Viewpoint -- Let's Take a Closer Look at Upcoming Lead Emissions Regulations

Oct. 6, 2008
EPA's proposed regulation focuses too much on yesterday's problems and virtually ignores today's concerns

Over the last 30 years, government and industry effort to reduce lead emissions ranks as one of the nation's great environmental success stories. Air lead levels have dropped 98% since 1978, with lead emissions decreasing from 74,000 tons annually three decades ago to 1,300 tons a year. Most important of all, blood-lead levels in children have plummeted -- from a mean level of over 14 micrograms per decaliter in 1976 to well less than 2 today.

The phase-out of leaded gasoline in the Eighties deserves much of the credit for reducing airborne lead levels. But industry, including the battery industry, has contributed to these environmental gains. Roughly 84% of the lead used in the United States goes into batteries and that percentage is likely to increase. Yet less than two percent of lead in the air comes from battery makers. Roughly a third of lead emissions don't come from manufacturing facilities. Half the sources that emit greater than five tons of lead per year are mobile sources, particularly non-commercial aircraft. Most important: According to government data, the most common source of children's lead poisoning is the lead in paint, lead-contaminated-dust and lead-contaminated soil.

These numbers are important because the Environmental Protection Agency will issue new lead emissions regulations by October 15. EPA's proposed regulations would tighten the National Ambient Air Quality Standard for lead. Driving EPA's push for stricter regulations is the agency's growing concern about the effect of lead exposure on children. We know the most at-risk children are those living in areas where 60% of the population lives in poverty.

EPA's effort to reduce lead poisoning in children is certainly praiseworthy. The agency's call for more stringent air emissions standards is based on a considerable amount of data developed since the agency last regulated lead in 1978. Unfortunately, there is a disconnect between EPA's goal and its solutions. EPA's proposed regulation focuses too much on yesterday's problems and virtually ignores today's concerns.

EPA's final rule must protect the most at-risk children from lead poisoning. These children live in major cities and high-poverty areas where the danger from lead poisoning comes from deteriorating lead paint, lead-contaminated dust and lead-contaminated soil, including soil still contaminated by the now-banned lead gasoline. EPA must implement a greatly expanded and more targeted air lead monitoring program in those cities and poor areas where the most at-risk children live.

Unfortunately, EPA's proposal will not accomplish this task. EPA emphasizes the monitoring of industrial facilities -- no longer the major source of lead emissions -- and requires only a small network of monitors in urban areas. Given its proposed monitoring requirements, EPA may be unable to collect the basic data needed to attack lead pollution. For example, EPA would require only a single monitor in Michigan, two in Illinois, and three in New York. More monitors are needed for EPA to address the children's health concerns.

States could comply with EPA's proposed requirements by putting a single monitor in each city with one million or more people, a total of 50 population-based monitors in urban areas across the entire country. No monitors would be required in the highest risk areas where more than 60% of children live in poverty and only a handful of monitors would be located in areas where more than 25% of the children are poor. Yet children in these counties are the ones most at-risk of lead poisoning. A monitoring network aimed at protecting the most vulnerable children demands more monitors in cities and many more monitors in high poverty areas where a disproportionate number of African American and Hispanic children live.

EPA also must place these monitors in urban areas, not suburbs, preferably in locations as close to children's activities as possible. Too often, the monitors have been placed on rooftops or along paved residential areas in newly developed neighborhoods, not near playgrounds, sports facilities, and roadways or housing areas where lead paint is a problem. These monitors must be roughly placed at the height of a child.

Let me be clear. I am not recommending that the monitoring of industrial facilities be stopped. If factory emissions are not properly contained, EPA monitoring makes sense. But most industrial facilities have been appropriately regulated for three decades. Tough emissions standards for these plants are justified and the lead industry will comply with EPA requirements. But industry compliance alone will not allow EPA to meet its goal.

EPA should be proud of its success in reducing lead emissions and improving children's health. But just tinkering with same approach is not enough. PA must employ new tactics to reduce lead poisoning. The new regulations must protect the most at-risk children. EPA should adopt a greatly expanded and highly targeted monitoring system in urban areas and those pockets of poverty where at-risk children live. Increased monitoring will give EPA the tools needed to reduce lead poisoning in children.

Tim Lafond is chair of the Battery Council International's environment committee and executive director of Environmental Engineering and Risk Management at Johnson Controls Inc.

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