Reports, Contacts, and Guidelines for Lead Poisoning Alliance

    ~4/ 
ALLIANCE TO END CHILDHOOD LEAD POISONING 

January 17, 1991 

Address 

City 

Dear 

Lead poisoning is a nationwide epidemic that affects one out of every six 
children. For 20 years, the federal response has been denial. Yet the 
next few months could prove critical in whether the government finally 

takes a leading role in eradicating this debilitating hazard. 

We want to alert you to several upcoming events of tremendous importance. 

The Alliance is a new national public interest organization dedicated 

exclusively to ending childhood lead poisoning. Our board of directors 
are leading experts on lead poisoning prevention. The enclosed brochure 
provides more information about our objectives. These are some of the 
critical initiatives in lead poisoning: 

o Last month, the Department of Housing and Urban Development pre- 
sented its plan to Congress for cleaning up lead paint in America's 
homes--3.8 million homes are identified as priority hazards. 

o In the next two months, the Department of Health and Human Services 
will release its strategic plan for ending lead poisoning through a 
a national abatement program. This plan marks a major change in 

HHS's priorities. 

o Later this spring, the Centers for Disease Control is expected to 
change its threshold for childhood lead poisoning, which will 
result in a ten-fold increase in the number of children recognized 
as lead poisoned -- one out of every six children nationwide. 

0 The city of Philadelphia has recently filed a class action lawsuit 
against the producers of lead-based paint, seeking billions of 
dollars for cleanup on behalf of all large U.S. cities. This 
January, public interest lawyers filed suit against the state of 
California to force screening for lead poisoning of all children in 
the Medicaid program. 

Although lead poisoning is the number one environmental health hazard and 
preventable disease in children, next to nothing has been done to prevent 
it over the past two decades. The enclosed December 20 New York Times 
article's salute to a new federal policy to wipe out lead poisoning is, 

in fact, somewhat premature. Although the dimensions of the problem have 
finally been acknowledged, the federal government has not yet committed 
any funds for the expected multi-billion dollar costs. 

  

It is vital that the government provide funds to combat this disease. And 
it is vital to educate the public about devastating consequences of lead 
poisoning. Please consider the Alliance as a resource in your lead 
poisoning articles. I would be happy to answer any questions and provide 
you with other background materials. 

® 600 Pennsyhanio Avenue, SE 9 Sule 100 ® Washington, D.C 20003 ¢ 202-543-1147 ® FAX 202-543-4466 

 



LEAD POISONING 

CONTACT: 

Don Ryan 
Executive Director 
Alliance to End 
Childhood Lead Poisoning 

Office Phone: 202-543-1147 

Herbert L. Needleman, M.D. 

University of Pittsburgh 

Western Psychiatric Institute 

and Clinic 

Office Phone: 412-624-0877 

John Rosen, M.D. 

Professor of Pediatrics, Albert 

Einstein College of Medicine 

Montefiore Medical Center 

Office Phone: 212-920-5017 

Ellen Silbergeld, Ph.D. 
Toxicology Department 
University of Maryland 
Office Phone: 301-328-8196 

Stephanie Pollack, Esq. 
Attorney at Law 
Conservation Law Foundation 
Office Phone: 617-742-2540 

Philip Landrigan, M.D. 
Director, Environment and 

Occupational Medicine 
Mt. Sinai Medical Center 
Office Phone: 212-241-4804 

Bailus Walker, Jr., Ph.D. 

Dean 
College of Public Health 
University of Oklahoma 
Office Phone: 405-271-2232 

PREVENTION CONTACTS 

EXPERTISE: 

Federal policy and programs, 
inter-agency coordination, 
Congressional action. 

Pioneering researcher and 
national expert on effects 
of low level lead poisoning. 
Chairman of the Alliance's 
Board. 

Chairman of CDC's expert 
Advisory Committee on 
childhood Lead Poisoning 
Prevention, which is 
revising the threshold and 

guidelines. 

Leading toxicologist, re- 
searcher and environmental 

health advocate. Director 
of the Environmental Defense 
Fund's Toxics Program. 
Co-author of Legacy of Lead. 
  

Director of CLF's Lead 
Poisoning project and author 
of the landmark lead poison- 
ing prevention legislation in 
Massachusetts. 

Occupational and environ- 
mental health effects. 

Chair of the National 
Academy of Sciences' 
Task Force on Pesticides 
and Children's diets. 

Prominent health educator 
and administrator: past 
director of Public Health 
Departments in Washington, 
D.C. and the state of MA.  



Richard J. 
Chairman 
Hazard Evaluation Section 
California Department of Health 
Office Phone: 415-540-2658 

Jackson, M.D. 

Henry Falk, M.D., M.P.H. 
Director 
Division of Environmental Hazards 
& Health Effects 

Center for Disease Control 
Office Phone: 404-488-4772 

Barry Johnson, Ph.D. 
Assistant Administrator 
Agency for Toxic Substances 

and Disease Registry (ATSDR) 
Office Phone: 404-639-0700 

Arthur Bryant 
Executive Director 
Trial Lawyers for Public 
Justice 
Office Phone: 202-797-8600 

Joel Schwartz, Ph.D. 

U.S. EPA Office of Policy 
Phone: 202-382-2784 

Karen Florini 
Senior Attorney 
Environmental Defense Fund 
Office Phone: 202-387-3500 

Brad Prenney 
Director 
Childhood Lead Poisoning 
Prevention Program 
MA Department of Public Health 
Office Phone: 617-522-3700 x175 

Jane Perkins 

National Health Law Project 
Office Phone: 213-204-6010 

Chairman of the American 
Academy of Pediatric's 
Environmental Hazards 
Committee. 

CDC Division Director 
responsible for lead 
poisoning prevention, 
including state and local 
grants and development of 
HHS strategic plan. 

on ATSDR 

congress: 
Contact person 
1988 report to 
The Nature and Extent of 

Lead Poisoning in Children 
in the United States. 

  

  

  

Information on lead poisoning 
litigation and national class 
class action lawsuit in the city 
of Philadelphia. 

Epidemiologist and economist. 
Research on lead health effects 
and cost/benefit analysis. 

Federal legislation, regu- 
latory policy, co-author of 
EDF's March 1988 Legacy of 
Lead report and $1 B/year 
trust fund proposal. 

  

Director of Massachusetts' 
aggressive and successful 
lead poisoning prevention 
program. 

Litigation to require lead 
poisoning screening of children 
by Medicaid and California class 
action lawsuit.  



  

Contact: Don Ryan 

Executive Director 

202 543-1147 

QUESTIONS AND ANSWERS ABOUT LEAD POISONING 

Why worry about lead? Lead is a powerful neurotoxin. At high 

levels lead causes coma, convulsions and even death. At low 

levels it affects the central nervous system and brain develop- 

ment. For this reason, children under age six are at greatest 

danger. 

What are the symptoms? Children with low levels of lead poison- 

ing do not have clear, easily identifiable symptoms. Usually, a 

child's blood must be tested to diagnose the disease. 

What does lead poisoning do to children? Although the outward 

signs may be subtle, the effects of lead poisoning are devastat- 

ing and may be irreversible: mental retardation, reduced IQ, 

reading and learning disabilities, hyperactivity, impaired 

growth, hearing loss, reduced attention span and behavior prob- 

lems. 

How many children are affected? According to federal government 

reports, 17 percent of U. S. children have neurotoxic levels of 

lead in their bodies. That translates into one child out of 

every six -- over three million children nationwide under the age 

of six. Childhood lead poisoning is a silent epidemic. 

What is the major cause of childhood lead poisoning? The over- 

whelming cause is lead-based paint and dust from lead-based paint 

in homes. Other sources of lead are drinking water, food, soil, 

outside air, hobbies and lead brought home from the workplace. 

Isn't this a disease of the poor? The stereotype that lead 

poisoning just hits poor, inner city (and usually minority) 

children is absolutely wrong. Yes, the highest rates are in 

poor, inner city neighborhoods (well over 50 percent of children 

in many areas). But lead poisoning affects children of every 

socioeconomic status. For example, the prevalence rate for white 

children outside of central cities is more than seven percent. 

How does childhood lead poisoning compare to other environmental 

health problems? Lead poisoning is the foremost preventable 

disease of childhood. And, according to the Centers for Disease 

Control, it is the number one environmental problem facing 

American children. The adverse effects of lead poisoning abso- 

lutely eclipse the risks of asbestos in buildings, for example. 

Aren't children being tested? The Centers for Disease Control 

recommends that all children be tested for lead poisoning. Yet, 

 



  

nine out of ten children are never screened. As a result, the 

vast majority of lead poisoning cases are never identified or 

treated. 

What should parents do to get their child tested? They should 

insist that their pediatrician or family physician test the child 

beginning at age 12 months. They may also call their local 

health department or visit a community health clinic. It is 

important that the test be a blood lead test and that parents be 

told the actual number (not just positive or negative). Another 

test in wide use, the EP test, is not sensitive enough to detect 

most lead poisonings. 

How is "lead poisoning" defined? Over the past 20 years, lead's 

adverse effects on children's neurological development have been 

recognized at lower and lower levels. Between 1971 and 1985, the 

blood lead threshold has been steadily reduced from 40 micrograms 

per deciliter (ug/dl) to 25 ug/dl. Based on new research, the 

Centers for Disease Control (CDC) will soon be changing the level 

to 10 ug/dl. 

How is lead poisoning treated? In cases of high lead poisoning 

(usually above 35-40 ug/dl) children are give chelation therapy, 

a costly procedure which usually requires hospitalization. At 

lower levels the only treatment is to eliminate or reduce the 

source of the child's lead exposure. The only real answer is 

prevention--removing lead from homes before children are poi- 

soned. 

Are the effects of lead poisoning permanent? Childhood lead 

poisoning can definitely affect learning capabilities and perfor- 

mance later in life. In an 1ll-year study, poisoned children had 

seven times higher school failure rates and were six times more 

likely to have reading disabilities than non-affected children. 

Is there a connection with "Why Johnny can't read?" Without a 

doubt, lead is one of the root problems underlying illiteracy, 

school failure and many of our educational system's maladies. 

Lead poisoning affects intelligence, reading, learning, vocabu- 

lary, and performance later in life. 

Is there still scientific debate over the hazards? We know more 

about lead's health effects than any other toxin. These risks 

are not theoretical--lead's adverse effects have been observed at 

low levels and confirmed in laboratory, clinical and epidemio- 

logical studies. The overwhelming consensus of researchers, 

scientists and federal agencies is that blood lead levels above 

10 ug/dl present a clear hazard to children. 

Are fetuses also at risk? Yes, because lead in the mother's 

blood crosses the placenta. Prenatal exposures result in low 

birth weights, early term deliveries, and lower subsequent IQ 

scores. According to a federal government report, each year a 

staggering 400,000 babies are born with neurotoxic lead levels. 

 



Didn't we take lead out of paint? At the direction of the 

Congress, lead was regulated in residential paint in 1972 and 

banned (to trace amounts) in 1978. Although some industrial and 

marine paints are still made with lead, the real problem is lead 

in homes built before the 1970's. Some older homes have paint 

which contains as much as 50 percent lead. 

Why do children eat lead paint chips? The idea that children 

have to eat paint chips to be poisoned is absolutely wrong. Some 

children do eat paint chips--leaded paint can have a bittersweet 

taste. But invisible lead dust from paint is just as great a 

hazard to children. Lead dust, invisible, sticky and difficult 

to clean up, is picked up on children's hands and ingested. 

what about lead in drinking water? Besides lead paint, there are 

many other sources of lead. Drinking water may have high lead 

levels due to lead pipes or lead solder in copper pipes. Infants 

on formula mixed with tap water are at risk. But the major cause 

of most childhood lead poisonings is lead-based paint and dust. 

Does my house have lead paint? Lead-based paint is found equally 

in homes of the rich and poor. If your home was built before 

1978, the chances are about 50-50 that it has some interior lead 

paint. The prevalence of lead paint is even higher in homes 

built before 1950. About three million U. S. homes have chipping 

and peeling lead paint causing immediate hazards. 

If I have lead-based paint at home, should I scrape it off? If 

the leaded paint is in good condition and has been painted over 

with lead-free paint, it should be left alone for now. Removing 

lead paint can generate large amounts of lead dust, aggravating 

problems and endangering workers and children. 

Can I rely on my contractor to take care of peeling lead paint? 

Probably not. Most contractors have not had the special training 

required and are unaware of the hazards and proper removal 

methods. Many contractors still remove leaded paint with open 

flame torches and electric sanders--practices which are strictly 

prohibited by federal guidelines. When a home is being deleaded, 

the family should move out temporarily. 

Doesn't deleading a house cost a lot? Yes. Depending on the 

amount of lead, the job may well cost $5,000 or more. Banks and 

mortgage companies are beginning to recognize the increased value 

of deleaded homes. Subsidies will also have to be provided to 

help many low-income families remove the lead from their homes. 

Can we afford to delead homes on a nationwide basis? We cannot 

afford not to. The health and education benefits far outweigh 

the costs of cleanup. Beyond that, deleading programs can 

provide jobs, train workers, provide decent housing and strength- 

en neighborhoods. Remember, childhood lead poisoning is com- 

pletely preventable.  



NOTABLE QUOTES 

"We believe that lead poisoning is the No. 1 environmental problem 

facing America's children. Therefore, it will take a major societal 

effort to eliminate it." New York Times, 12/20/90, pg. 1 
Dr. William Roper, Director 
Centers for Disease Control 

  

"The Government's record in dealing with this problem is one of 

absolute dereliction." New York Times, 8/26/90 

Dr. Herbert L. Needleman 
University of Pittsburgh 
Leading expert on effects of low-level lead exposure 

  

"Without question, the amount of lead poisoning in our society has 

been a disgrace. It is about time we set our priorities that will 

insure protection of American children." New York Times, 12/20/90, 

Pg. 1 

  

John Rosen, M.D. 

Montefiore Medical Center 

Chairman of CDC's Expert Advisory Committee 

"The problem is so well defined, so neatly packaged, with both causes 

and cures known, that if we don't eliminate this social crime, our 

society deserves all the disasters that have been forecast for. it." 

Rene Dubos, 1965 

Philosopher, Environmentalist 

"When we talk about pesticides or asbestos, we use risk assessment 

models that discuss some statistical chance--one in a million, say-- 

that someone might be harmed. With lead, we know that about one out 

of every six children is already suffering. In some places we even 

have their names and addresses. New York Times, 8/26/90 

Don Ryan, Executive Director 
Alliance to End Childhood Lead Poisoning 

  

"In terms of both quantitative impact and persistence of the hazard, 

as well as dispersal of the source into the population, leaded paint 

has been and remains the major source for childhood exposure and 

intoxication." 
U. S. Agency for Toxic Substances and Disease Registry 

(ATSDR), July 1988 Report to Congress, p. VI-54. 

"As a pervasive toxicant, lead is shown in this report (ATSDR, 1988) 

to affect totals of. children that are high in all socioeconomic/ 

demographic strata. 
ATSDR July 1988 Report to Congress, p. 16. 

"There is no correlation between the incidence of lead-based paint 

and the income of the household. Lead-based paint is found as often 

in the homes of the well-to-do as the poor." 

U. S. Department of Housing and Urban Development, 

December 1990 Report to Congress, p. xviii.  



LEGACY OF LEAD: 
AMERICA'S CONTINUING EPIDEMIC 

  

OF 
~ CHILDHOOD LEAD POISONING 

Table A-3. Estimated total number of children 6 months to 5 years who are projected to exceed selected 

blood lead levels for individual SMSAs with populations over 1 million. 

  

  

SMSA 

Anaheim-Santa Ana-Garden Grove, CA 

Atlanta, GA 

Baltimore, MD 

Boston, MA 
Buffalo, NY 

Chicago, IL 

Cincinnati, OH-KY-IN 

Cleveland, OH 

Columbus, OH 

Dallas-Fort Worth, TX 

Denver-Boulder, CO 

Detroit, MI 

Fort Lauderdale-Hollywood, FL 
Houston, TX : 
Indianapolis, IN 

Kansas City, MO-KS 

Los Angeles-Long Beach, CA 

Miami, FL 

Milwaukee, WI 

Minneapolis- St. Paul, MN-WI 

Nassau-Suffolk, NY 

New Orleans, LA 

New York, N.Y-NJ 

Newark, NJ 
Philadelphia, PA-NJ 

Phoenix, AZ 

Pittsburgh, PA 

Portland, OR-WA 

Riverside-San Bernardino-Ontario, CA 

Sacremento, CA 

St. Louis, MO-IL 
San Antonio, TX 

. San Diego, CA 

San Francisco-Oakiand, CA 
San Jose, CA 

Seattle-Everett, WA 

Tampa-St. Petersburg, FL 
Washington, DC-MD-VA 

SMSA 
Population 

1583689 
175193 
168937 
176957 

87443 
604862 

120413 
147225 

96246 
23900189 

142197 

- 330684 
64944 

314479 - 

100752 

114924 

654692 
125378 

116685 
184637 
172248 

112345 

656937 
134614 

357534 
1191582 
1478585 

98903 
156291 

82568 
178984 
111714 
156162 

206937 
98287 

119113 
101611 
2365738 

  

>10 ug/dl 
Er % 

52670 33.1 

82453 47.1 

98857 53.5 

122862 69.4 

54012 51.8 

371952" 861.5 

65748 54.8 

95304 64.7 

48738 50.6 

124350 42.9 

51825 36.4 

188768 538.5 

258345 39.0 

124209 139.5 

50174 49.8 

58018 50.5 

380905 58.2 

84180 51.2 

86110 58.7 

82904 44.9 

83078 35.5 

64845 57.7 

490977 74.7 

08230 : 70.7 

221654 62.0 

388518. .32.3 

86921 58.9 

44249 44.7 

83519 40.8 

33781 40.9 

98705 55.7 

48747 43.6 

62949 40.3 

114921 55.5 

+:34700  .38.3 

47556 39.9 

41849 41.2 

122406 51.7 

  

>15 ug/l 

# % 

14858 9.3 

28614 16.3 
42063 24.9 

42187 23.8 

20631 23.6 

154037 25.5 

23957 19.9 

40365 27.4 

17179 17.8 

41025 14.1 

15122 11.3 

77492 23.4 

8062 12.4 
40204 ~~ 12.8 

17323. 172.2 

21743 18.9 

137788 21.0 

24194 19.3 

25041 21.5 

24921 13.5 

16776 9.7 

29866 26.6 

222229 33.8 

40318 30.0 

94297 26.4 

12298 0.3 

30447 20.6 

13889 14.1 

19204 12.3 

10627 12.8 

41968 23.4 

17114 15.3 

19683 12.6 

40817 18.7 

9863 10.0 

14321 12.0 

14585 14.4 

46267 19.6 

 



  

Contact: Don Ryan 
Executive Director 

(202) 543-1147 

HUD REPORT TO CONGRESS: COMPREHENSIVE AND WORKABLE 

PLAN FOR THE ABATEMENT OF LEAD-BASED PAINT 
IN PRIVATELY OWNED HOUSING 

SUMMARY 

  

Background: In its December 13, 1990 Report to Congress, the 

Department of Housing and Urban Development (HUD) formally 

released its first comprehensive plan for addressing lead-based 

paint hazards in privately-owned housing. 

HUD was mandated by the 1987 amendments to the Lead-based Paint 

Poisoning Prevention Act to: conduct a national survey on the 

extent of lead-based paint in American housing; undertake abate- 

ment demonstrations in FHA-foreclosed and public housing units to 

find more cost effective methods; and develop a "comprehensive 

and workable plan" to address lead hazards in all U.S. housing. 

In its formal submission to Congress, HUD consolidated these 

efforts in this single report. The report was submitted three 

months after the statutory deadline. 

conclusions: The report contains important and disturbing con- 

clusions: 
  

o The report reviews recent medical research on the health 

hazards to children and fetuses of low lead levels (summa- 

rized in the release on the Centers for Disease Control in 

this packet). 

o Although there are many sources of lead in the environment, 

lead-based paint plays a major role in childhood lead poi- 

soning. Lead-based paint is an important source of house- 
hold lead dust, which also causes poisonings. 

o Lead-based paint is still widespread in housing. Three- 

quarters of the 77 million homes built before 1980 contain 

lead-based paint. Of those 57 million homes with lead-based 

paint, 10 million have children under 7 years old living in 

them. 3.8 million of the units occupied by young children 

are priority hazards because of excessive amounts of lead 
dust, peeling lead-based paint, or both. 

o There is no correlation between the incidence of lead-based 

paint and the income of the household. Lead-based paint is 

found as often in the homes of the well-to-do as the poor. 

o The cost of removing lead-based paint in American housing 

ranges from about $5,500 to $7,700 for most homes. For 

 



  

homes with extensive lead paint, costs range from about 
$8,900 to $11,900. 

o Most state and local governments have done little to respond 
to the lead-based paint hazard, except to react to cases of 
childhood lead poisoning. Those cases are usually discov- 
ered through blood lead screening programs that, in most 
areas, reach only 5 percent of the children. 

o If lead paint abatements are not done properly, they can 
aggravate problems and increase dust levels. There are not 
enough trained workers to perform the needed testing and 
abatement work competently. 

  

HUD's "Comprehensive Plan": HUD's plan contains the following 
elements: 

o Updating HUD's lead-based paint regulations 

o Addressing hazards in all federally-owned housing 

o Expanding information and education efforts 

o Initiating research and demonstration activities 

o Helping local governments to expand safe lead removal 

o Providing funds for lead-based paint abatement 

ALLIANCE'S ANALYSIS: 

For the past 20 years, HUD's general approach to the hazards of 
lead-based paint has been denial--and its unstated but steadfast 
policy goal to do as little as possible. In Administration after 
Administration, action by HUD came only as a direct result of 
specific mandates from Congress and the courts. In fact, it was 
Congress' mounting frustration with HUD which triggered the 
extremely prescriptive legislative requirements for these studies 
and development of this plan. 

  

It is this long legacy of inaction on lead-based paint which 
makes this report to Congress all the more significant as a 
turning point in HUD's approach to childhood lead poisoning. For 
the first time, the Department of Housing and Urban Development 
has clearly acknowledged the reality of the serious hazards 
caused by lead-based paint in millions of American homes. 

Equally significant is the fact that HUD has implicitly accepted 
responsibility for helping remove lead hazards in private hous- 
ing. This policy shift is extremely significant, since the 
federal government has essentially left cities and states to fend 
for themselves. 

 



Unfortunately, this plan offers no hard evidence of any real 

commitment by HUD to address these hazards and little detail on 

program specifics. We will not know whether HUD plans to follow 

up on its report by requesting funds until the President's 1992 

Budget is submitted to Congress on February 4, 1991. 

The Alliance believes the following technical points and issues 

deserve special emphasis: 

0 The report acknowledges the medical evidence of the subtle 

but pervasively debilitating effects of low lead levels, as 

well as CDC's impending changes in the blood lead threshold. 

The report points out the limitations of most local preven- 

tion programs--removing lead-based paint hazards only after 

children are poisoned and identified through screening. This 

approach stems partly from a lack of federal support. 

This report also clearly acknowledges the serious hazards of 

invisible lead paint dust, in stark contrast to HUD's past 
regulatory attempts to define the problem as "chipping and 
peeling paint up to five feet high." 

HUD's recent sampling survey offers the most accurate pic- 
ture of lead paint in U.S. housing. These figures are 
slightly higher than the rough estimates in the 1988 ATSDR 
but validate its methodology and conclusions. 

In contrast to the general preoccupation with lead-based 
paint in public housing, the HUD report makes clear that the 
worst problems lie in private housing. In fact, HUD's 
survey data indicate that lead-based paint significantly 
affects housing at all income levels. 

  

The estimate that 57 million homes have some lead paint may 
be used by some to perpetuate feelings of paralysis in 
dealing with the problem. The report's most critical sta- 
tistic is that 3.8 million homes are priority hazards in 
need of attention as soon as possible. 

HUD's plan deftly avoids virtually all implementation is- 
sues. There are a host of technical, research, standards, 
training and technology transfer tasks which must be ad- 
dressed by HUD, EPA, OSHA and other federal agencies. It 
appears unlikely that most of these will be addressed in the 
President's upcoming 1992 Budget. 

It should be noted that HUD's demonstration of lead paint 
abatement in public housing is woefully behind schedule. 
Work has not even begun on some public housing units vacated 

more than one year ago. 

The rhetoric has shifted in the right direction--the work 
still needs to begin.  



  

Contact: Don Ryan 
Executive Director 

(202) 543-1147 

HHS STRATEGIC PLAN FOR ELIMINATING CHILDHOOD LEAD POISONING 

SUMMARY 

Background: The Department of Health and Human Services is 

expected to release its national strategic plan to eliminate 

childhood lead poisoning in the next few months. This plan was 

called for in February 1990 by Dr. James Mason as an early 

initiative after becoming Assistant Secretary for Public Health. 

  

Dr. William Roper, director of the Centers for Disease Control in 

Atlanta, directed preparation of the plan. The document has 
received wide review both within HHS and among other Federal 
agencies. This strategic plan is expected to be released in the 

near future. 

conclusions: Reviewers of this strategic plan have reported that 

its comprehensive analysis: 
  

0 Documents the adverse health effects of low-level lead 

poisoning. 

o Reveals the epidemic proportion of lead poisoning in U.S. 
children. 

o Identifies lead-based paint as the primary cause of 
poisonings. 

o Conducts a cost-benefit analysis which demonstrates the 
overwhelming benefits of lead-based paint abatement in U.S. 
housing. 

o Highlights the need for greatly increased screening to iden- 
tify children at risk. 

o Calls for interagency coordination to increase prevention 
efforts. 

ALLIANCE'S ANALYSIS 

The HHS strategic plan is in direct follow-up to the 1988 Agency 
for Toxic Substances and Disease Registry (ATSDR) report to Con- 
gress, which documented the scope and severity of the epidemic 2 
1/2 years ago. Unfortunately, the ATSDR report met with re- 
sounding silence in both the Congress and the Executive Branch: 
no publicity, no hearings, no legislation, and no screening or 
prevention program initiatives. 

 



  

This strategic plan marks the beginning of the response phase by 

the Federal government. Its release by Secretary Sullivan will 

be a monumental turning point in the battle against childhood 

lead poisoning in the United States for several reasons: 

  

o This will be the first time HHS has called concerted atten- 
tion to childhood lead poisoning as an overriding public 
health problem. 

o The document will make clear that lead-based paint, long 
dismissed as a nuisance housing issue, is the primary cause 
of this most serious environmental and public health hazard. 

o This plan implicitly acknowledges the leadership role re- 
quired of the federal government in dealing with research, 
technology, "infrastructure," and resource requirements--a 
problem for which state and local governments has been left 
‘holding the bag. 

o In contrast to past prevention efforts that have been halt- 
ing and ineffective, this is the first time the federal 
government has taken a strategic approach to solving the 
problem. 

0 The strategic plan's expanded cost/benefit analysis accounts 
for the full social costs of childhood lead poisoning--not 
just the costs of chelation therapy and remedial education-- 
and makes clear the overwhelming benefits of a national 
abatement program. 

0 Finally, the plan is expected to identify the various steps 
required to be taken by the Federal government to launch an 
effective national abatement program. However, this plan 
will fall far short of identifying which federal agencies 
are responsible for which tasks. Although HUD has long been 
blamed for inaction, many Federal agencies have been dere- 
lict in addressing critical technical and other issues under 
their jurisdiction. 

Reportedly, HHS's strategic plan has been cleared and reviewed by 
all levels within CDC, HHS, and other federal agencies. The 
document is comprehensive and complete. There are now concerns 
over the plan's release may be delayed. 

There are also doubts that the President's 1992 Budget will 
request the money and staff for implementation by the various 
Federal agencies whose assistance is required. Plans and poli- 
cies are empty gestures without the resources to implement them. 

 



  

Contact: Don Ryan 
Executive Director 

(202) 543-1147 

CENTERS FOR DISEASE CONTROL THRESHOLD AND GUIDELINES 

SUMMARY 

Health Hazards: Lead is a powerful neurotoxin which causes many 
adverse effects in the human body. At high levels lead causes 
convulsions, coma and even death. Lead is also known to cause 
cancer, anemia, high blood pressure, kidney disease, short-term 
memory loss, sterility, impotence and spontaneous abortion. 

  

Lower levels of lead put children under age six at greatest 
danger because of their developing brains and nervous systems: 
reduced IQ, reading and learning disabilities, reduced attention 
span, hyperactivity and hearing loss. Lead also affects the 
developing fetus causing low birth weights, early deliveries, 
slower growth and reduced intelligence. 

Blood Lead levels: In the 1960's only children whose blood lead 
levels were above 60 micrograms per deciliter (ug/dl) were 
considered at risk. Research studies then confirmed damage at 
lower levels which do not produce clear symptoms, making it 
critical to identify poisoned children through screening. 

  

Over the years the level of lead deemed hazardous to children 
steadily declined as clinical, epidemiological and laboratory 
research studies demonstrated clear adverse effects at lower and 
lower levels. In 1971 a 40 ug/dl threshold was established for 
children. In 1975 this level was reduced to 30 ug/dl. In 1985 a 
25 ug/dl threshold was established. Research studies over the 
past decade have since established a strong consensus that 
adverse neurological and developmental effects occur in children 
at blood lead levels of 10 ug/dl and possibly lower. 

Upcoming CDC Guideline Revisions: Based on this new scientific 
evidence, the Centers for Disease Control (CDC) is revising its 
threshold and guidelines for screening lead poisoning in chil- 
dren. CDC formally convened a l4-member advisory committee to 
make specific recommendations. This committee met in July 1990 
and again last November. Discussions at these meetings demon- 
strated a growing consensus on the risk to children of lead 
levels above 10 ug/dl. In fact, CDC proposed a long-term goal of 
reducing all children's blood lead levels to below 5 ug/dl. 

  

A proposed draft of the revised guidelines is expected to be 
circulated by CDC to all advisory committee members in early 
February, followed shortly by their final meeting. CDC's formal 
action reducing the threshold and issuing new guidelines is 
expected to be formally issued in early spring. 

 



  

The current definition of lead poisoning is expected to be 
changed from 25 ug/dl to 10 ug/dl, based on the discussions. at 

the July and November meetings and subsequent press reports. The 
vast increases in caseload, however, will make individual case 
management and followup by local programs possible only for 
children with blood leads above 15 or 20 ug/dl in most areas. 

The presence of children with lead levels above 10 ug/dl (but not 
under case management) demonstrates a serious public health 
problem. A totally new approach will be required using on 
community-wide primary prevention strategies. 

ALLIANCE'S ANALYSIS 

CDC's revision of the childhood lead poisoning threshold and 
guidelines represents a policy change of enormous significance--a 
watershed event. The acknowledgement of the health hazards to 
children with blood lead levels above 10 ug/dl finally closes the 
gap between science and policy. 

The significance of this change is demonstrated by the ten-fold 
increase in the number of children recognized as lead poisoned. 
Instead of 1 1/2 or 2 percent of children, the prevalence rate is 
now estimated at 17 percent--one child out of every six in the 
United States or 3,000,000 children nationwide. This means more 
than 1,500 infants and children are being lead poisoned every 
day. 

  

  

This change should shatter widely held misconceptions that lead 
poisoning is confined to the urban poor or minorities. Large 
numbers of suburban white children are already affected. Child- 
hood lead poisoning is the foremost preventable disease of 
children. And as Dr. William Roper the director of CDC, has said, 
its "the No. 1 environmental problem facing America's children." 

The consequences of this change on local childhood lead preven- 
tion programs are also enormous. These programs, whose resources 
are already stretched thin, will experience huge increases in 
caseloads. Even if only cases above 20 ug/dl are tracked, their 
workloads will double, triple and in some cases quadruple. 

Finally, CDC's recognition of the hazards at blood lead levels of 
10 ug/dl makes clear that lead poisoning is one of the most 
serious public health problems in the country. There are so many 
children poisoned that the case-by-case "medical model" approach 
cannot possible reach them all. Communities must come to grips 
with this environmental health and public health problem and 
begin treating the root causes--most importantly, lead-based 
paint in older homes. 

Note: Under a grant from the Environmental Protection Agency, the Alliance To 
End Childhood Lead Poisoning is developing a primary prevention strategies 
handbook to help communities make the transition from reaction to true 

prevention. 

 



Contact: Don Ryan 
Executive Director 
(202) 543-1147 

ATSDR 1988 REPORT TO CONGRESS: THE NATURE AND EXTENT 

OF LEAD POISONING IN CHILDREN IN THE UNITED STATES 

SUMMARY 

Background "The Nature and Extent of Lead Poisoning in Children 
in the United States" was prepared by the Agency for Toxic 
Substances and Disease Registry (ATSDR), a sister agency to the 
Centers for Disease Control. This report to Congress was ordered 
by the 1986 amendments to the Superfund legislation and was 
submitted in July 1988. 

Conclusions The ATSDR Report summarizes the research on the 
health effects of low-level lead exposures, estimates nationwide 
and population subgroup prevalence rates at various blood lead 
levels and analyzes the sources of lead and causes of poisoning. 

Health Effects The ATSDR Report summarized the research findings 
on lead's adverse health effects in children down to the 10-15 
ug/dl range. (These health effects are summarized in the release 
on the Centers for Disease Control in this packet.) 

  

Prevalence Rates ATSDR estimates that 17 percent of all U.S. 
children (one child out of every six or approximately 3,000,000 
children) have blood lead levels in excess of 15 ug/dl. The 
following table, showing the percents of children in various 
population subgroups with lead levels above 15 ug/dl, is adapted 
from the ATSDR report: 

  

Outside Central 

Cities White Overall 

< 1 million 7 8 

> 1 million 1] 13 

Inside Central 

Cities 

< 3 'million 12 40 20 

> 1 million 18 53 31 

(Note: If 10 ug/dl had been used the number of children affected would have 
been even higher). 

In addition, the ATSDR report estimates that nationwide approxi- 
mately 10 percent of white women and from 15 to 20 percent of 
black women of child-bearing age have blood lead levels above 15 
ug/dl. This means that each year approximately 400,000 babies  



  

are born lead poisoned as a result of excess lead in their 

mothers' bodies. 

Sources of Exposure The ATSDR report identifies leaded paint in 
homes as the primary cause of childhood lead poisoning. In 
additicen to children eating paint chips, the ATSDR report makes 
clear the equally serious danger of ingestion of lead dust. Lead 
dust is invisible, settles on contact surfaces, and readily 
sticks to children's hands. 

  

Assesment of Past Approaches The ATSDR Report also identified 
various problems in past responses to childhood lead poisoning: 

o Local screening programs have reduced the rates of severe 
lead poisoning. However, chronic exposures at the lower 
levels now deemed hazardous will require other approaches. 

o The current case-by-case response to lead poisoning and 
lead-based paint abatement is not effective. A community 
approach would better serve public health objectives and 
encourage market forces to value lead removal. 

0 Traditional approaches to removing leaded paint often relied 
on improper methods, which generated large amounts of lead 
dust posing a hazard to both workers and families who reoc- 

~ cupy "deleaded" homes. 

0 Improved nutrition is important as a preventive measure, 
since having proper calcium and iron levels affects the 
amount of lead absorption. 

o Education efforts, such as those targeted at cigarette 
smoking and seat belt use, have been demonstrated as effec- 
tive in changing people's behavior and should be directed at 
childhood lead poisoning. 

ATSDR Report Recommendations 

o Every child in the U.S. should be screened. Lead screening 
data should be uniformly compiled on a nationwide basis. 

o All high-risk pregnant women should be screened. 

o An integrated assessment of all exposure sources for chil- 
dren is required. 

o Coordinated efforts are needed to reduce the major causes of 
lead poisoning: lead-based paint, paint dust and soil lead. 

o More precise and sensitive methodologies for testing, detec- 
tion and environmental monitoring of lead are required. 

 



  

0 Lead abatement initiatives should carefully consider move- 

ment of lead and dust to avoid simply shifting the problem 

from one part of the environment to another. 

ALLIANCE'S ANALYSIS 

Attention to childhood lead poisoning had been steadily declining 

during the 1980's after federal categorical grants and reporting 

requirements were terminated in 1981. The ATSDR 1988 Report to 

congress therefore marked a turning point. Some have even 

compared the significance of its message to the Surgeon General's 

1963 Report on Cigarette Smoking. 

For the first time, the ATSDR Report identified childhood lead 

poisoning in the U.S. as an epidemic: 17 percent of children 

under six--one child out of every six--3,000,000 children nation- 

wide. This report also highlighted dangers. to the fetus from 

lead. Each year, 400,000 babies are born with lead poisoning, a 

chilling statistic. : 

This report to Congress made clear how disproportionately child- 
hood lead poisoning falls on the shoulders of minorities and the 
poor. The prevalence rate for poor, black children living in 
inner cities is a staggering 55 percent. 

At the same time, the report shattered misconceptions that lead 
poisoning is only a disease of the poor. Even in the lowest risk 
subgroup--white children outside central cities--the prevalence 
rate is seven percent. These figures make it painfully clear 
that lead poisoning eclipses other environmental problems and is 
the foremost preventable disease in children. 

The ATSDR Report also cleary identified lead-based paint as the 
primary cause of childhood lead poisoning. In that respect, its 
analysis of the various causes of lead poisoning marked the first 
strategic approach to the problem--in sharp contrast to EPA's 
piecemeal regulation of lead. 

Finally, the most remarkable aspect about the 1988 ATSDR Report 
to Congress was the deafening silence which met its release. It 
is noteworthy that the Administration released the report on a 
Saturday--with no publicity. No initiatives were proposed to 
respond to the epidemic just identified--no hearings held--no 
legislation proposed. Despite the report's utterly disturbing 
findings, it took two years for consciousness to begin to awaken 
and momentum for action to begin to build. The federal govern- 
ment is finally just now beginning to respond. 

 



Contact: Don Ryan 
Executive Director 
(202) 543-1147 

HUD'S LEAD-BASED PAINT INTERIM GUIDELINES FOR 
HAZARD IDENTIFICATION AND ABATEMENT 

IN PUBLIC AND INDIAN HOUSING 

THE GUIDELINES The Department of Housing and Urban Development's 

(HUD) technical guidelines for lead-based paint abatement, 

initially published on April 15, 1990, included confusing worker 

protection recommendations. Corrections and clarifications were 

published in September 1990 and are now in full effect. Copies 

of the HUD Guidelines are available for $3.00 by calling (800) 

245-2691. 

The HUD guidelines provide comprehensive recommendations on all 

technical matters related to lead-based paint abatement done in 

the context of a major rehabilitation project. Although written 

specifically for public housing comprehensive modernization 

projects, most aspects of these guidelines are applicable to 

other lead-based paint abatement projects. 

Briefly summarized: 

o Testing Several options are available to identify the pres- 

ence of lead-based paint. The guidelines explain the use 
and limitations of x-ray fluorescent testing devices and the 
wide variability of readings and confidence limits. Guide- 
lines for other chemical tests are also provided. 

Abatement Three basic approaches are outlined: 1) replace- 
ment of the lead painted component; 2) removal of the paint; 
and 3) encapsulation. Techniques commonly used in the 
past--removing lead paint by open flame burning and open 
sanding--are strictly prohibited. Great emphasis is placed 
on controlling the generation of lead dust and on post- 
abatement cleanup procedures. Occupants must be relocated 
from their homes during major abatement work. The guide- 
lines also make clear that abatement must be conducted by 
well trained workers--it is not for the amateur or week-end 

home handyman. 

  

  

  

Worker Protection The guidelines recommend work practices 
and safeguards to protect workers from lead poisoning. Most 
notable is the requirement that all workers engaged in 
abatement projects wear respirators at all times. Workers 
must also clean up carefully at the end of the day so that 
they do not carry lead dust home and poison their children. 
Worker blood lead levels should be regularly monitored to 
assure that they are not being poisoned. 

   



Cleanup The report emphasizes the need to clean up lead dust 

upon completion of a job. Multiple cleanings using indus- 
trial vacuums and phosphate detergents are called for. 
Also, dust wipe testing must be conducted to assure that 
post-abatement surface lead dust does not exceed recommended 
levels. 

Disposal All abatement debris must be handled with care. The 
report describes testing procedures to determine which kinds 
of abatement debris must be handled as "hazardous waste." 
Clearly, lead paint chips, dust, and residues containing 
concentrated lead must be treated as hazardous. By segre- 
gating waste with the highest lead concentrations from bulky 
items, however, the majority of abatement debris need not be 
disposed of as hazardous waste. 

ALLIANCE'S ANALYSIS 

During the 1970's and 1980's, many abatement projects were 
conducted using improper techniques that only aggravated problems 
and poisoned more children and workers. No national set of 
technical recommendations on methods and safeguards had existed. 
The vast majority of abatement projects are now being conducted 
using improper techniques, often by unprotected workers who do 
not even realize they are doing lead abatement. 

Getting the guidelines developed and published by HUD required 
the continuing oversight and prodding from Congress over a two- 
year period. One year after its initial direction to HUD to 
develop consensus guidelines, Congress was forced to set the 
April 1990 deadline in statute. Finally, Congress had to direct 
that revisions be made to correct the confusion over worker 
protection recommendations when the Office of Management and 
Budget made last minute changes. 

As the first national set of consolidated technical guidelines, 
this HUD document fills a critical gap and makes an important 
contribution to safe and effective lead-based paint abatement. 
The guidelines are significant for several reasons: 

o The prohibition of mechanical sanding and open flame burning 
is extremely important and deserves broad dissemination. 

The concerted emphasis on hazards presented by lead dust 
and the need for rigorous post-abatement cleanup is para- 
mount. The majority of current lead-paint abatement work 
relies on methods which generate large quantities of dust 
with little or no attention to cleanup. 

The current Occupational Safety and Health Administration 
(OSHA) standards for worker protection are woefully inade- 
quate. The OSHA general industry standard was promulgated 
in 1978 and does not protect workers from exposures now 
known to present clear hazards. To make matters worse,  



  

lead-based paint abatement workers, as part of the "con- 
struction industry," are not currently even protected by the 
general industry standard. 

0 It is most significant that the HUD guidelines recommend 
that lead abatement workers wear respirators at all times. 

Now that national technical guidelines have finally been estab- 
lished the challenge is to put these new methods into practice. 
As a next step, the HUD guidelines must be widely distributed and 
public housing authority staff, contractors, architects and 
inspectors trained. Training courses must be developed, so that 
workers can be trained and contractors certified to build nation- 
al capacity for safe and effective abatement. Information about 
the hazards of improper lead removal must also be provided to the 
public. 

At the same time, the need for federal action on a multitude of 
technical issues is painfully clear. It is appalling how little 
technical progress has been made in the twenty years since the 
federal government made a commitment to end childhood lead 
poisoning. Laboratory protocols are inconsistent, cleanup 

~ standards are lacking, methods for detecting lead in paint and 
- dust are unreliable, and performance requirements for abatement 
are nonexistent. In many cases, drafters of the HUD guidelines 
were forced to rely on state and local standards. 

Addressing these technical problems is clearly the responsibility 
of the federal government and must be given a high priority. The 
cost of lead-based paint cleanup can only be reduced through 
expanded federal research, evaluation, and demonstration projects 

- and systems to assure quality control of laboratories and con- 
tractors. Modest investments in these areas will save billions 
in the long run. But, so far the Administration has refused to 
request the funds for HUD, EPA, and HHS to meet their responsi- 
bilities.