Opinion: It’s Past Time for Comprehensive Approach to Protect Children from Lead
There is a sense that lead exposure is an issue that has been resolved. But while significant improvements have been made, they are not enough
Have you noticed that the number of articles and reports on lead exposure and drinking water has dwindled? Think back to the Flint, MI, debacle and how it resounded across the country and struck a chord here in New Jersey.
There still are occasional articles about new test results in our schools, and about criminal indictments of regulatory and utility managers in Michigan, but the uproar has subsided. Perhaps it is just the summer doldrums, issue fatigue, or perhaps people assume that action is being taken to solve the problem.
Recent steps in New Jersey may contribute to a sense that the issue is resolved. The state is providing funds and has adopted mandates for testing school drinking water for lead, though this step only identifies the problem and far more funding will be needed for solutions. The state has finally restored some funds to make low- and moderate-income housing lead-safe, after years of limited funding. The New Jersey Department of Environmental Protection (NJDEP) has improved public education regarding lead and is working with water utilities. Some water utilities have applied for low-interest loans to replace lead-based lines, including those in private buildings.
However, the lead problem has not been solved — not even close. Even with all the actions taken so far, we are still in the early stages of greatly reducing ongoing childhood lead exposure in New Jersey, and thus blood-lead levels. Note the word “reducing.” We should never forget that, according to the federal Centers for Disease Control and Prevention (CDC), there is no known “safe” level of lead in blood. If we want our children to be entirely safe from lead, that would mean eliminating lead, not just reducing exposures somewhat.
Lead exposure is so difficult to deal with, in part because responsibility for the issue is spread widely and many of the necessary actions involve private property, often in poorer communities and neighborhoods. Diffuse responsibility, lack of an easy solution, and limited political influence is a tough combination.
We could fill a room with those who have or should have some responsibility for lead exposures. Health science agencies such as the CDC provide critical information on how exposures result in elevated lead levels in blood. The U.S. Environmental Protection Agency (USEPA) and state DEP adopt drinking water requirements to reduce the corrosiveness of drinking water so that less lead is leached into tap water.
The federal government also requires disclosure of known lead-paint risks for housing that is being rented or sold; but the government does not actually require an evaluation or abatement, which is left to the buyer and seller to decide.
The N.J. Department of Community Affairs (DCA) requires certification of contractors who handle lead paint evaluation and abatement, and sets standards for the evaluation and abatement processes. Contractors conduct lead abatement actions, when someone has the funding.
Public health agencies at the community level help educate residents about lead paint and ensure screening of children’s blood levels, and they can order the abatement of lead hazards. They are even allowed to conduct the abatement themselves and bill the property owner, though of course that requires a funding source that most health boards lack.
Physicians are expected to monitor children’s blood lead levels and report elevated findings to the local health agencies, under rules from the N.J. Department of Health and Senior Services (DHSS). The healthcare system is involved in treating acute lead poisoning, but affordability is an issue for many families. Teachers in our schools provide remedial education to help overcome damage to learning abilities, if they are aware of the problem.
School systems must now test their water for lead and take action to better protect their students and staff. Some social service and advocacy organizations do their part to educate the public, promote effective action, and advance remedial activities. Private and public residential landowners also are supposed to be responsible for dealing with lead sources, whether paint or pipes, in housing of every type from single-family homes to public housing projects, but enforcement of the related housing code is a critical issue.
Banks and insurers should be protecting their interests by making sure that properties they finance and insure are lead-safe. And parents play a critical role in ensuring that their children are tested for lead, have proper diets, and are protected from lead poisoning to the extent they can control.
All told, a lot of people and entities have some role in lead, and I’m sure there are others who could be added. Who, then, is in charge overall? Where does responsibility lie for ensuring that the combined efforts of all players actually protect our children? Suddenly that room we could fill with those who have or should have some responsibility for lead exposures goes too quiet. The various people, agencies and organizations each is responsible for acting on their part of the issue. But it is a jigsaw puzzle, not a comprehensive picture, and we know that important pieces are missing.
A standard policy answer would be to identify someone to serve as New Jersey’s lead “czar.” We have seen this many times at the national and state level. The problem is that no lead leader can ensure action. They just become another player in the system.
A better approach would be the adoption of a comprehensive lead action program — not just a plan, but the implementation of that plan, as well — for all aspects of the issue. Existing programs and new ideas could be incorporated as appropriate, including concepts from pending legislation and a draft NJ Strategic Plan for Healthy Homes (prepared for the N.J. Department of Health and Senior Services several years ago).
The planning process should start with the end point: what do we want to achieve regarding lead poisoning? Our health laws focus on a threshold for a blood lead level of 10 micrograms/deciliter, but expected to shift to 5 micrograms/deciliter. But the CDC says no level is safe. What level is generally acceptable to society and by when?
In addition, how can lead safety be linked with the broader issue of healthy housing?
Next, what needs to happen to achieve the safety level we want? Zero risk immediately is impossible, but a steady reduction of risk is feasible. Focusing on the greatest benefits first makes sense, recognizing that these benefits differ by neighborhood and household.
Given the multiple sources of lead exposure for children — such as paint, soil, drinking water, old toys —what specific actions are both needed and technically feasible to achieve the health objectives? We need specifics, not general statements. How quickly can action be taken and benefits achieved? Then, who is most appropriate to carry out each action? How shall we monitor their efforts to ensure that a good job is done? Research and examples from New Jersey and other states are available to help answer all of these questions.
Finally, where do the costs fall? We should recognize that there are large costs to both individuals and society as a whole if we do not address lead exposure, in terms of healthcare, special education, employability, productivity and socialization skills. What makes sense in terms of the split of costs among society — as a moral imperative and a way of reducing other societal costs — and private interests? Where individuals are already financially stressed, how can and should society help?
With a full program defined, the critical pieces should be incorporated into legislation, so that all the players have a playbook. In this manner, the Legislature becomes the decision-making body it should be, and sets the rules for both state government and others. Implementing the program through legislation also reduces, but does not eliminate, the possibility that a new administration might dump the work of its predecessors.
Decades of effort to reduce lead exposures have resulted in significant improvements, but have not achieved enough. We need to adopt and implement a comprehensive approach that will work well. It is past time.