What Happened
At a December 11 meeting, CDC’s Lead Exposure Prevention Advisory Committee (LEPAC) adopted an impressive draft report that calls for measures to protect adults from the harmful effects of lead exposure.1 The report makes 16 groundbreaking recommendations with detailed justifications for each.
Key drivers for action were the recognition that lead exposure is a cardiovascular risk factor on par with high cholesterol, smoking, and high blood pressure and that risk “has received relatively sparse attention in health professional education and outreach to the lay public.” LEPAC was also concerned about lead’s risk to both pregnant people and their fetuses.
The magnitude of lead-related risk is on par with that of other prominent cardiovascular risk factors, such as elevated cholesterol, smoking, and hypertension, that have been the focus of extensive public health concern.
from the LEPAC Draft Report
In October, EPA quantified the benefits of reducing lead-related cardiovascular disease mortality when it finalized two major rules that tightened dust lead action levels and mandated removal of virtually all lead pipes. The estimated benefits for each rule far exceeded the costs of those rules.
The recommendations include:
- Recognize and emphasize the cardiovascular disease risk in preventive health policies and communications; take decisive and consequential actions when adult blood lead levels are at or above 10 µg/dL.
- Combine adult and child blood lead surveillance systems at federal, state, and local levels; improve national and state Adult Blood Lead Epidemiology and Surveillance (ABLES) programs, including performance measures, data management, and funding.
- Use new California OSHA standards as a model for feasible health protection because the federal standards fail to protect workers.
- Encourage occupational physicians to exercise their discretionary authority to recommend medical removal and other protective measures at blood lead levels lower than OSHA limits.
- Eliminate all unnecessary workplace and commercial uses of lead where substitution of safer alternative materials is possible and feasible.
- Increase compliance with EPA’s Lead-Safe Renovation, Repair and Painting (RRP) rule.
- Mandate lead hazard mitigation activities for permits and inspections conducted in accordance with model codes of the International Code Council.
- Offer no-cost blood lead screening to uninsured or low-income adults.
- Improve compliance with CDC and the American College of Obstetricians and Gynecologists (ACOG) recommendations for blood lead screening of pregnant people and track success through healthcare performance measures.
Why it Matters
LEPAC gave seven specific reasons to support its call for action:
- “A prominent endpoint of concern is death, as opposed to subtle or subclinical effects on organ system function that are often sufficient for public health and regulatory action.”
- “The epidemiological evidence that associates this outcome with lead exposure is derived from multiple large, high quality prospective cohort studies that extensively controlled for confounding and bias.”
- “This epidemiological evidence is coherent with clinical and experimental findings that demonstrate plausible modes of action at consistent lead doses.”
- “Because the background risk of cardiovascular mortality in populations with this ongoing extent of lead exposure (largely but not exclusively in the workplace) is high, the absolute increase in mortality may be substantial.”
- “The magnitude of lead-related risk is on par with that of other prominent cardiovascular risk factors, such as elevated cholesterol, smoking, and hypertension, that have been the focus of extensive public health concern.”
- “Levels of chronic adult lead exposure linked to this risk remain prevalent in many workplace settings.”
- “The observed risk of cardiovascular mortality associated with blood lead concentrations ≥ 10 µg/dL does not establish the absence of risk at lower blood lead concentrations.”
Our Take
We fully support LEPAC’s recommendations to CDC and encourage the agency to act with urgency given the risks. The two years LEPAC invested in the comprehensive report was worth the wait.
We also encourage all who seek to protect people from lead to consider the recommendations now and not to wait for federal action. These state, local, and private actions will serve as models to help the federal government to act when it is able.
Unleaded Kids also asked CDC to:
- Encouraged CDC to closely review ACOG’s risk factors because they have not been validated and are hard to apply in practice even for folks knowledgeable on issue.
- Finalize its Lead Exposure Risk Index presented by CDC at a December 2021 LEPAC meeting so drinking water utilities could add it to their maps of lead service lines to avoid the misperception that lead pipes are the sole or primary source of lead exposure. Indiana and California have their own helpful examples.
- Encourage rather than discourage data sharing with EPA and HUD so they can take action to protect families from lead.
- Consider redefining the Blood Lead Reference Value as an “action level” as other federal agencies have done for dust-lead, food, water, and workplaces. This approach would better describe the purpose of the BLRV and be consistent with other agencies, making it easier to communicate.
- LEPAC approved the report but asked the workgroup that wrote the report to clarify three areas: 1) reference EPA analysis to support lead in water and dust rules that quantified the health benefits of reducing adult exposure to lead in terms of fewer cardiovascular disease deaths, and fewer low birth weights; 2) drop call to link clinical lab certification to compliance with state-mandated blood lead reporting requirements; and 3) include local agencies increasing compliance with lead-safe renovation, repair, and painting rule. ↩︎