Today the Trump Administration issued its long-promised and much-ballyhooed “Lead Action Plan,” which it said will “identify and reduce lead contamination while ensuring children impacted by lead exposure are getting the support and care they need.”
We welcome the recognition that lead continues to be an extraordinary threat to public health. However, upon scrutiny, the plan goes over like a lead balloon among those who carefully track lead issues. Feel-good promises to “consider” and “evaluate” actions, without time frames or commitments to take specific regulatory or enforcement action, will not protect children.
- The agencies say they will “consider” revisions “as appropriate” to lead hazard standards for lead-based paint. But they are already required under a court order to do so by July 2019. “Considering” complying with a court order will not cut it. The Environmental Protection Agency’s (EPA’s) July 2018 proposal did tighten the dust standards (not as much as the public health, medical, housing, and environmental communities were recommending). But it completely failed to update the lead paint clearance standards, meaning that after cleanup, levels could remain the same as required in the old extremely weak standards.
- The agencies say they will revise (with no deadline) the EPA Lead and Copper Rule (LCR) for drinking water. But they plan to base their revisions on comments “from state, tribal, and local partners” and fail to mention the views of public health, medical, environmental, and other scientific experts. Many state and local officials have fought against significant improvements to this rule, such as mandatory full replacement of all lead service lines paid for by water utilities by a date certain. Furthermore, EPA previously said the strengthened LCR would be proposed by January 2018; then they said they would be proposed by February 2019. Now, the action plan offers no deadline.
- The agencies say they will assist schools and child care centers with the 3Ts approach (Training, Testing and Taking Action) on lead in school tap water. But earlier this year they updated their approach by eliminating the previous recommendation that any fountain serving over 20 ppb lead should be taken out of service—there is now no recommended maximum.
- The agencies say they will “evaluate updating” the clearly inadequate blood lead reference value of 5 micrograms of lead per deciliter of blood (ug/dL), even though they admit the data would dictate a 3.5 ug/dL level.
- They say they will “evaluate” the impacts of continued use of lead in aviation fuel, with no promise of even proposing action as recommended by public health experts.
- The agencies say they will “reevaluate” the provisional tolerable total dietary intake level for lead in food, will “consider” increased monitoring, and will “consider whether to establish maximum lead levels in foods by regulation or guidance.” However, there is no commitment to propose rules or promised dates for such actions. While we welcome that FDA recently adopted an “interim” level to update its outdated 1993 dietary intake target, recent data shows about 1 million kids are over the FDA target, showing a clear need for strong regulatory action to reduce lead levels in the diet.
We need strong action to protect children and every American from toxic lead. There is no safe level of lead; until strong and meaningful regulator action cuts continued exposure, little progress will be made. Let’s get the lead out!