My previous life as a scientist was largely focused on lead pollution issues–having worked in a lab that traces its roots back to the work of Dr. Claire Patterson. The first chapter of my dissertation involved the response of San Francisco Bay to leaded gasoline phase-out. So, my ears perked up when I heard this story on NPR on the way to work this morning regarding the CDC’s new recommendations for addressing lead exposure in children. As a scientist-turned-lawyer (and a father of two wonderful young children), lead science and policy remains a personal interest of mine.
My personal perspective on lead reduction in the environment is that it is one of the single most important public health achievements of the 20th century. As the CDC aptly summarizes, the evolving science of lead as a toxin indicates that even low levels of lead exposure have negative (and permanent) effects on children–including behavioral and achievement issues, lower IQ levels, links to ADHD, and even immunological responses. Because these effects are permanent, they influence an individual’s entire life, and ripple through society to the extent the effects impact and direct the use of public resources.
This evolving science resulted in the CDC eliminating its “blood lead level of concern” guidance of 10 micrograms per deciliter–recognizing that blood lead levels below that concentration can cause adverse and permanent effects in children. This is a fairly rapid reversal in position by the CDC, who issued a statement in 2005 keeping this level in place. This threshold has been replaced with a reference value currently set at 5 micrograms per deciliter, which is based on the 97.5 percentile of blood lead levels in children ages 1-5. As those blood lead levels continue to decrease, so will this reference value, which the CDC plans to update every four years.
A couple interesting points made by the CDC:
1. Because lead exposure primarily happens in residential settings, and because lead paint was banned in 1978, children in older homes and poorer neighborhoods face greater lead exposure risks. But, this recognition of adverse effects at any level makes lead an issue for all socioeconomic classes. I’m wondering if we’ll see more attention focused on lead as a result of lead not just being an issue in urban, lower-income environments.
2. The CDC’s focus is now on primary prevention–stopping children from getting dosed in the first place. This is a necessary approach because of the recognition that there is no lower boundary to the adverse effects of lead.
The CDC’s new recommendations reflects a continuing public health policy shift–one that moves away from treatment of already-dosed children and towards prevention.The CDC’s recommended approach to implementing primary prevention includes increased enforcement of lead safety laws and housing codes, and elimination of all non-essential uses of lead in products.
You can already see this shift reflected in the recent lead paint Renovation, Repair and Painting standard, and some relatively large fines levied by EPA for failure to disclose lead paint, such as this one at a naval base in New England, and another fine levied against a landlord in Everett this week. I’d expect to see this trend continue, and even increase, depending on agency resources.
One last final note in terms of resources: lead exposure prevention can be cost-effective and provide good bang for the buck. Congress has cut CDC’s budget to address lead in children from $30 million in 2011 to $2 million in 2012. In an era where EPA is contemplating cleanups that will cost hundreds of millions of dollars, often ultimately at taxpayer expense, or where agencies are focused on driving water quality standards down to levels equal to detection limits at potentially great expense to dischargers, I’m wondering if we need to step back and reconsider how resources are allocated, and put things into overall context in terms of public health benefits. Arguments over hypothetical and conservative risk estimates likely will never go away, but when I hear of regulatory actions imposing great cost to avoid miniscule cancer risks, I can’t help but think of how those resources could be better used. I recognize that this is a bit of an apples-and- oranges comparison because of the different regulatory schemes involved, but I can’t help but look at how we are allocating resources and setting priorities, leading me to think that maybe it is time to get back to basics in terms of public health and the environment.