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Testimony of
David E. Jacobs, PhD, CIH
Director, Office of Lead Hazard Control
U.S. Department of Housing and Urban Development
Before the Subcommittee on Public Health
Senate Health, Education, Labor and Pensions Committee
November 15, 1999
Lewiston, Maine
Today I will discuss both the achievements and remaining challenges in the nation's efforts to decrease elevated blood lead levels, including eliminating childhood lead poisoning. I am also providing more detailed information for the record on the scientific understanding of how exposures to lead in paint occur and how they can be prevented, because I firmly believe that good science must be used in establishing public policy.
But first I want to recognize the leading role played by Senators Collins and Reed on this issue. The recent unanimous Senate resolution co-sponsored by both Senators established National Childhood Lead Poisoning Prevention Week for the first time. President Clinton's Proclamation on this issue reinforced the Adminstration's commitment to solving this important problem. I have received reports from all over the country indicating the week was a tremendous success in galvanizing hundreds of neighborhoods, community groups, parent's groups, business organizations, and state and local governments into action. During that week, Secretary Cuomo announced $56 million in grants to correct lead-based paint hazards in privately-owned, low-income housing. This is a reflection of his strong and continuing commitment to ensure that America's children are safe from lead-based paint hazards.
Today I want to report some of the breakthroughs we have achieved and the remaining obstacles that need to be overcome. At the beginning of this decade, the nation was mired in inaction about what to do regarding lead-based paint in housing. Some believed the problem was too big or, paradoxically, not important enough.
In 1991, only one state had a law that licensed lead inspectors and abatement contractors. There was virtually no infrastructure in place to respond responsibly to the problem. The scientific understanding of how children are actually exposed to lead in paint was poorly developed. The technology of identifying lead paint hazards had unacceptably high rates of error. There were no federal laws on the books that addressed existing lead paint hazards in housing (other than in housing assisted by the federal government). Few state and local governments actively enforced local lead paint ordinances.
Since that time, much has changed for the better, including:
- HUD lead-based paint grants are now active in over 200 cities, making the homes of low-income families lead-safe and creating new jobs, job training and other economic development opportunities;
- Disclosure and education in virtually all pre-1978 housing lease and sale transactions are now required under federal law. A new enforcement effort by HUD, EPA and the Department of Justice makes it stick. The law ensures that parents have the information they need to protect their children;
- Modernized, scientifically valid lead paint regulations in federally-assisted housing were recently published in September, 1999, overhauling and consolidating the Department's lead paint requirements for the first time in 20 years;
- Lead licensing laws now exist in 33 states, with the remaining states falling under EPA jurisdiction in March 2000;
- Tens of thousands of inspectors, abatement contractors, rehab specialists, remodelers, and do-it-yourselfers have been trained in lead-safe work practices and the system is in place to train many more. For example, HUD has worked with Home Depot, Lowes and Ace Hardware to make sure that educational materials are provided to customers and that hardware store employees know how to advise people in lead-safe work practices. We have provided grants to train several thousand professional remodelers through the National Association of the Remodeling Industry;
- Controlling lead paint hazards has become more inexpensive and reliable as a result of innovation and government action.
Here in Maine, HUD has provided a $2.7 million grant to the State of Maine (which will be used to target privately-owned homes and apartments in neighborhoods both here in Lewiston and in Bangor) and two grants to Portland totaling $2.8 million. In Portland, the grants have been used to create an innovative program to bring immediate help to families with a lead poisoned child through emergency specialized control of lead dust hazards.
The grants are used to correct lead-based paint problems before a child is poisoned. Under this program, we diagnose houses instead of using our children as detectors. The grants have also stimulated the creation of a trained, licensed professional workforce, because the Congress wisely required that federal funds not be used to support poor quality work.
When Congress first authorized HUD's lead paint grant program in 1991, it required the Department to evaluate its effectiveness. We recruited 14 of the first grantees (including the State of Rhode Island) into a rigorous scientific study to determine whether or not the hazard control methods funded under the program were effective. This study of about 1,200 dwellings is the nation's largest-ever examination of residential lead hazard control. We have sent interim findings in a Report to Congress each year for the past few years.
Today, I wish to release the most recent results, which contain some unexpectedly good news.
Outcome was measured in two principal ways in the evaluation: children's blood lead levels and levels of lead-contaminated dust over a three year time period. The dust outcome measure is particularly important in relation to children's blood lead levels.
The latest data show that dust lead levels on floors declined by 64% compared to baseline levels and dust lead levels on window sill surfaces declined even more (ranging from 86% to 95%) over a three year period. Furthermore, the dust lead levels have stayed well below HUD's interim safety standards. Blood lead levels in children living in the units declined by 26%.
The trend in dust levels is particularly good news. Because grantees focus on removing lead-based paint hazards, as opposed to removing all lead-based paint, many researchers believed that dust lead levels would reaccumulate after a short time, requiring additional work. Instead, the data show that the decline has been maintained for at least 3 years, and, if the current trend continues, probably for far longer. HUD will be extending the evaluation to determine how long such treatments last. Because lead paint remains in the units, it must be properly managed if children are to be protected. We expect to issue the latest interim report in February, 2000.
These findings have enormous policy implications, because they show that children can be protected through lower-cost treatments to houses, if those treatments are properly maintained. In our Economic Analysis for the lead paint regulation for federally-assisted housing, we relied on cost data from the HUD grant program. The cost of repairing a given housing unit depends on its overall condition, the extent of lead hazards, the type and number of building components coated with lead paint and the type of hazard control method employed. Our experience has shown that costs can vary dramatically from one housing unit to another, ranging from $100 to $15,000.
Our data show that the average cost of addressing lead-based paint hazards in the nation's low-income housing stock is about $2,500. More long-term strategies will obviously entail greater costs and greater benefits.
We also calculated the benefits of controlling lead-based paint hazards in federally-assisted housing. The benefits result from savings in medical care, and in special remedial education, and increased lifetime earnings due to increased intelligence and cognitive ability. We believe there are other benefits not yet explored scientifically.
For federally-assisted housing alone, we estimate the total cost of the regulation in the first year to be $253 million. The benefits in the first year are over $1.1 billion, resulting in a net benefit of about $890 million, using a 3 percent discount rate. Because this estimate is for federally-assisted housing alone, the total benefit of addressing lead paint problems in the entire housing stock would be considerably greater.
In spite of all this progress, the remaining obstacles to making the U.S. housing stock lead-safe for our children remain substantial.
The need for resources is clear. In the past round of funding, HUD received over $205 million in requests for funding from state and local governments. Despite mostly good applications, only one in three applications could be funded.
More needs to be done to increase public awareness of the importance of lead paint poisoning and elevated blood-lead levels from lead-based paint, how repainting and remodeling work can be done in a lead-safe manner, and how lead paint activities can be integrated into existing housing finance, maintenance and rehabilitation work. HUD's new lead paint regulation is based on this concept. The lead paint requirements are based on the type of federal assistance received, such as rental assistance, rehab, or mortgage insurance, not on the specific program. Therefore, HUD need not change its lead paint requirements every time one of its programs change.
More needs to be done to enforce the federal lead paint disclosure regulation. Although we now have over 80 on-going cases in about 2 dozen cities, and have brought about nearly $2 million in penalties, there is a clear need to devote additional resources to enforcement of federal lead-based paint regulations. HUD, the Department of Justice and the Environmental Protection Agency will be increasing their enforcement programs. Our enforcement actions are targeted at those situations that have been particularly egregious, where a child has been poisoned, or where lead-based paint was known to be present, yet the owner or manager failed to provide the necessary information.
We must find better ways to provide services in housing before blood lead levels rise, which typically occurs between the ages of 1 and 3, when children become more mobile. We should do better at linking parents of these children and pregnant women with an integrated network of services and educational programs to enable them to find home-based inspection visits, educational programs, blood lead screening services, or the local HUD lead-based paint hazard control program. I believe parents have a key role to play in not only protecting their own children, but helping to get information out more broadly than ever.
More resources are needed to address housing undergoing rehabilitation, where lead paint hazards may be inadvertently created or left behind at the conclusion of the work. Financial incentives targeted at low and moderate income families may also be needed to facilitate lead hazard control actions.
These are great and important challenges. Yet past experience has shown that we can be effective. Two decades ago, there were 3-4 million children with blood-lead levels above the Centers for Disease Control and Prevention's (CDC's) level of concern at that time. That number fell to 1.7 million in the 1980's and the most recent data from CDC show that cases have declined further to about 890,000. These were the result of the elimination of lead in food and beverage canning, gasoline, new residential paint, and in plumbing systems, as well as changes in the housing stock, such as demolition, rehab and on-going abatement efforts. Yet we still have much to do. Among low-income families living in older housing where lead paint is most concentrated, 16% have children with blood lead levels above the current CDC threshold, compared to 4.4% of all children. And among African-American children living in such housing, the rate climbs to one in five.
Today, we know that lead paint in housing is the major source of exposure to lead for most children. More importantly, we have the know-how and experience to guide our prevention strategies. Knowing what works, having the systems in place, and engaging all levels of government and all citizens puts us at an unprecedented advantage. Indeed, 100 years after childhood lead paint poisoning was first diagnosed, we are in a position to break the back of this preventable disease.
Supplemental information for the Record
Submitted by David E. Jacobs, PhD, CIH
Director, Office of Lead Hazard Control
U.S. Department of Housing and Urban Development
Although it has a large number of commercial applications, lead is a toxic material that has no useful biological function in the body. Its effects are most pronounced in young children and the developing fetus. It adversely affects virtually every system of the body. Lead can impair a child's central nervous system, kidneys, and bone marrow and, at higher levels, can cause coma, convulsions, and death. A recent review by the National Academy of Sciences showed that lower levels of lead exposure are harmful and are associated with decreased intelligence, impaired neurobehavioral development, decreased stature and growth, and impaired hearing acuity. No clear-cut threshold has been established for a "safe" blood lead level, but some studies suggest the presence of harmful effects of lead even at blood lead levels below 10 mg/dL. , However, the evidence of harmful effects is clear for blood lead levels of approximately 10 micrograms of lead per one- tenth liter of blood (mg/dL) or greater, a threshold recommended in guidelines issued by the Centers for Disease Control and Prevention (CDC) to trigger primary and secondary prevention efforts.
Lead exposure among young children has been dramatically reduced over the last two decades through a concerted effort by federal, state, and local government agencies, and voluntary actions in the private sector. Especially important have been measures to eliminate or greatly reduce exposure to lead from gasoline, food and beverage cans, house paint, industrial emissions, drinking water, and a variety of consumer goods. As a result, children's blood lead levels have declined by over 80% since the mid-1970s.
Despite this progress, nearly 1 million children under age 6 have elevated blood lead levels above 10 mg/dL.4 The most common source of elevated blood lead levels and lead poisoning for children is lead-based paint in older housing and the contaminated dust and soil it generates. , , , Poisoning from leaded paint has affected millions of children since it was first recognized more than 100 years ago , and it persists despite a 1978 ban on addition of lead to new paint. Although all children living in older housing are at risk, low-income and minority children are much more likely to face hazards. For example, 16% of low-income children living in housing built prior to 1946 have elevated levels of lead in their blood above the limit recommended by CDC, compared to the average for all children of 4.4%.4
Children may be exposed to lead from paint either directly, by ingestion of paint chips, or indirectly through its contribution to contamination of house dust or soil. , Leaded paint contaminates dust or soil when it deteriorates or is disturbed during repainting, remodeling, demolition or leaded paint removal without proper precautions , . Nationally, residences with exterior leaded paint are more than three times as likely to have lead in soil exceeding 500 parts per million than are dwellings without lead in exterior paint (21% versus 6%).11, If non-intact exterior paint is present, soil contamination is 8 times more common (48%) than at residences without exterior leaded paint.11,20
In general, for children with high baseline blood lead levels (greater than about 25 mg/dL), measures to remove or repair non-intact leaded paint are followed by declines in blood lead of between 20 and 30 percent over the following year. In one controlled study the decline in blood lead levels for children in treated dwellings was about twice that of children in untreated dwellings.
Extensive removal of leaded paint from homes of lead poisoned children without measures to prevent exposure of children to abatement dust and debris have been shown to cause increases in blood lead levels in children associated with increases in the levels of lead in house dust. , , Consequently, federal, state and local regulations and guidelines have prohibited certain hazardous paint removal methods and required safe work practices, cleaning, and dust lead clearance testing prior to re-occupancy. More recent longitudinal studies , , of lead hazard controls have evaluated strategies that combined measures to prevent generation of leaded paint chips and dust (treatments to eliminate non-intact leaded paint and windows with leaded paint subject to friction) with measures to reduce and prevent reaccumulation of leaded dust (specialized cleaning and sealing of floors). In addition, the elimination of leaded paint hazards relied primarily on component replacement and paint stabilization, with limited on-site paint removal. These treatments result in substantial, sustained reductions in interior dust lead loading and little if any risk of substantial short term increases in blood lead.
Field studies have shown that modern lead hazard control methods have been effective in reducing exposure to contaminated house dust by an average of 60% with an associated decline in blood lead levels of an average of at least 25%. House dust is the most common exposure pathway through which children are exposed.
A number of regulations have been developed to implement these hazard control measures. A modern, streamlined standard of care has been promulgated through new regulations for Federally-owned and Federally-assisted housing. Regulations to protect construction workers from lead exposure have also been issued and enforced (24 CFR 1926.62).
The current distribution of leaded paint in U.S. housing
Most residential lead-based paint is contained in housing built before 1960. Tables 1 and 2 show that between 88-96% of all lead in paint in housing is located in pre-1960 housing. Consistent with these data are blood lead data showing that among children living in pre-1946 dwellings (those built when the use of lead-containing paint was most common), the prevalence of elevated blood lead levels is five times higher than among children living in homes built after 1973, most of which do not have lead-containing paint.
Table 1
Estimated Average Paint Lead Consumption by Decade of Housing Construction
|
Lead Consumption (tons 000) |
Decade-End Occupied Units (MM) |
White Lead Pounds per Unit |
1991 AHS Units (MM) |
1991 White Lead Tons (000) |
Percent of All White Lead |
|
|
White Lead |
Red Lead & Litharge |
|
|
|
Before Rehab |
After Rehab |
1914-23 |
1,340 |
0 |
24.35 |
110 |
9.02 |
496 |
413 |
49.1% |
1920-29 |
1,307 |
356 |
29.91 |
87 |
5.06 |
221 |
184 |
21.9% |
1930-39 |
737 |
421 |
34.86 |
42 |
5.98 |
126 |
104 |
12.4% |
1940-49 |
476 |
1,189 |
42.83 |
22 |
7.67 |
84 |
72 |
8.6% |
1950-59 |
196 |
816 |
53.02 |
7 |
12.51 |
44 |
37 |
4.5% |
1960-69 |
82 |
781 |
63.45 |
3 |
14.52 |
22 |
20 |
2.4% |
1970-79 |
29 |
625 |
80.39 |
1 |
21 |
11 |
10 |
1.2% |
|
4,111 |
4,187 |
|
|
|
1,004 |
841 |
100% |
Source: U.S. Geological Survey, American Housing Survey
Table 2
HUD National Lead Paint Survey Data
|
Pre-40 |
1940-1959 |
1960-1978 |
Total |
LBP Surface Area (million sq. feet) |
|
|
|
Interior |
15,912 |
8,247 |
5,279 |
29,438 |
Exterior |
25,969 |
12,635 |
10,502 |
49,106 |
Average LBP Concentration (mg/sq.cm) |
|
|
|
Interior |
5.7 |
2.5 |
2.0 |
Exterior |
6.1 |
4.2 |
3.2 |
Total Lead in LBP (1000 tons) |
255 |
75 |
45
|
376 |
Interior |
93 |
21 |
11 |
125 |
Exterior |
162 |
54 |
34 |
251 |
Percent of Total Lead in LBP |
68% |
20% |
12% |
100% |
Interior |
74% |
17% |
9% |
100% |
Exterior |
65% |
22% |
14% |
100% |
According to the National Health and Nutrition Examination Survey (NHANES) data, the proportion of children age 1-5 years with elevated blood lead levels fell to 4.4% in 1991-94, a more than 80% decline from 1976-80.4 Despite these accomplishments, nearly one million children in the United States have elevated blood lead levels. The remaining problem is especially acute in certain population groups. For example, among children living in pre-1946 dwellings (those built when the use of lead-containing paint was most common), the prevalence of elevated blood lead levels is five times higher than among children living in homes built after 1973, most of which do not have lead-containing paint. Nationally, children who are eligible for Medicaid also represent a high-risk group, comprising 80% of children with blood lead levels 15 ug/dL and above. Childhood lead poisoning is the most common environmental disease of young children eclipsing virtually all other environmental health hazards found in the residential environment.
There are many potential sources of lead exposure in children, although they vary greatly in magnitude. Many of these sources have already been addressed and have directly contributed to the dramatic decline in blood lead levels to date. The Environmental Protection Agency (EPA) has virtually eliminated lead in gasoline, and has placed strict limits on the amount of lead in drinking water and on lead emitted from industrial facilities. EPA has also phased out lead in pesticides, and has addressed lead contamination at many Superfund sites. Food processors, in voluntary cooperation with the Food and Drug Administration (FDA), virtually eliminated the use of lead solder in domestically-canned food. FDA has established strict regulations concerning the amount of lead that can leach from ceramicware into beverages and foods. OSHA has regulated lead exposure for workers, also benefiting the children of those workers who may have been placed at risk via take-home exposures (such as lead dust on work clothing). The Consumer Product Safety Commission (CPSC), in addition to implementing a ban on residential leaded paint, has addressed lead contamination in children's toys, miniblinds, playground equipment and other sources, and continues to conduct special dockside inspections to look for children's products containing lead that present hazards. Public education efforts have been launched to publicize the dangers of lead in folk remedies, pottery glazing, art supplies, cosmetics, fishing sinkers, and other products. In addition, lead in residential paint was phased out and completely banned by CPSC in 1978.
The most important remaining exposure for children are lead hazards in their residential environment -- deteriorated lead-based paint, and house dust and soil contaminated by it.
References
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Partial Bibliography on Lead-Based Paint
Amitai 1987. Amitai, Y., Graef, J.W., Brown, M.J., Gerstle, R.S., Kahn, N., and Cochrane, R.E., "Hazards of Deleading Homes of Children with Lead Poisoning, American Journal of the Disabled Child, 141, 1987, p. 758-760
Amitai 1991. Amitai, Y., M.J. Brown, J.W. Graef, and E. Cosgrove. Residential Deleading: Effects on the Blood Lead Levels of Lead-Poisoned Children, Pediatrics 88(5):893-897.
Annest 1984. Annest, J. L., and Mahaffey, K., "Blood Lead Levels for Persons Aged 6 Months to 74 Years, United States 1976-80," Vital and Health Statistics, Series 11, 1984, No. 233, DHHS Publ. No. (PHS) 84-1683, Washington, D.C.
Aschengrau 1994. Aschengrau A., Beiser A., Bellinger A., et al. "The Impact of Soil Lead Abatement on Urban Children's Blood Lead Levels; Phase II Results from the Boston Lead-In-soil Demonstration Project," Environmental Research 1994: 67:125-148.
Aschengrau 1997. Aschengrau A. Beiser A, Bellinger D, Copenhafer D, Weitzman M. "Residential lead-based paint hazard remediation and soil lead abatement: their impact among children with mildly elevated blood lead levels," Am J. Public Health 1997; 87:1698-1702
ATSDR 1988a. ATSDR (Agency for Toxic Substances and Disease Registry). 1988. The Nature and Extent of Lead Poisoning in Children in the United States: A Report to Congress. Atlanta, GA.: U.S. Department of Health and Human Services.
Bellinger 1987. Bellinger, D., A. Leviton, C. Waternaux, H. Needleman, and M. Rabinowitz. 1987. "Longitudinal analyses of prenatal and postnatal lead exposure and early cognitive development," N. Engl. J. Med. 316:1037 1043.
Bellinger 1992. Bellinger D.C., Stiles, K.M, Needleman HL, "Low-level Lead Exposure, Intelligence and Academic Achievement: A long-term Follow-up Study," Pediatrics (6):855-861
Blackfan 1917. Blackfan, K. D., "Lead Poisoning in Children," American Journal of Medical Science, Vol. 153, 1917, pp. 877-887.
Bornschein 1987. Bornschein, R.L., Succop, P.A., Krafft, K.M., Clark, C.S., Peace, B., Hammond, P.B., "Exterior Surface Dust Lead, Interior House Dust Lead and Childhood Lead Exposure in an Urban Environment," Trace Substances in Environmental Health, 20, 1987, p. 322-332
Breinl 1914. Breinl, A., and Young, W. J., "The Occurrence of Lead Poisoning Amongst North Queensland Children," Annals of Tropical Medicine and Parasitology, Vol. 8, 1914, pp. 575-590.
Brody 1994. Brody, D.J., J.L. Pirkle, R.A. Kramer, K.M. Flegal, T.D. Matte=, E.W. Gunter, D.C. Paschall, ABlood Lead Levels in the US Population. Journal of the American Medical Association 272(4):277-283.
CDC 1991a. CDC (Centers for Disease Control). 1991. Preventing Lead Poisoning in Young Children: A Statement by the Centers for Disease Control, Report No. 99-2230, Atlanta, Ga.: CDC, U.S. Department of Health and Human Services.
CDC 1991b. Strategic Plan for the Elimination of Childhood lead Poisoning, Centers for Disease Control and Prevention, Public Health Service, Department of Health and Human Services, Atlanta, GA
CDC 1997a. "Update: Blood Lead Levels--United States 1991-1994," Morbidity and Mortality Weekly Report, U.S. Department of Health and Human Services/Public Health Service, Vol 46, No. 7, Feb 21, 1997, p. 141-146
CDC 1997b. Screening Young Children for Lead Poisoning: Guidance for State and Local Public Health Officials, Centers for Disease Control and Prevention, National Center for Environmental Health, Atlanta, GA, November 1997
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