EPA Introduces Strategy for Addressing Lead Exposure, Asks for Input

EPA is accepting comments on draft strategy, currently criticized for treating lead as “legacy” concern and lacking “specifics”
November 10, 2021

The U.S. Environmental Protection Agency has released a draft version of its new strategy to reduce lead exposures in communities around the country and said it will seek input from the communities most affected by lead contamination.

Critics welcomed the call for input, saying the plan does not do enough to cite specific actions the federal government will take to ensure the lead problems present for decades in places like East Chicago, Hammond and Indianapolis, are finally addressed.

The “EPA Strategy to Reduce Lead Exposures and Disparities in U.S. Communities” sets wide-ranging goals to reduce lead exposure in homes, childcare facilities, drinking water and from pollution emissions.

“Communities disproportionally affected by lead contamination, asthma disparities, and the effects of climate change have waited too long for action. Together, we will use the promise of President Biden’s whole-of-government approach to address these issues while also working to eliminate the stark inequities in children’s environmental health across our country,” said EPA administrator Michael Regan.


The plan includes general guidelines for accomplishing those goals, called approaches, that highlight the authority EPA and partner agencies have to achieve those goals, but groups supporting the Biden administration’s goal to reduce lead exposure said the plan is “woefully short on specifics.”

“EPA’s plan commits to being based in science, to centering equity concerns and to strengthen enforcement; all of which would be a welcome change regarding EPA lead regulation. But EPA must explain how it intends to apply those principles when regulating lead in water,” said Julian Gonzalez, legislative counsel for Earthjustice, a nonprofit organization that helps litigate environmental cases.

The group said the EPA’s plan states problems with great detail but does not say how it will address those issues with the same detail.

The group points to the agency’s goals like the reduction of exposure to lead from drinking water sources.

Lead can enter drinking water through old lead pipes, solder, faucets and fixtures.

In adults, lead can cause increased blood pressure, hypertension and other cardiovascular effects, along with decreased kidney function and reproductive problems. In children, lead can cause behavioral and learning problems, lower IQ, hyperactivity, slowed growth and hearing problems.

Black children and children from low-income families have average blood lead levels 13% higher than the national average.

The agency said it would “eliminate all lead drinking water pipes and service lines in the United States” with funding from the American Jobs Plan, most of which was included in the recently passed Infrastructure Investment and Jobs Act, a $1.2 trillion infrastructure package with about $27 billion allotted for the replacement of lead service lines and pipes.

The EPA said it would distribute loans and grants to upgrade water systems, remove lead service lines and support training and technical assistance to test drinking water for lead, prioritizing communities with the highest lead levels and those with environmental justice concerns.

“[The plan] should note how it plans to replace lead service lines regardless of what funding levels are allocated by Congress, or else another generation of children will be drinking lead-contaminated water,” Gonzalez said.

A factor that could complicate the plan’s approach is that very few communities have a complete list of lead service lines still in use and there has never been a record of lead lines installed in homes.

Gabriel Filippelli, director of the Center for Urban Health at Indiana University Purdue University Indianapolis, said communities started mapping service line construction in the 1970s and 1980s.

“We actually have absolutely no idea where most of these service lines might be,” Filippelli said. “I think we have a very inadequate understanding of the distribution of lead in soils, paint and water. And, clearly, we can’t test 5 million soil samples around the state. It just doesn’t work that way.

Filippelli said he believes the EPA’s plan should include funding for better risk assessment tools. He said one of the only ways to know whether there’s a lead problem is if a child is found with an elevated blood lead level.

He said he and other researchers are working on a questionnaire to detect potential lead exposure that is about 75% accurate.

IUPUI also partnered with faith leaders of the Indianapolis Ministerium to distribute free, anonymous lead testing kits to learn more about the distribution of contaminated soil in Indianapolis.

The EPA said it would provide more details on implementation and update the strategy after it receives public comments on the proposal.

The plan will also most likely include the Centers for Disease Control and Prevention’s recently updated blood lead reference value, a screening value to identify children with higher levels of lead in their blood compared to most other children.

The CDC recently reduced the reference value from 5 micrograms per deciliter to 3.5 micrograms per deciliter, the lowest level that can currently be commonly accurately measured in a clinical setting.

The value serves as a guideline for state and other local authorities to set their own action levels for children and could serve as a trigger for future action by the EPA.

The Indiana State Department of Health’s reference value for action is 10 micrograms per deciliter, but the state allows county health departments to act when lower blood lead levels are present.

Filippelli, who also serves as executive director of Indiana University’s Environmental Resilience Institute, said the new reference value will allow nearly all children who show positive results to be referred for follow-up testing.

The new reference value could also affect EPA standards for lead in household paint and soil and air emissions, which could further complicate how the EPA prioritizes contamination sites.

The EPA will accept public comments on the proposed strategy until Jan. 26 online and by mail to U.S. Environmental Protection Agency, EPA Docket Center, Office of Land and Emergency Management Docket, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460.

The agency said it will host listening sessions, engage with communities and organizations with vested interests in addressing lead exposures, and collaborate with federal agencies to identify and incorporate additional opportunities for action before the end of the comment period.

The final lead strategy will be released some time in 2022.

EPA Introduces Strategy for Addressing Lead Exposure, Asks for Input