Engaging other Lead Poisoning 

Prevention Programs

• The Need
• State Examples     
• Local Examples               
• Opportunities                 

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A drinking water utility’s core expertise is delivering water to its customers. Other programs, both government and non-profit, in the community may have greater expertise when it comes to housing, health, and lead poisoning prevention. This is also true at the state level where one-third of the state drinking water programs are based in the health department while the balance are in environmental agencies. When these programs collaborate to accelerate lead service line (LSL) replacement, the effort is likely to be more effective.

​To identify potential partners, it is helpful to understand the federal lead poisoning prevention programs beyond drinking water. At the Environmental Protection Agency (EPA), there are programs to address lead-based paint, air emissions of lead, and contaminated waste sites involving lead. The Centers for Disease Control and Prevention (CDC) and Department of Housing and Urban Development (HUD) also have programs dedicated to reducing exposure to lead. In addition, the Occupational Safety and Health Administration (OSHA), Food and Drug Administration (FDA), Consumer Product Safety Commission (CPSC), and Center for Medicaid and Medicare Services (CMS) have significant requirements regarding lead.
 
All of these agencies are represented on the President’s Task Force on Environmental Health and Safety Risks to Children. In 2000, the Task Force developed a strategic plan to eliminate lead poisoning as a public health problem. The Task Force published an inventory of key federal programs related to lead in November 2016. In December 2018, the Task Force released a “Federal Action Plan to Reduce Lead Exposure.”  

The lead-based paint programs at HUD and EPA significantly overlap with EPA’s lead in drinking water program because both lead paint and lead pipes:

• Represent significant legacies of past use of lead;
• Require involvement from the resident and property owners to resolve; and
• Are most common in older homes with lead-based paint banned in 1978 and LSLs in 1986.

 
The HUD and EPA lead-based paint programs include the following:

• EPA’s standards that define how much lead in dust, soil, or paint presents a hazard that needs to be addressed.
• EPA’s Renovation, Repair and Painting (RRP) rule that applies to pre-1978 housing and child-occupied facilities and presumes old paint contains lead. The rule requires that renovators be certified, complete a one-day training course, use lead-safe work practices, and notify the resident before beginning work.
• HUD’s Lead Hazard Control grants that provide more than $100 million annually to state and local governments to protect low-income residents from lead hazards.
• HUD’s Lead-safe Housing Rule with requires owners of federally-subsidized property to follow detailed requirements to help ensure the housing is lead-safe for residents.
• EPA’s rules that require anyone who identifies whether paint contains lead or not or who assesses the risk posed by lead-based paint to complete an EPA-training course and be certified by the agency or a state if they are compensated for the work. These rules also require that contractors who intend to permanently eliminate lead-based paint and associated hazards be trained and certified by EPA or states to do the work safely, follow specific work practices, and confirm no lead-hazards remain when the work is complete.
• EPA and HUD real estate disclosure requirements require anyone selling or renting pre-1978 housing to notify potential buyers or tenants of lead-based paint and related hazards.

 
Beyond lead-based paint, CMS requires that young children served by Medicaid be tested for lead and authorizes states to use Medicaid funds to provide case management and environmental investigation services for those found to have elevated blood lead levels. In addition, CDC provides grants to state health departments to operate lead poisoning prevention programs that include educating health professionals and communities about the risks of lead. These programs can address lead in drinking water. 
 
Many of these lead poisoning prevention programs have integrated their work into a larger effort to make homes healthier. This approach is generally more effective at reaching property owners and residents because it deals with a broader range of hazards such as mold, pests, water damage, carbon monoxide, and allergens in a coordinated manner. Unfortunately, most of these programs do not deal with lead in drinking water in a significant manner. Even within EPA they are not closely coordinated. Some of the limitations are grounded in the statute. 

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• In Cincinnati, the Health Department conducts water testing during Public Health Lead Investigations, makes referrals to Greater Cincinnati Water Works when an LSL is identified during an investigation, and includes information about lead in water in lead awareness materials. The Health Department and utility also work together with other relevant agencies and stakeholders on conducting community outreach, seeking funding, and collaborating on the Lead-Safe Cincinnati initiative.   
• In Denver, the Department of Public Health and Environment (DDPHE) refers homes to Denver Water if a child with an elevated BLL is identified and the investigators discover lead in the water. The utility is able to work closely with customers to prevent further exposure to lead from water. Additionally, Denver Water advertises DDPHE’s lead paint grant program in its mail insert. The water utility is also a member of the Colorado Lead Coalition, which enables them to incorporate issues of lead in water as part of the coalition’s outreach. See the Collaborative’s webinar for more information.       
• New York City provides free water testing to all residents who request one, and the water utility also shares the results of testing with the Department of Health and Mental Health’s Healthy Homes Program.
• The Philadelphia Water and Health Departments coordinate closely and provide support to each other, including on public education, communications, and community engagement around lead in water. Additionally, if the Health Department identifies a child with an elevated BLL, the water department will assist with water testing and service line material investigation. See the Collaborative’s webinar for more information. 
• Milwaukee Water Works partners with City of Milwaukee Health Department to provide outreach and education about lead poisoning and to replace LSLs at child care centers in the city. Additionally, the health department and utility are partners of Lead Safe Milwaukee – an initiative to reduce childhood lead exposure.

Opportunities to support efforts include:

• ​Federal agencies could provide a website that provides a single place to get information about lead and reducing exposure.​
• Federal agencies could better integrate lead in drinking water into their programs, especially in how they communicate the sources of lead and the risks each pose. Examples include:
  • EPA, HUD and CPSC could recommend in its “Protect Your Family from Lead in Your Home” booklet that anyone buying or renting a pre-1978 home find out whether the home has an LSL and, if it does, have the line replaced.
  • EPA and HUD could encourage lead-based paint inspectors and risk assessors to determine if an LSL is present and test the water.
  • CDC could encourage health departments investigating a child’s elevated blood lead level to routinely determine if an LSL is present and test water for lead.
  • EPA could recommend LSL replacement as part of major renovations in its “The Lead-Safe Certified Guide to Renovate Right” booklet that contractors provide to owners and occupants of housing and child-occupied facilities undergoing renovation, repair and painting work.
• Congress could support the integration by:
  • Allowing HUD’s Lead Hazard Control Grant funding to replace LSLs without limiting the number of homes made safe from lead-based paint.
  • Expanding HUD’s Lead-Safe Housing Rules from lead-based paint to include lead in drinking water and LSL replacement.
  • Expanding EPA and HUD real estate disclosure requirements to include whether an LSL is present.
  • Providing additional funding to the HUD, EPA and CDC lead poisoning prevention programs.
• States could support integration of lead in drinking water into their lead poisoning prevention and healthy homes efforts, especially at health departments.
• State Early Head Start and Women, Infant, Children (WIC) could encourage local programs to coordinate with utilities and health departments.
• Private information technology firms could make information available to consumers on all lead hazards in an integrated manner thereby greatly expanding the reach of the lead poisoning prevention programs.
• Private investors and foundations could provide stronger support for healthy homes and lead poisoning prevention programs that integrate LSL replacement into the efforts. ​