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Airborne Poisons: EPA Turns an Ear to the Lead Industry
by Don Fitz
For almost two centuries evidence has accumulated that lead damages virtually every organ system, including the central nervous system, cardiovascular system, red blood cells and kidneys. As each new set of data arrives, the lead industry intensifies its efforts to confuse the public and divert governmental controls. Recent events repeat the scenario, but with a corporate cynicism that reaches an appalling level. At the same time that new research is confirming the powerful influence childhood lead poisoning has on violent crime and learning ability, industry has argued that the US Environmental Protection Agency (EPA) should do away with standards limiting the amount that they dump in the air.
Lead’s toxicity to those working in the industry has been known at least since 1839.  “As early as 1904, an Australian physician, J. Lockhart Gibson, published an article on the source of childhood lead poisoning among his patients.”  Rick Rabin’s history of the lead industry documents that it was well aware of the dangers by the 1920s. Criticism of the industry was a major factor in the 1928 formation of the Lead Industries Association (LIA) which worked to suppress information whenever it could.
The LIA was highly successful in campaigns to influence public opinion and halt or reverse legislation to regulate lead in paint. When the automobile became omnipresent after WWII, people were ill-prepared to resist leaded gasoline and became subjected to an even greater source of lead poisoning.
The year 1978 is often given as the time that US law banned lead from paint. That interpretation is deceptive. The use of lead in house paint began to decline long before. A zinc-based compound made its debut around 1920 as a substitute for white lead pigments. Latex paint came into use during the 1930s and was the main interior wall paint by the 1950s.  The 1978 ban on the use of lead in paint may have had less to do with a courageous Congress standing up to the paint industry than it did with the paint industry no longer needing lead. Legislation also phased out lead in gasoline, which fell by 70% from 1975 to 1984 and was ended by 1996. [3, 4]
Poisoning at low lead levels
Despite efforts by the industry to discredit research, medical information on lead has resulted in a continuous lowering of blood lead levels considered to be “safe.” Before 1971, a child had to have 60 ug/dL (micrograms of lead per deciliter of blood) to be considered lead poisoned. That year it dropped to 40 ug/dL. The definition of lead-poisoned fell to 30 ug/dL and then to 25 ug/dL. The “level of concern” for lead adopted by the Centers for Disease Control in 1991 was 10 ug/dL. 
The CDC has refused to change that definition for almost 20 years, despite massive evidence that lead has more toxic effects and effects at lower levels than previously thought. Some of the most important work demonstrates how extremely low levels of lead damage intellectual development.
Investigations consistently show that (a) the greater a child’s blood lead level is, the lower is the child’s IQ; and (b) the largest incremental damage to IQ is in the 1–10 ug/dL range (which the CDC does not consider to be a “level of concern”). [6, 7] Typical is an investigation headed by Richard Canfield which found (a) an increase of blood lead from 1 to 10 ug/dL was associated with a decline of 7.4 IQ points; (b) an increase in blood lead from 10 to 30 ug/dL predicts an additional loss of 2.5 IQ points; and (c) the greatest damage to reading and math scores was for blood lead below 5 ug/dL. The authors concluded “that there may be no threshold for the adverse consequences of lead exposure and that lead-associated impairments may be both persistent and irreversible.”  The sentiment that there is no “safe” level of lead is now echoed by experts throughout the field.
…extremely low levels of lead damage intellectual development.
These studies are so powerful that it is easy to neglect recent findings on adults. For example, 2006 research reported in the Journal of the American Heart Association demonstrated that compared to those with extremely low levels, adults with blood lead levels of 3.6–10 ug/dL were 2.5 times more likely to die of a heart attack, 89% more likely to die of stroke, and 55% more likely to die of cardiovascular disease. 
Whither the CDC?
So what is the CDC doing with this accumulating evidence of the toxicity of lead at levels below 10 ug/dL? It is using doublespeak to make the problem worse. Health agencies across the US know full well that the phrase “level of concern” is a technical term referring to a specific concentration of lead but that most people interpret it as a dividing line between “lead-poisoned” and “not lead-poisoned.”
Many agencies do not report the actual blood lead concentration in children and tell parents their child does not have enough lead for a “level of concern” if tests show lead below 10 ug/dL. Almost all parents hear such information to mean, “My child is not lead poisoned.” Since no one tells them that intellectual damage can occur with low levels of lead, parents often conclude that nothing needs to be done to reduce their child’s exposure.
The child may have 2, 4, 6 or 8 ug/dL, all of which can cause physical, mental and behavioral problems; but rather than saying that to the parent, the agency may parrot the CDC’s doublespeak. One physician confidentially said that doctors are aware of this, but public clinics are so underfinanced that they must focus on the traumatic lead levels of 40 ug/dL and above.
It is past time for the CDC to quit exacerbating lead poisoning by playing word games and state that any measurable level of lead in the body constitutes “lead poisoning.”
Have you been hit by lead?
The most dramatic line of research makes a strong connection between lead exposure during childhood and violent crime during adulthood. If you have ever had a gun pointed at you or been attacked, you may have experienced secondary effects of lead poisoning.
…research makes a strong connection between lead exposure during childhood and violent crime during adulthood.
Herbert Needleman showed that 12 to 18 year olds who had been through Pittsburgh’s juvenile justice system were four times more likely than matched controls to have high bone lead concentrations.  Of the 3111 counties in the US, those with the highest murder rates have air lead concentrations four times as high as counties with the lowest murder rates. 
The most fascinating data come from comparing lead exposure during early childhood to crime rates two decades later. Rick Nevin traced lead exposure for over 100 years.  This included two time periods for peak lead: exposure from massive use in house paint during the early 20th century, and exposure from leaded gasoline after WWII. For both, he calculated the amount of lead children were exposed to and murder rates 21 years later.
Figure 12 in his now classic study is amazing. It charts total per capita lead exposure from 1876 through 1984, and superimposed on top of that data is the murder rate 21 years later. The figure shows exposure to lead from house paint increasing through 1916 and a parallel increase in the murder rate (with a 21-year delay). As substitutes for lead in paint were found, exposure declined after WWI and murder rates showed a similar decline (with the 21-year lag). As lead exposure again increased with its use in gasoline, there was again a 21-year lagged increase in the murder rate. Then, lead exposure declined as it was phased out of gasoline during 1975–85. A decline in murder rates 21 years later allowed chest-thumping politicians to spout that their “get tough on crime” programs during the late 1990s were protecting society.
In 2007, Nevin reported data for nine countries that phased lead out of gasoline at different times.  For each country, increases and decreases in gasoline lead were followed by increases and decreases in violent crime — but the effects were only found by using a two decade delay between lead exposure and crime. As insightful as Nevin’s research is, it looks at social averages rather than lead levels of specific children.
That was corrected in the most definitive study to date, published in May 2008 by a team coordinated by Kim Dietrich.  It looked at 250 children born between 1979 and 1984. Each blood lead level increase of 5 ug/dL during early childhood was associated with an increased likelihood of being arrested for a violent crime when 19 to 24 years of age.
The effects of lead on violence are somewhat like alcohol. Alcohol does not automatically cause violence. A passive person will not become violent when drunk. Alcohol inhibits the inhibitors. It interferes with several brain processes, including the production of the brain chemical serotonin, associated with impulse control. A person who has learned to be violent will be less able to control anger when drunk.
Similarly, lead poisoning does not automatically cause violence. But if a lead-poisoned child grows up in a violent society, as an adult the person will be less able to control violent behavior. Being drunk has an acute effect on impulse control. Being lead-poisoned has a chronic effect. Being drunk, being lead-poisoned, and having been exposed to thousands of hours of violent TV is a very bad combination.
Whither the EPA?
Since, by any rational standards, America has violence of epidemic proportions, you might think that an agency charged with protecting public health would vigilantly keep abreast of research on lead poisoning and take actions to protect our well-being. After all, the agency has a full staff to review publications.
At its June 12, 2008 public hearing on air lead standards, the EPA distributed a “Fact Sheet” which revealed just how much the agency has kept up to date.  The “Fact Sheet” indicated it was, in fact, aware of findings on lead poisoning and intellectual development, somewhat familiar with recent research on adult health, and totally clueless concerning new findings of lead’s effects on crime and violence. The vague reference to “delinquent behavior” in its June 2008 document could have come from Julian Chisolm’s 1971 article that I used when teaching nursing school students three and a half decades ago.  It made no mention of the 20-year time lag between lead poisoning as a child and crime as a young adult, which is the hallmark of research since 2000.
Let’s look at why that June 12 hearing took place. It began with the Clean Air Act of 1970, which mandates the EPA to review air quality standards every five years to make sure that the standards reflect current scientific findings. Industry is only allowed to release lead into the air if it is within the maximum allowable levels the EPA sets in the National Ambient Air Quality Standards (NAAQS). Despite continuous new understanding of lead poisoning effects, the EPA has not reviewed its lead NAAQS for 30 years. In 1978, it set the level at 1.5 ug/m3 (micrograms per cubic meter). According to Kathleen Logan-Smith, Executive Director of the Missouri Coalition for the Environment, “Lead pollution comes out of over 16,000 pollution sources, including smelters, refineries, cement kilns and airports.”  Lead is still allowed in aviation fuel.
Violation of Congressional mandates for lead is hardly out of character for the EPA. Children are often poisoned during home renovations that spread lead dust and fumes. In 1992, Congress instructed the EPA to compile lead safe rules by 1996, an order that the agency ignored for 10 years. 
The EPA’s current air quality standard limiting lead to 1.5 ug/m3 is keyed to the CDC’s blood lead standard. That standard was 30 ug/dL in 1978 and the EPA has seen it lowered twice while doing nothing about the NAAQS, indicating that the EPA has even more contempt for childhood health than does the CDC.
The EPA’s inaction on airborne lead particularly angered environmentalists in Missouri. Not only does St. Louis have a very high rate of childhood lead poisoning, Missouri is the source of over 95% of the lead mined in the US. The Doe Run Company’s lead smelter in Herculaneum, Missouri is the only industrial facility that has received a “nonattainment” designation for meeting NAAQS requirements. 
Jack and Leslie Warden lived in Herculaneum for years. Angry that they were forced to move by the town’s extraordinarily high levels of lead, on May 27, 2004 they jointly filed a lawsuit with the Missouri Coalition for the Environment requesting that the US District Court order the EPA to comply with the Clean Air Act and issue updated NAAQS requirements. 
On September 14, 2005, US District Judge E. Richard Webber found “that the EPA has blatantly disregarded Congress’ mandate that the lead NAAQS be reviewed at five year intervals.”  He required the EPA to pay attorney’s fees for those bringing suit and ordered the agency to propose new rules by May 2008, allow public comment for 60 days, and complete a final updated rule by September 1, 2008.
With the rusty wheels of change finally starting to turn, the lead industry zipped into action, outdoing its own history of disregarding public health for over 100 years. “The Battery Council International [BCI] is a trade group of smelters, lead battery makers, distributors and suppliers.”  On July 12, 2006, Timothy J. LaFond, Chair of BCI’s Environmental Committee, wrote the EPA that “lead ambient air concentrations in the United States have been dramatically reduced since 1970.” In what must be one of the most brash polluter recommendations of all time, the BCI spokesperson concluded that the EPA should “delete lead from the list of criteria pollutants.”  That’s right. The lead industry reasoned that since air lead levels have dropped due to taking lead out of gasoline, smelters should be able to put lead back into the air.
With the same steadfast resolve that has characterized the US government’s relationship with the lead industry for most of the past century, in December 2006 the EPA began floating the idea of eliminating air lead standards altogether. [19, 21, 22] That thought flew over the environmental community like a lead balloon. With people writing the EPA that they were madder than hell, the agency did some back-pedaling, some rewording, and, of course, some doublespeaking.
The rule that the EPA proposed for comment at its June 12, 2008 public hearings in St. Louis and Baltimore was as slick as Al Gore’s “opposition” to the East Liverpool incinerator.  Pressured to give the appearance of requiring a huge reduction in lead emissions, the EPA proposed to revise its standard from 1.5 ug/m3 to a range of 0.10 to 0.30 ug/m3, but announced that it would be “taking comments on alternative levels up to 0.50 ug/m3.” 
The tightest standards in the world will be pointless if emissions are not measured.
In plain English this means that the EPA would not incorporate scientific findings that lead is toxic at any level, would propose the lowest reduction it could get away with, and would invite industry to defend the ridiculously high level of 0.50 ug/m3. A broad coalition of environmental groups pointed out that using a “range” of levels is a backhanded way of allowing the maximum of the “range” to become the norm. Though most environmentalists asked for a maximum lead emission of 0.20 ug/m3, some EPA staff conceded that it could be set as low as 0.02 ug/m3. 
Currently, the amount of lead released into the air is calculated as a three-month average, meaning that a dangerous spike of air lead can be covered up by lower readings from adjacent months. At the June 12 hearing, environmentalists also asked for monthly averages of emissions, which would partly reduce the problem of lead “spikes.”
Lead: The gluttony of overproduction
A big problem with current measurement of lead emissions is the very large number of facilities that are nowhere near a lead monitor and whose emissions are unrecorded. The tightest standards in the world will be pointless if emissions are not measured. So it is reasonable to ask for a maximum emission of 0.15 ug/m3 and monthly averages of emissions. But it is also important to insist that the EPA halt the operation of any facility which (a) emits lead if it is located in a state without any lead monitors and (b) emits more than five tons of lead per year if it is not within one mile of a lead monitor.
Looking at lead as one pollutant in a sea of toxins, it is clear that there is not only poorly regulated production — there is vastly too much production. We need to be asking: Is there a need to allow lead mining and lead smelting in the US or to allow US companies to mine lead anywhere in the world? Or, could we reuse the existing mountains of lead instead of throwing them into landfills?
And should companies be allowed to use lead when there are non-toxic or less toxic alternatives? Most important, should we allow industry to churn out unending quantities of consumer goods designed to fall apart in the briefest amount of time? Every product planned to be obsolescent increases the release of toxins (frequently lead) during its life-span of mining, manufacturing, use and disposal.
It is impossible to protect public health unless all consumer goods are manufactured with the lowest toxicity and the longest durability possible. Corporations have long shown themselves incapable of making decisions to protect human health, and a government controlled by corporations cannot possibly protect its citizens from them.
Communities and unions need to begin asking how we can produce fewer goods, produce different goods, and design products that endure. And they need to be asking if they, rather than corporations, should be making decisions concerning all phases of production.
In Greek mythology, the greedy king Sisyphus was doomed to forever roll a heavy stone uphill only to watch it roll down again. If we fail to take decision-making power out of the hands of corporate boards, struggles against toxins merely share the Labor of Sisyphus.
Don Fitz has taught psychology at Washington University, Harris-Stowe State University, University of Missouri-St. Louis and St. Louis Community College at Meramec and Forest Park. He is editor of Synthesis/Regeneration: A Magazine of Green Social Thought and produces Green Time TV in St. Louis. He can be reached at firstname.lastname@example.org
Postscript. The EPA’s October 15, 2008 “Final revisions to the National Ambient Air Quality Standards for lead” brought some positive news. After outcries across the nation, the EPA “revised the level of the primary (health-based) standard from 1.5 ug/m3 to 0.15 ug/m3.” The document openly states that “There is no known safe level of lead in the body,” which is critically important for challenging the CDC criteria that lead levels below 10 mg/dL are not a “level of concern.”
However, the calculation of air lead levels still uses three month averages, which means monthly “spikes” in lead emissions can be downplayed. The new standards only require monitors “in areas with sources of lead emissions greater than” one ton of lead annually, despite the fact that staff recommended monitors when lead exceeded half that amount. This allows a huge amount of lead to flow into the air with no monitoring.
The standards allow states to ignore the regulations for eight years before they must comply. And, of course, there is no guarantee the government will actually do anything to facilities which spew out lead greater than permitted limits.
1. Nevin, R., 2000. How lead exposure relates to temporal changes in IQ, violent crime, and unwed pregnancy. Environmental Research, 83, 1–22.
2. Rabin, R., Fall, 2006. The lead industry and child lead poisoning, Synthesis/Regeneration: A Magazine of Green Social Thought, 41, 2–6.
3. Nevin, R., 2007. Understanding international crime trends: The legacy of preschool lead exposure. Environmental Research, 104, 315–336.
4. Reyes, J. W., 2007. Environmental policy as social policy? The impact of childhood lead exposure on crime. The B.E. Journal of Economic Analysis and Policy, 7 (1), Article 51.
5. Rachel’s Environment and Health News, August 5, 2004. No. 792.
6. Schwartz, J., 1994. Low-level lead exposure and children’s IQ: A meta-analysis and search for a threshold. Environmental Research, 65, 42–55.
7. Lanphear, B.P., Hornung, R., Khoury, J., Yolton, K., Baghurst, P., Bellinger, D.C., et al., 2005. Low-level environmental lead exposure and children’s intellectual function: An international pooled analysis. Envir Health Perspect. 113, 894–899.
8. Canfield, R, Henderson, C.R., Cory-Slechta, D.A., Cox, C., Jusko, T.A., & Lanphear, B.P., April 17, 2003. Intellectual impairment in children with blood lead concentratons below 10 microg per deciliter. The New England Journal of Medicine, 348 (16), 1517–1526.
9. Menke, A., Muntner, P., Batuman, V., Silbergeld, E.K., & Guallar, E., September 18, 2006. Blood lead levels below 0.48 umol/L (10ug/dL) and mortality among US adults. Journal of the American Heart Association, http://circ.ahajournals.org DOI: 10.1161/CIRCULATIONAHA.106.628321.
10. Needleman, H.L., Reiss, J.A., Tobin, M.J., Biesecker, G.E., & Greenhouse, J.B., February, 1996. Bone lead levels and delinquent behavior. Journal of the American Medical Association, 275 (57), 363–369.
11. Stretsky, P., & Lynch, M., 2001. The relationship between lead exposure and homicide. Arch. Pediatr. Adol. Med., 155, 579–582.
12. Wright, J.P., Dietrich, K., Ris, M.D., Hornung, R.W., Wessel, S.D., Lanphear, B.P, et al., 2008. Association of prenatal and childhood blood lead concentrations with criminal arrests in early adulthood. PLoS Medicine, 5(5): e101.doi:10.1371/journal.pmed.0050101
13. Fact sheet: Proposed revisions to the National Ambient Air Quality Standards for lead, June 12, 2008. U.S. Environmental Protection Agency. Distributed at the Public Hearing in St. Louis, Missouri.
14. Chisolm, J. February, 1971. Lead poisoning. Scientific American, 224(2), 15–23.
15. Alert: The U.S. Environmental Protection Agency hearings on the air quality standard for lead, June 12, 2008. Missouri Coalition for the Environment. Distributed at the Public Hearing in St. Louis, Missouri.
16. Fitz, D., May 27–29, 2006. Acceptable levels of lead poisoning? EPA goes lead wild. CounterPunch, http://counterpunch.org/fitz05272006.html
17. Missouri Coalition for the Environment vs. Leavitt, Case No. 4:04CV0660 (U.S. District Court, Eastern District of MO), filed May 27, 2004.
18. Memorandum and Order, Missouri Coalition for the Environment vs. U.S. Environmental Protection Agency, Case No. 4:04CV0660, (U.S. District Court, Eastern District of MO, September 14, 2005, Webber, J.), p 6.
19. Kruzen, T., January 17, 2008. Groups to EPA: Drop that irresponsible idea of eliminating lead air standard, Clear Air Watch Blog. To find out about the BCI go to http://www.batterycouncil.org/AboutUs/tabid/53/Default.aspx
20. LaFond, T.J., July 12, 2006. Letter to Ms. Lydia Wegman (C504-02), U.S. EPA, Office of Air Quality Planning and Standards, Health and Environmental Impacts Division, Research Triangle Park NC 27711
21. Alert: The U.S. Environmental Protection Agency considers eliminating the air quality standard for lead — Public health action needed, 2007. Missouri Coalition for the Environment.
22. Heilprin, H., December 7, 2006. EPA may drop lead air pollution limits. Associated Press, http://www.ap.org
23. In case you’ve forgotten, when Al Gore was running for Vice-President in 1992, he promised to close the infamous incinerator in East Liverpool, Ohio. Once he was in office, all the environmental movement heard was excuses as to why he could do nothing.
24. Associated Press, January 15, 2008. Cited in Kruzen, T., January 17, 2008.
[17 dec 08]