Against Childhood Lead Poisoning
Maryland Attorney General Brian E. Frosh joined a coalition of 19 state attorneys general in calling on the United States Environmental Protection Agency (EPA) to strengthen protections against lead poisoning. In comments on the EPA’s “Draft Strategy to Reduce Lead Exposures and Disparities in U.S. Communities,” the coalition called the draft strategy a “strong starting point.” However, the coalition lays out specific recommendations for how the EPA should bolster the plan to combat the many ways in which children are exposed to lead.
“The EPA’s draft strategy to mitigate lead exposure is a good one, but we believe that it should be strengthened. Lead poisoning disproportionately impacts children in low-income communities and communities of color. Our comments urge a more aggressive approach that will more rapidly deliver environmental justice,” said Attorney General Frosh
Lead is a highly toxic metal that can cause serious and irreversible adverse health effects. The Centers for Disease Control and Prevention estimates that children in at least 4 million households nationwide are exposed to high levels of lead. A 2021 study published in the Journal of the American Medical Association Pediatrics suggested that more than half of all U.S. children have detectable levels of lead in their blood. That study also found that elevated blood lead levels in children were closely related to poverty, race, and living in older housing.
In Maryland, laws are in place that require residential landlords of properties built before 1978 to register their property with the Maryland Department of Environment, provide specific information about lead poisoning prevention to tenants, perform full risk reduction measures, obtain certification that those measures have taken place, and provide that certificate to their tenants prior to moving in. Residential landlords must also perform modified risk reduction measure when they are served with a “Notice of Defect,” including peeling paint or presence of a child with elevated blood lead levels.
Children who have been exposed to even very low levels of lead are at risk for neurological and physical problems during critical stages of early development. In fact, no safe lead level in children has been identified. Children under the age of 6 are more likely to be exposed to lead than any other age group, as their normal behaviors could result in them chewing lead paint chips; they could breathe in or swallow dust from old lead paint that gets on floors, window sills, and hands; and lead can be found in soil, foods eaten by children, and other consumer products.
In their comments, the coalition credits the EPA’s Draft Lead Strategy for identifying government-led approaches to increasing public health protections, addressing legacy lead contamination for communities with the greatest exposures, and promoting environmental justice. However, the coalition’s comments identify numerous other measures necessary to strengthen the Strategy by aggressively targeting hazards posed by lead in paint, drinking water, soils, aviation fuel, air, food, and through occupational and take-home exposures. These include:
- Increasing resources for the enforcement of existing laws relating to lead paint in rental housing and amending existing regulations to require landlords to increase the frequency of inspections of houses with a history of lead paint hazards;
- Developing proactive policies and standards for hazardous waste sites, drinking water, and other sources of lead exposure that are more protective of health and designed to reduce lead poisoning;
- Developing aggressive deadlines for tightening standards, developing enforcement policies, and conducting an endangerment determination for lead in aviation gas under the Clean Air Act;
- Identifying meaningful environmental justice targets to ensure that the communities most in need and the vulnerable are protected;
- Encouraging inter-agency collaboration and data-sharing with other federal agencies such as HUD, OSHA, FAA, and FDA, and USDA;
- Pledging allocations of federal funds to replace drinking water service lines containing lead reaching struggling and historically marginalized communities;
- Adopting federal regulations requiring testing of water and remediation of lead service lines and lead plumbing fixtures in public, charter, and private schools, and in childcare centers;
- Expanding multi-language informational campaigns and blood lead testing programs to address “take-home lead” exposure – lead from work that accumulates on a worker’s clothing and shoes; and
- Developing other specific metrics for achieving and evaluating success in lead reduction.
Joining Attorney General Frosh in submitting the comments are the attorneys general of California, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois Maine, Massachusetts, Minnesota, New Jersey, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, and Wisconsin.