supervisory role at the state level.
o The law of the supervisory role of the state is espe-
cially important in such areas as laboratory certifica-
tion.
27
* The reader is referred to the State Model Law, also enclosed
as a comment draft in this envelope, for an example of
legislation mandating a CLP prevention program.
28
The state law should generally preempt less stringent
requirements at the local level. At the same time, it
should retain the authority of existing departments and
inspectors.
4. THE LAW SHOULD ESTABLISH A FUND TO BE USED IN FINANCING
ACTIVITIES RELATED TO THE CLP PREVENTION PROGRAM EFFORT AND LEAD
HAZARD REDUCTION
The law should provide an opportunity for establishing a
special fund into which identified sources of money should
go, including fines and mandatory fees for screening and
training and certification. Monies from the fund should be
dedicated to providing CLP prevention program support.
5S. THE LAW SHOULD INCLUDE FULL INSPECTION AND ENFORCEMENT
PROVISIONS
o The law should take a "carrot and stick" approach that
includes mandatory requirements, as well as incentives to
achieve lead hazard reduction.
6. THE LAW SHOULD ALSO INCLUDE INCENTIVE PROGRAMS FOR ENGAGING
THE PRIVATE SECTOR AND MARKET FORCES IN FINANCING AND EFFECTING
LEAD HAZARD REDUCTION
o Some examples of incentive programs that could be incorpo-
rated into legislation are given in the Resource chapter,
above.
THE LAW SHOULD PROVIDE FOR MANDATORY EDUCATION AND COMMUNITY
OUTREACH AS AN INTEGRAL PART OF A PRIMARY PREVENTION PROGRAM
o Public awareness and community participation is the driving
force behind the establishment, continuation, and effective-
ness of CLP prevention programs.
PRIMARY PREVENTION STRATEGIES HANDBOOK
CONCEPTUAL OUTLINE
EDUCATION/COMMUNITY OUIREACH
1. EDUCATION/COMMUNITY OUTREACH IS AN ESSENTIAL ELEMENT OF A
COMPREHENSIVE CLP PREVENTION PROGRAM
2. ONE OF EDUCATION'S PRIME ROLES IS TO BREAK MYTHS THAT IMPEDE
EFFECTIVE SOLUTIONS TO CLP
o Among the myths that must be broken are:
o that the victim is to blame for being poisoned.
0 that only poor minority children living in
dilapidated housing become poisoned.
o that it is one agency's or one program's sole
responsibility to solve the lead issue.
3. CLP EDUCATION MUST TAKE DIFFERENT FORMS FOR DIFFERENT
AUDIENCES IN DIFFERENT SITUATIONS
0 Education must be presented in many modalities, visual,
written, or auditory, in order to be effective.
0 Education must be geared to the level of literacy
and characteristic modes of receiving information
for each target audience. Conversely, education
material should not condensend by assuming a lower
level of literacy and comprehension within a given
community or group than is warranted.
o Education and educational materials must be multi-
cultural and sensitive to the educational background,
values and styles of the community and cultures within
a community because no culture is monolithic.
o Examples of modes and materials of community
education include:
- Material development
Flyers
- Handouts
- Principles of making handouts
- Video
- Journal articles
30
White papers
Conference proceedings
4. CLP EDUCATION MUST BE POSITIVE AND AIMED AT DEFINING A
HEALTHY COMMUNITY, I.E. HOW A LEAD-FREE SOCIETY LOOKS AND
RESPONDS
0 The issue of poverty, racism, and inequality in
exposure to toxics should be raised and discussed.
5. EDUCATION SHOULD NOT BE DIDACTIC, BUT RATHER SHOULD HELP
FOSTER COMMUNITY AND INDIVIDUAL SELF~SUFFICIENCY AND INVOLVE
PEOPLE IN MAKING DECISIONS THAT AFFECT THEIR LIVES
0 All people who are at-risk of lead poisoning should
receive materials and programs as part of an active
intervention program to prevent CLP.
6. THE CLP PREVENTION AGENCY SHOULD USE ITS EXPERTISE AND
RESOURCES TO EDUCATE THE PUBLIC ABOUT CLP
0 An agency-sponsored public information campaign to
increase citizen awareness and catalyze citizen action
about CLP prevention should include the following
elements.
o The health dangers of lead poisoning, including
- Risk communication concerning the actual
hazard presented by lead in different
situations
How to protect self and children from lead (during
pregnancy, childhood, and work)
How to pay for screening and treatment (gaining
access to public programs to support lead
poisoning prevention)
Information about lead hazard reduction:
What is lead hazard reduction and what are
the applicable techniques
What programs for abatement training and
certification are offered by state and local
government
How to choose and evaluate an abatement
contractor
51
0 Description of sources of lead in the home and
neighborhood and region
o Explanation of federal, state and local laws and
regulations on lead
0 Citizen's rights (e.g., entitlements, tort claims,
citizen's suits)
0 Tenant's rights
o Descriptions of ways to coordinate efforts with
housing groups and methods of linking agencies
such as housing, environment, health, human
services, education, universities, and advocacy
organizations
0 Information about CLP and its prevention should be
institutionalized into school curricula:
lo] An awareness campaign in the schools
o A curriculum review of materials and curriculum K-
12
0 Adult training, continuing education courses,
college and university courses.
o Screening programs, especially those in higher risk
neighborhoods should be conducted in concert with
public education campaigns.
0 CLP education programs should include neighborhood
outreach in the form of:
o Presentations/lectures
0 Forums /meetings
0 White papers/policy roundtables
o Projects
0 Conferences/fairs
0 An agency should initiate a process to identify which
communities to enter with educational materials and
programs.
0 The interagency group or agency should develop
criteria for choosing which communities will be
entered.
o The group or agency should develop a community
profile and define the nature of the community's
needs.
32
Educational resources within a community should be
determined through a needs assessment and
community profile.
An educational plan and educational style should
be tailored to fit the community profile.
An implementation plan should be prepared that
provides educational support for the community and
an active role for the community in CLP
prevention.
The education plan should be evaluated by both the
community and the interagency task force.
A protocol should be developed for entering a community
to establish a community-based CLP prevention program.
Technical assistance should be provided to communities
upon request.
Coordinated in-service training should be conducted for
outreach workers and program people in housing, youth
and family services.
Community outreach workers should be hired and trained
from communities at risk.
oO The outreach worker should serve as the basic
access point for information about all available
social programs and should be the "point person"
for a program's educational efforts.
0 The outreach worker should be role oriented
instead of task oriented and trained in
communication and advocacy.
33