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LEAD Action News Volume 22 Number 4 December 2024 Page 19 of 131
Protecting Kids from Lead: 10 Reasons to be
Thankful
Blog originally published on 4th Dec 2024 at https://unleadedkids.org/10-reasons-to-be-
thankful/2024/12/04/ and reprinted with kind permission of Tom Neltner.
Tom Neltner is national director for Unleaded Kids. He is a chemical engineer and attorney dedicated
to chemical safety issues. He is using his quarter century of experience in government, industry,
academia, and non-profit advocacy to protect kids from harmful exposure to lead.
CLEANUP, FOOD, HEALTH
RISKS, HOUSING, LEAD, PAINT, PIPES, PRO DUCTS, SOIL, WATER, WORKPLACE
FelipeSalgado/Unsplash
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This year has been a great one for actions to protect kids—and adults—from lead exposure, helping
to make families and communities across the country healthier for decades to come. So great that
picking Unleaded Kids’ Top 10 was challenging. Here is the list of what we are thankful for:
1. EPA mandates water utilities remove virtually all lead pipes by 2037.
2. HUD awards historic $395 million to reduce children’s exposure to lead-based paint hazards.
3. EPA reframes dust-lead standards as action levels and strengthens cleanup limits.
4. EPA tightens soil-lead screening levels for industrial sources impacting children.
5. Water utilities notify customers who likely have lead pipes and post maps of its inventory.
6. California strengthens rules to protect workers—and their families—from lead.
7. FDA recalls lead-contaminated cinnamon and inches closer to action levels for baby food.
8. Washington State limits lead contamination in metal cookware.
9. State and federal agencies map lead exposure risks.
10. USAID promotes efforts to reduce lead in consumer products overseas.
1. EPA mandates water utilities remove virtually all lead pipes by 2037. Lead service lines (LSLs)
connect the water main under the street with homes and buildings. They are the primary source of
lead in drinking water. Formula-fed infants are at greatest risk.
In October, EPA improved its Lead and Copper Rule (LCR) by requiring utilities to replace virtually all
LSLs by 2037.1 This timeline is consistent with recommendations by EPA’s National Drinking Water
Advisory Committee in 2015 and EPA’s Administrator in 2018.
EPA estimated that the benefits of the rule will exceed the costs by up to 13 times. The benefits
include up to 1,500 fewer heart-disease related deaths, up to 900,000 fewer babies with low
birthweight, up to 2,600 fewer children with ADHD, and preventing the loss of up to 200,000 IQ points.
Congress’ 2021 Bipartisan Infrastructure Law provided $15 billion in critical funding to support LSL
replacement programs through the Drinking Water State Revolving Fund, which helps keep water
affordable. Thanks to EPA’s new rule and Congressional funding, families across the nation should
eventually be free of the scourge of these lead pipes.
2. HUD awards historic $395 million to reduce children’s exposure to lead-based paint
hazards. An estimated 3.6 million American households have young children who live with lead
exposure hazards. At greatest risk are those in low-income families renting market-rate housing,
where they lack protection from requirements that accompany federal subsidies.
HUD’s Lead Hazard Reduction Program is essential to helping these children since their families
have few options, especially in communities where cleanups are not required, even when a child is
already harmed.
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For these reasons, we give thanks to HUD’s October announcement of $395 million in grants to four
states and 69 local governments to remediate lead-based paint hazards in more than 25,000 homes
with low-income families. HUD also provided $13 million to Missouri and nine local governments to
build their capacity to remediate lead-based paint hazards in the future.
Unfortunately, Congress cut these grant funds by 31% in FY2024 and may cut further in FY2025, so
the most recent round may remain unprecedented.2
3. EPA reframes dust-lead standards as action levels and strengthens cleanup limits. Lead-
contaminated dust on the floor of homes is the primary source of most toddler’s lead exposure. In
October, EPA revised a rule that reframed and tightened its standards for lead-contaminated dust in
homes and child-occupied facilities pursuant to a 2021 order by the Ninth Circuit Court of Appeals.
Compliance with the revised rule is required in January 2026, maybe later where states need to update
their rules.
By switching the key term3 to “dust lead action level,” the agency is more consistent with similar terms
for drinking water, food, and workplaces. This consistency will make it easier to know when EPA
recommends cleanup, while still being clear that a hazard may be present. There is, after all, no safe
level of exposure to lead.
We are particularly thankful that EPA made important changes to its 2023 proposal based on
comments it received. After considering reliability, effectiveness, and safety, EPA tightened the level at
which action was needed4 and relaxed how low labs needed to be able to measure lead. As a result,
the long-term benefits of the rule will exceed the costs by up to eight times. Next up are action levels
for soil lead and for lead-based paint.
4. EPA tightens soil-lead screening levels for industrial sources impacting children. Often,
children’s lead exposure comes from a nearby industrial or commercial source. In this situation,
Superfund and the Resource Conservation and Recovery Act (RCRA) are key tools to clean up the
contamination.
We are thankful that in January, EPA revised its guidance for these cleanups, tightening the
screening levels for the first time in 30 years. The levels were 400 parts per million (ppm). Now, the
level is 100 ppm where other localized sources of lead exposure are present such as lead-based
paint, lead service lines (LSLs), or an area that does not meet lead air standards. For other areas,
the level is 200 ppm.
EPA and states will incorporate the new guidance into its cleanups moving forward, including five-
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year reviews at existing Superfund sites. Overall, the long-term benefits of the change should exceed
the costs by up to 1.8 times.
5. Water utilities notify customers who likely have lead pipes and post maps of its
inventory. Pursuant to December 2020 revisions to EPA’s LCR, customers with a service line that is
or may be an LSL (or in some cases galvanized) should have received notices from their utilities
advising them of the potential risks and encouraging them to act by mid-November.
The utilities also sent their service line materials inventory to the state and made it publicly available. If
they are one of about 1,000 utilities that serve more than 50,000 people, they had to post the
inventory online. Most did this as a searchable map showing the location of each service line and
whether it was an LSL, galvanized requiring replacement, or unknown.
While we don’t yet know how many of the 50,000 utilities complied, we are thankful for those that did
and are undertaking efforts to replace known LSLs and resolve the material of those that are unknown.
6. California strengthens rules to protect workers—and their families—from lead. Workers across
the country are exposed to lead from industries that process materials containing lead or from
construction and maintenance projects that disturb old lead contamination in paint and other
materials. Even at low levels, this exposure harms their hearts, kidneys, and nervous systems. The risk is
greater for pregnant people because lead increases risk of spontaneous abortion, preterm births, and
reduced fetal growth.
In addition, these workers take lead home with them on their body and clothes that contaminate their
vehicles and home, potentially harming their families.
We are thankful that in April, CalOSHA dramatically strengthened its version of the federal OSHA
rules for general industry and construction activities. Those federal rules, written more than 30 years
ago, are woefully outdated and do little to protect worker’s families. CalOSHA’s rule changes,
effective in January 2025, include lowering the action level 15-fold to 2 micrograms per cubic meter of
air, tightening the permissible exposure limit (PEL) five-fold, mandating the use of interim protections
for tasks presumed to exceed the PEL, and strengthening interim protections by requiring employers
to provide washing facilities and ensure their workers use them for hands, exposed arms, and face
before entering eating areas, drinking, smoking, or applying cosmetics, and at end of their shift.
7. FDA recalls lead-contaminated cinnamon and inches closer to action levels for baby
food. Many common food ingredients, including roots crops, spices, and some fruits, are
contaminated from lead in the environment. While the levels are often low, the cumulative impact can
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be significant, especially for babies and toddlers. FDA’s analysis shows that more than 2.6 million
children exceed the agency’s goal of keeping dietary lead intake below 2.2 micrograms of lead per
day.
Last year, FDA forced the recall of applesauce contaminated with lead after finding that lead
chromate had been added to cinnamon used in the product. In 2024, FDA began intensively testing
the popular spice and forced recall of 13 brands where levels were 2 ppm or greater.
As part of its Closer to Zero program, FDA also committed to finalizing action levels for lead (and
cadmium) in baby food by the end of this year, based on its January 2023 proposal. On October 21,
the agency submitted its decision on lead for interagency review.
We are thankful that FDA is acting to limit lead levels in food. We will be more thankful when it fulfills
its commitment and sets protective limits on lead in baby food by the end of 2024.
8. Washington State limits lead contamination in metal cookware. Metal cookware is commonly
used in household and commercial kitchens. Studies by Hazardous Waste Management Program in
King County, WA and the University of Washington showed that some cookware, especially lead and
brass can be highly contaminated with lead that may leach into food resulting in harmful exposures to
children.
Faced with FDA inaction, Washington State legislature responded to the study by unanimously
passing a law prohibiting manufacturers from making, selling, offering for sale, or distributing for sale
or use in the State, any metal cookwarewith a component containing more than 5 ppm of lead by the
end of 2025. Cookware includes any container or device intended for the preparation or storage of
food.
We are thankful that states like Washington are taking on issues and setting standards when FDA
drops the ball.
9. State and federal agencies map lead exposure risks. Virtually every community in the United
States has a lead exposure risk because of decades of use in gasoline, paint, manufacturing, and
consumer products. While our country continues to make progress reducing the risk, much remains to
be done. Maps of that risk and of lead exposures sources help people visually understand their
situation. When they are interactive, they are particularly helpful means to access detailed information
about those risks.
In 2024, EPA, with support from HUD and CDC, published an impressive study identifying the
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nation’s potential lead exposure hotspots that warrant a deeper analysis for targeting lead actions. The
mapping is built on sophisticated models driven by actual data in several states.
In addition to EPA’s effort, Ohio, New Jersey, Indiana and California developed their own models
and maps to help residents better understand the cumulative impact of various sources of lead
exposure.
We are thankful for their efforts to make the information more accessible to all and anticipate seeing
more in the coming year.
10. USAID promotes efforts to reduce lead in consumer products overseas. The U.S. has made
tremendous strides in protecting Americans from lead exposure. Unfortunately, developing countries
have only begun to take on the issue, often allowing lead intentionally added to paint, spices, and
other consumer products. In addition, industrial operations, especially those that recycle lead, spread
lead contamination through neighboring communities. A staggering 1.6 million lives are
lost worldwide due to lead exposure.
In 2024, USAID undertook a promising new effort to reduce lead in consumer products, such as spices
and cookware, in developing countries. The potential benefits are huge, topping $1 trillion annually,
with only a relatively small investment. We are thankful that USAID partnered with UNICEF and
others to provide this bridge to protecting public health on a global scale. And because these
contaminated products often make their way into our country, the effort will help protect children
here.
1. Utilities can take longer than 2037 if: 1) At least 39% of their service lines must be replaced and
they convince state regulators they need more time; or 2) current and future property owners
deny access to the LSL despite repeated efforts.
2. The total exceeds the $314 million awarded by HUD in 2019 to 77 state and local
governments.
3. The previous terms were hazard standard and clearance level.
4. The tightened from: 1) 5 micrograms per square foot (µg/ft2) for floors, down from 10; 2) 40
µg/ft2 for window sill, down from 100; and 3) 100 µg/ft2 for window troughs, down from
400.
