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Threats or Promises: Which Way for the Trump Administration on Childhood Lead Poisoning Prevention?

Recent news articles suggest that Trump’s EPA hopes to drastically cut funding and staff for its lead poisoning prevention programs ("EPA Memo Outlines Plans to Defund Lead-Paint Program," in Remodeling, April 4; and "Trump’s EPA Moves to Dismantle Programs that Protect Kids from Lead Paint," in The Washington Post, April 5). This follows on the heels of a high-level meeting between the EPA’s new administrator, Scott Pruitt, and the National Association of Home Builders (NAHB). NAHB complained about so-called “excessive” regulations, specifically EPA’s Renovation, Repair, and Painting (RRP) Rule

But it was exactly inadequate regulations that led to the Flint crisis and others like it, such as the East Chicago disaster in Indiana, the vice-president’s home state.
 
The fact is that congressional action and regulations have worked: Blood lead levels in the nation’s children have been greatly reduced  as a result of the implementation of statutes and regulations (see "U.S. Policies vs. Children's Average Blood Lead Levels" below). When we as a nation mandated the removal of lead from food canning, gasoline, new residential paint, plumbing and other sources, all through regulations, it worked. If anything, the regulations should be strengthened, not weakened, because over half a million children still have blood lead levels above the CDC reference value.1 

Some industries have supported these regulations over the years,2 but a few others have actively opposed them.3 Most recently for example, the National Association of Home Builders (NAHB) wants the EPA’s RRP regulation restricted to only pre-1960 housing, even though lead paint was not banned (by regulation) until 1978. They want “training” of their contractors to be only online, when in fact construction contractors don’t really learn that way. They want a new cost-benefit analysis, even though many previous studies have already shown that the benefits far outweigh the costs.4, 5 NAHB already succeeded in previous years in eliminating a dust testing requirement that has existed for years in federally assisted housing rehab work with scientifically proven positive results.6 (Children’s blood lead levels in assisted housing are lower than in non-assisted low-income housing, and dust testing [dust is one of the main ways children are exposed] is the major reason why). NAHB should protect the interests of its members by ensuring that homes are safe, not cutting corners and weakening laws and regulations that, if anything, need to be strengthened. And it should work to ensure that its member contractors don’t inadvertently do sloppy work that can cost $100,000 per house to clean up.7

Furthermore, preventing childhood lead poisoning not only protects children, it will create at least 75,000 good-paying jobs.8

During his campaign, the president promised to fix things that don’t work right. What better example is there that lead poisoning needs to be fixed than the 24 million homes that still have lead paint hazards, or the 6-10 million homes that still have lead water pipes? The solution is not to weaken regulations or to cut budgets but to strengthen them, putting the resources in place to end this preventable disease. Lead problems are a sign of our crumbling infrastructure, something the president also vowed to fix. We think that an infrastructure bill should include lead poisoning prevention. 

At HUD, the new Secretary, Dr. Ben Carson, promised to “enhance” lead poisoning prevention and healthy housing, proposing to increase the budget for that program from $110 million to $130 million. But at the same time, the proposed HUD budget wipes out the multi-billion-dollar Community Development Block Grant (CDBG) program. Many local jurisdictions use CDBG to provide their local “match” funding, anywhere from 10% - 25%, for lead hazard control. So, even though the proposed increased funding for the lead program is welcome, it appears that with the CDBG proposed elimination, the net effect will reduce, not increase, the total HUD resources to protect our children from lead poisoning. Why give with one hand only to take away more with the other? 

The National Safe and Healthy Housing Coalition has produced a number of recommendations that will protect our children

We urge the new administration and the new Congress to act on those recommendations to improve (not weaken) regulations and to propose a budget that will get the job done.

Instead of paying over $50 billion a year for lead poisoning, let’s solve the problem, not eliminate EPA programs or reduce HUD funding. At its beginning, the Flint fiasco was supposedly an attempt to save money, and NAHB’s wishes sound just like that, don’t they? We cannot afford another Flint, and we cannot afford to continue to pay the high costs of needlessly poisoned children. In Flint and across the nation, we will now spend far more now than had we acted to solve the problem in the first place. And we do know how to solve it. We should act on what we know, put our people to work, protect our children, and stop wasting money by caving in to a few narrow short-sighted industries at the expense of the rest of us.





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1 Wheeler, W., & Brown, M. J. (2013, April 5). Blood lead levels in children aged 1–5 years — United States, 1999–2010. Morbidity and Mortality Weekly Report (MMWR), 62(13), 245-248. Retrieved April 6, 2017, from https://www.cdc.gov/mmwr/preview/mmwrhtml/mm6213a3.htm

2 National Safe and Healthy Housing Coalition. (2016). Declaration of the Lead and Environmental Hazards Association. Retrieved April 6, 2017, from  http://www.nchh.org//Portals/0/Contents/LEHA_Declaration_2016.pdf 

3 Jacobs, D. E. (2016 July-August). Lead poisoning: Focusing on the fix. Journal of Public Health Management and Practice, 22(4):326-330. doi: 10.1097/PHH.0000000000000430. Retrieved from http://journals.lww.com/jphmp/Citation/2016/07000/Lead_Poisoning___Focusing_on_the_Fix.2.aspx
   
4 Gould, E. (2009, July). Childhood lead poisoning: Conservative estimates of the social and economic benefits of lead hazard control. Environmental Health Perspectives, 117(7), 1162-1167. Retrieved April 6, 2017, from https://ehp.niehs.nih.gov/wp-content/uploads/117/7/ehp.0800408.pdf

5 Nevin, R., Jacobs, D. E., Berg, M., & Cohen, J. (2008, March). Monetary benefits of preventing childhood lead poisoning with lead-safe window replacement, Environmental Research, 106(3), 410-419. Retrieved April 6, 2017, from http://www.ncbi.nlm.nih.gov/pubmed/17961540
 
6 Ahrens, K. A., Haley, B. A., Rossen, L. M., Lloyd, P. C., & Aoki, Y. (2016, November). Housing assistance and blood lead levels: Children in the United States, 2005-2012. American Journal of Public Health, 106(11), 2049-2056. Retrieved April 6, 2017, from https://www.ncbi.nlm.nih.gov/pubmed/27631737
 
7 Jacobs, D. E., Mielke, H., & Pavur, N. (2003, February). The high cost of improper removal of lead-based paint from housing: A case report. Environmental Health Perspectives, 111(2), 185-186. from https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1241348/
 
8 National Center for Healthy Housing & National Safe and Healthy Housing Coalition (2017, February). Find It, Fix It, Fund It: A lead elimination action drive: Policy recommendations to Congress and the new administration. Retrieved April 6, 2017, from http://bit.ly/FFFAdmin

9 Jacobs, D., & Weinberg, A. (2017, February 22). Infrastructure and mortgages: What about the kids? National Center for Healthy Housing website. Retrieved April 6, 2017, from http://bit.ly/Infra_Kids



Dr. David Jacobs, former Director of the Lead Poisoning Prevention Program at the U.S. Department of Housing and Urban Development, is the Chief Scientist for the National Center for Healthy Housing and an adjunct professor at the University of Illinois at Chicago School of Public Health

Infrastructure and Mortgages: What about the Kids?


During the 2016 election season, Donald Trump (the Republican presidential nominee, now president) proposed spending $1 trillion dollars on infrastructure to put people to work and rebuild the sinews of the nation. Democrats have also called for infrastructure improvements. Those improvements must include making our homes and schools safe for our children. In its recent (January 2) editorial, "Housing that Ruins Your Finances and Your Health," The New York Times wrote, “One solution would be for Fannie Mae to eliminate dangerous lead conditions in foreclosed homes.” But lead requirements are antiquated or nonexistent not only at Fannie Mae but also at Freddie Mac and HUD’s FHA single-family mortgage insurance program. These federal housing programs are the only ones that were not reformed back in 1999 and are long overdue to be fixed.

In years past, both parties worked together to reduce childhood lead poisoning. But Flint is only the tip of the iceberg, and parents of lead-poisoned children are demanding that we do more to put a stop to the needless suffering. Lead poisoning costs us an estimated $50 billion annually for healthcare, substandard school performance, and lost work productivity (2008 dollars).1 The real tragedy is that we know how to fix lead hazards. The disasters in Flint and elsewhere could have been prevented and will now cost much more than if we had made the necessary upfront investments and reforms. The inadequate lead requirements at FHA, Fannie Mae, and Freddie Mac should comply with HUD lead-safe housing regulations, but they currently do not.

Traditionally, infrastructure spending only goes for roads and bridges and the basic equipment and structures that are needed for a country to function properly. But many are surprised to learn that the lead services lines bringing water into their homes are NOT part of the “infrastructure” and that the burden was on families to replace them. They are also surprised that home inspections required by mortgage companies do not include lead inspections. 

We think infrastructure and federally guaranteed mortgages should be used to make our homes safe for our children. Indeed, we have “shared” our homes with guests and friends and, of course, our families. But 37 million homes built before 1978 have lead paint,2 and at least six million homes have lead water service lines. This “shared” lead has poisoned millions of our children, sometimes poisoning one child after another as one family leaves and another moves in. Existing FHA, Fannie, and Freddie underwriting standards are part of the problem, but they could be part of the solution.

The biggest culprit is old single-pane painted windows, which have the highest lead paint and lead dust levels of any building component. Replacing windows is already a proven strategy. In a pilot program, Illinois replaced lead-contaminated windows in Peoria and Chicago in 500 homes,3 resulting in huge and sustained lead dust reductions not only on windows but also on floors; and many other studies have reached similar conclusions.

The time has come to replace all those old contaminated windows, those lead drinking water pipes, and the other lead hazards in our homes. Enormous benefits follow if infrastructure funds are used to address lead in homes:
  • First, over 75,000 jobs – good-paying jobs for both made-in-America window manufacturing and installation workers;
  • Second, increased property values anywhere from $5,900 to $14,300 per home4
  • Third, a return on investment of at least $17 per dollar spent on lead remediation or removal5
  • Fourth, up to $500 per household saved each year on reduced fuel bills, because new windows are more energy efficient.6 
With the right infrastructure improvements, we can all share safe drinking water and lead-safe homes. 

The evidence is clear – whether in small towns or big cities, rural or urban: We all win when we eliminate lead hazards and protect our children. Our traditional approach has been to respond only after a child is poisoned, but there is no reason to wait until the damage has already been done. We should test our homes and schools, not just our children’s blood. And we should insist that housing finance institutions like FHA, Fannie, and Freddie do the right thing and eliminate those hazards before children are poisoned.

As part of our new national infrastructure initiative, let’s include solving the lead problem. We urge the new president and Congress to protect our children. Let’s not wait for another Flint or another poisoned child. Get Fannie, Freddie, and FHA to do the right thing. Get rid of those old lead-contaminated windows and old lead pipes and put our people back to work to protect our children and our future.

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1 Tresande, L., & Liu, Y. (2011, May). Reducing the staggering costs of environmental disease in children. Health Affairs 30(5), 863. Retrieved February 21, 2017,
from http://content.healthaffairs.org/content/30/5/863.long
2 Cox, D. C., Dewalt, G., O'Haver, R., Salatino, B. (2011, April). American healthy homes survey: Lead and arsenic findings. Washington, DC: U.S. Department of Housing and Urban Development. Retrieved February 21, 2017, from  https://portal.hud.gov/hudportal/documents/huddoc?id=AHHS_Report.pdf
3 Jacobs, D. E., Tobin, M.,Targos, L., Clarkson, D., Dixon, S. L. Breysse, J., et al. (2016, September-October). Replacing windows reduces childhood lead exposure: Results from a state-funded program. Journal of Public Health Management & Practice, 22(5), 482-491. Retrieved February 21, 2017, from https://www.ncbi.nlm.nih.gov/pubmed/26910871
4 Nevin, R., Jacobs, D. E., Berg, M., & Cohen, J. (2008, March). Monetary benefits of preventing childhood lead poisoning with lead-safe window replacement, Environmental Research, 106(3), 410-419. Retrieved February 21, 2017, from http://www.ncbi.nlm.nih.gov/pubmed/17961540
5 Gould, E. (2009, July). Childhood lead poisoning: Conservative estimates of the social and economic benefits of lead hazard control. Environmental Health Perspectives, 117(7), 1162-1167. Retrieved February 21, 2017, from https://ehp.niehs.nih.gov/wp-content/uploads/117/7/ehp.0800408.pdf
6 Nevin, R., Jacobs, D. E., Berg, M., & Cohen, J. (2008, March). Monetary benefits of preventing childhood lead poisoning with lead-safe window replacement, Environmental Research, 106(3), 410-419. Retrieved February 21, 2017, from http://www.ncbi.nlm.nih.gov/pubmed/17961540



Related: Portuguese Translation
Infraestrutura e hipotecas: E as crianças: "Infrastructure and Mortgages: What about the Kids?" was translated into Portuguese by Artur Weber and Adelina Domingos. Note that this article was not translated by NCHH; therefore, we cannot be responsible for any errors or omissions in the translation. [url]


 
Dr. David Jacobs, former Director of the Lead Poisoning Prevention Program at the U.S. Department of Housing and Urban Development, is the Chief Scientist for the National Center for Healthy Housing and an adjunct professor at the University of Illinois at Chicago School of Public Health

Anita Weinberg is a Clinical Professor and the Director of the ChildLaw Policy Institute at Loyola University Chicago School of Law, which spearheaded lead poisoning prevention efforts in Illinois for over 10 years.

Taking Action: HUD's Lead Poisoning Prevention Announcement – June 13, 2016

Today, Department of Housing and Urban Development (HUD) Secretary Julián Castro issued welcome news about lead poisoning prevention, continuing the department’s leading role. He announced a series of HUD lead poisoning prevention initiatives as part of a "Lead-Safe Housing, Lead-Free Kids" toolkit. His goal that every child in this great nation must be safe from lead poisoning is exactly the right one. His announcement of additional funding to help local jurisdictions create lead-safe homes is also welcome news; those funds will enable thousands of children to live in lead-safe homes for decades to come

The announced initiatives track closely with many of the goals of the "Find It, Fix it, Fund It Lead Elimination Action Drive" (#findfixfund) launched last month by the National Center for Healthy Housing (NCHH) and the National Safe and Healthy Housing Coalition (Coalition). Indeed, Secretary Castro's announced toolkit addresses:

  • Finding lead hazards: improving lead paint hazard assessments and identifying water hazards in HUD-assisted housing, as well as identifying hazards in private-sector housing;
  • Fixing: updating standards to match recent science and better protect children; developing mechanisms and guidance to address lead hazards in public and assisted housing more quickly and effectively; and providing millions of dollars in grants for lead-hazard control in privately owned low-income housing, where the risks are greatest;
  • Funding: calling on philanthropic partners to join the effort to eliminate lead poisoning.
The announced initiatives include urgently needed actions, such as anticipated regulatory changes to HUD's Lead-Safe Housing Rule, to align the blood lead level requiring response in assisted housing to the CDC reference level, lowering it to 5 μg/dL (micrograms per deciliter). These rule changes are currently being reviewed by the Office of Management and Budget (OMB), and we call for quick release to ensure children are protected. In the meantime, we urge local housing and health agencies to adopt the CDC level; nothing in the current regulation prevents local authorities from taking such action.

Secretary Castro also announced efforts to carry out more validated lead risk assessments in federally assisted housing. We hope that the initiatives announced will result quickly in lead risk assessments being required in all federally assisted housing including pre-1978 Section 8 Housing Choice Voucher program homes in which children under six reside or are expected to reside. Currently, only visual assessments are required in the voucher units, which cannot measure the presence of lead dust hazards. We urge Congress to provide needed direction and funding so that HUD can implement these protections for children.

The toolkit also includes development of a consistent standard for and response to water quality issues. We appreciate this initiative and encourage HUD to carry out testing water for lead, a relatively inexpensive procedure, as part of HUD inspections and assessments and to coordinate this testing with local health and water authorities.

We encourage HUD to build on the critical steps announced today by updating the nation's Healthy Homes Survey, which estimates the number of houses at risk for both lead and other housing-related diseases and injuries. Furthermore, we call for the creation of a plan to identify specific locations of both lead-based paint and lead pipes in all the nation's housing stock, so that we know where the lead hazards are. This would supplement CDC's efforts to provide GIS mapping of elevated blood lead levels called for by the Senate appropriations committee last week in its report language for the health appropriations bill.  

In addition to addressing public housing, Castro's announcement includes efforts to remediate lead hazards in low-income private sector housing where the risks are greatest. He announced $46.5 million in new lead hazard control grants to 15 state and local jurisdictions, with millions more to follow in the coming months.

In a very positive step, the toolkit encourages interagency collaboration with CDC and EPA on lead poisoning prevention. The Coalition and NCHH strongly support this and urge the Administration to convene a cabinet-level interagency task force to develop and implement a plan to eliminate lead poisoning. One us (Jacobs) participated in the prior such presidential task force in 2000, but Congress didn't provide adequate funding to carry out the plan and met the goal of eliminating lead poisoning. The plan and funding numbers need to be updated, and we must commit ourselves as a nation to provide the resources to get the job done. The savings will be enormous‎ – HUD's lead hazard control program is estimated to have a return on investment of at least $17 per dollar spent.

Indeed, both Secretary Castro and I would be the first to acknowledge that the goal of protecting all children from lead poisoning will not be achieved at current funding levels. That is why the NCHH and the Coalition and others have been working with Congress to increase funding. And we have had some success. Committees in Congress have provided for an increase in $50 million for HUD’s lead poisoning prevention efforts in both public and private housing. The Coalition has requested that HUD’s program be increased from $110 million last year to at least $230 million – a funding level drawn from the interagency plan on lead developed 15 years ago. There is simply no excuse to permit this problem to continue for even more decades into the future; we know how to solve it, and we should act on what we know. We need to #findfixfund: Find exactly where the lead hazards are, fix them using both short- and long-term proven methods, and obtain the funding to make it a reality.
 
Finally, the Secretary’s call means that all of us must do more. That means the private sector should contribute to the solution, as should philanthropy. We need real partnerships with housing, medical, public health, financing, community development, environmental, construction, inspection, and other allied professions – and, of course, parents and community groups. All of us can and must redouble our efforts to end this entirely preventable disease.

If you're attending the National Environmental Health Association/HUD conference in San Antonio this week, we encourage you to join our "Find It, Fix It, Fund It" meeting Tuesday, June 14, 2016, at 4:50 p.m. in conference room 11, where we'll work together on a plan to eliminate lead poisoning.

Fund Healthy Housing NOW!

ACT NOW to ensure continued funding for HUD’s Office of Lead Hazard Control and Healthy Homes and CDC’s Healthy Homes and Lead Poisoning Prevention Program!

The home is the most dangerous place for U.S. families. Nearly six million families live in housing rivaling that of developing countries, with broken heating and plumbing, holes in walls and windows, roach and rodent infestation, falling plaster, crumbling foundations, and leaking roofs. Millions more in all 50 states live in housing with serious health and safety hazards including mold, exposed wiring, radon, unvented heaters, toxic chemicals, broken stairs, missing smoke detectors, and other hazards. Home-based interventions to address health hazards improve health and have a large return on investment: Each dollar invested in lead paint hazard control results in a return of $17 to $221, and each dollar invested in asthma home-based interventions that include education and remediation results in a return of $5.30 to $14.00.

That's why it makes both great common sense and great fiscal sense to direct more funding to the critical government programs that invest money in America's future by making homes safer and healthier. Unfortunately, these programs are always in serious danger of debilitating budget cutting.

Please take these simple steps now to ensure healthy homes and lead hazard control and lead /poisoning prevention programs continue!


STEP 1: SIGN your organization on to the attached letter to Congress for HUD and CDC funding.

Click here to sign on to the attached letter. And forward these links to your networks!


STEP 2: CALL your representative in the U.S. House!

1. Call the U.S. Capitol switchboard at 202.224.3121 and ask to be connected to your representative. (If you don't know who your representative is, the switchboard can tell you based on your address.)

2. Ask to speak with the staff person who handles the health or housing issues for the office.

3. When you reach or leave a message for the staffer (or speak to the receptionist if the staffer is not available), tell him or her:

  • "I'm calling to urge Representative [representative's last name] to sign on to the Congresswoman Slaughter sign-on letter in support of healthy homes and lead poisoning prevention funding for HUD and CDC. The sign-on letter deadline is March 19.
  • "I also urge the representative to submit a request to the health appropriations subcommittee to fund CDC’s Healthy Homes and Lead Poisoning Prevention Program at $29 million.
  • "These funds will ensure the protection of over 500,000 lead-poisoned children who need CDC-funded services.
  • "Thank you!"

STEP 3: Call your senators! (Coming soon!)

Only you can help us win this budget battle.

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