Document 2NJeRRb0Xr9G1z6qmoJbVNZX5

6 Lead Industries Association, Inc. /c 292 Madison Avenue New York, N.Y. 10017 Telephone: (212) 578-4750 / ^J ^ ju'i'<-/c^_ TO : FR : RE LIA Environmental Health Committee LIA Regulatory Activities Committee Rosalind A. Volpe Assistant Director, Environmental Health Comments of the Lead Industries Association on EPA*s Proposal to Reduce the Lead Content of Gasoline to 0.1 Grams per Gallon Attached are the comments of the Lead Industries Association on EPA's proposal to reduce the lead content of gasoline to 0.1 grams per gallon. The comments were filed on October 1, 1984. Rosalind A. Volpe mfcl Att.: a/s lZj't. /L CCi^ / /4^ ^^ itL C- t-i- ---t-- >- CM' BEFORE THE ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. In the Hatter of REGULATION OF FUELS AND FUEL ADDITIVES, LEAD PHASEDOWN ) Docket No. EN-84-05 ) ) 49 Fed. Reg. 31032, et ) seq. (Aug. 2, 1984) COMMENTS OF LEAD INDUSTRIES ASSOCIATION, INC. EDWIN H. SEEGER KURT E. BLASE Prather Seeger Doolittle & Farmer 1101 Sixteenth Street, N.W. Washington, D.C. 20036 Attorneys for Lead Industries Association, Inc. WERNER T. MEYER, President ROBERT D. PUTNAM ROSALIND VOLPE Lead Industries Association Inc. 292 Madison Avenue New York, New York 10017 October 1, 1984 TABLE OP CONTENTS Page SUMMARY......................................................................... 3 TABLE I ............................. 7 I. EPA HAS NOT SHOWN THAT THE LEAD PHASEDOWN PROPOSAL IS THE MOST COST-- EFFECTIVE WAY TO CONTROL MISFUELING . ............................ 8 A. Misfueling Can Be Controlled At No Additional Cost Through Proper Enforcement of I/M Programs.............................................. 9 B. Misfueling Can Be Controlled Through Additional Enforcement Authority......................... 12 II. EPA* S PROPOSAL WILL COST OWNERS OP PRE-1971 VEHICLES NEARLY II BILLION IN ENGINE VALVE DAMAGE............................................. .14 III. EPA'S PROPOSAL WILL INCREASE GASOLINE COSTS BY NEARLY II BILLION...................................................... 20 IV. EPA'S PROPOSAL WILL NOT PRODUCE THE PREDICTED CONVENTIONALBENEFITS . .........................................22 ' A. Exhaust System Replacement . .............................. .22 B. Fuel Economy s................................................................................. 23, C. Extended Oil Changes.............................................................24 D. Environmental Benefits Prom Reduction of Misf ueling............................... .... 26 V. EPA'S PROPOSAL WILL PROVIDE NO LEAD- RELATED HEALTH BENEFITS AND MAY INCREASE THE RISK OF LEAD INTOXICATION FOR YOUNG CHILDREN......................................................................................28 A. The Gas Lead/Blood Lead ^ Relationship ................................................................................ 28 ' B. Effects at Elevated Blood Lead Levels . ... 36 n C' 171U 1'J U -1 Page C. Effects At Low Blood Lead Levels..........................3 8 CONCLUSION..................................................................... ............................. 44 EXHIBIT As Costs of Reducing Lead in Gasoline, Turner, Mason & Associates (July 13, 1984), including explanatory testimony and memorandum. EXHIBIT Bs Oil Change Intervals Cannot Be Doubled By Switching to Unleaded Fuel. EXHIBIT Cl Comments of Dr. Peter C. Elwood, Chairman, Epidemiology Unit, United Kingdom Medical Research Council, concerning the gas lead/blood lead relationship (January, 1984) . EXHIBIT Ds Testimony of Dr. Edward B. McCabe, Clinical Professor of Pediatrics, University of Wisconsin Medical School (August, 1984) EXHIBIT Es Testimony of Dr. Paul B. Hammond, Head, Division of Toxicology and BioEnvironmental Sciences, Department of Environmental Health, University of Cincinnati Medical Center (August, 1984) . EXHIBIT Ps Report of BPA Expert Committee on Pediatric Neurobehavioral Evaluations (November 14, 1983). EXHIBIT G: Low Level Lead Effects. EXHIBIT H: Legal Memorandum Supporting Comments of Lead Industries Association, Inc. 3 BEFORE THE ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. In the Matter of REGULATION OF FUELS AND FUEL ADDITIVES, LEAD PHASEDOWN ) Docket No. EN-84-05 ) 5 49 Fed. Reg. 31032, et ) seq. (Aug. 2, 1984) COMMENTS OF LEAD INDUSTRIES ASSOCIATION, INC. SUMMARY The Lead Industries Association, Inc. (LIA) strongly urges the Environmental Protection Agency to abandon its latest lead phasedown proposal because it will not pro vide any public health benefits but will cost gasoline con sumers and owners of vehicles requiring leaded gasoline billions of dollars. Though leaded gasoline consumption has been reduced by 70 percent as a result of the rising proportion of cars using unleaded gasoline and EPA's phasedown regulations, there is no reliable evidence of any reduction in the number of lead intoxicated children and considerable evidence that the 1/ LIA is a nonprofit trade association whose member companies include nearly all domestic producers and many commercial con sumers of lead. 4 number is not falling* The reason is that lead-based paint in dilapidated housing is the principal cause of elevated blood lead levels in children* EPAfs effort to reduce the number of children at risk by limiting the lead content of gasoline has thus been a failure and? worse still? has lulled federal officials into ignoring the real problem -- lead-based paint in old housing. Despite this history, EPA now proposes to acceler ate the lead phasedown program and reduce the lead content of gasoline to 0.1 grams per gallon. Perhaps because it recog nizes that the phasedown program has not benefited children with high blood leads? EPA places heavy emphasis on alleged benefits to children with low blood leads. First, EPA cites recent studies which "suggest possible small effects on IQ and other behaviorial disfunc tions" (49 Fed. Reg. 31038) . This conflicts with the find-' ings of a panel of scientists established by EPA which could find no evidence that "validly established (after proper con trol for confounding variables) a relationship between low- level Pb exposure and neuropsychologic deficits in children." EPA appears to have rej ected the findings of its own panel. Although the panel severely criticized the widely publicized Needleman study on this issue, EPA has apparently accepted a reanalysis of the Needleman data that was not submitted to the panel for review. _