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June 26, 128Q TO: R. 'If. KENNARD D, W. MARQUARDT R, D, s n k e " --' J, M, LUCAS' FROM: C. G, PFEIFER A PERSPECTIVE ON THE ENVIRONMENTAL LEAD ISSUE Attached is an article which puts into perspective the issues and politics surrounding the identification and regulation of environmental sources of lead that I think you'll find interesting, A brief account highlighting Du Font's position is given on page 33. CGP/bg Attch TEH 0532339 Go\ vernment * Several federal programs aim to reduce human exposure to lead, but which source 1$ most dangerous is subject of growing controversy Lois R. Ember C&EN, Washington She was three years old, and lioed in decaying inner-city housing. When she was admitted to the hospital she was stuporous, extremely pale, and her brain was swollen--a condition known as encephalopathy, the result o{ severe lead poisoning. Her doctor treated her with drugs called che lating agents. And she recovered. This child was the turning point for Herbert Needleman, now at Children's Hospital Medical Center in Boston. At first, he recalls, "I felt triumphant; J had made a good di agnosis; I had done the right treat ment; and / saw the child getting bel ter. Then when I told the mother that her daughter couldn't go back into that home, she asked me: `Where am I going to move? Every house on the block is the same.' Confronted by the mother's realities, I began to re alize that it is not enough just to give a drug. The disease is out there in the world, not just in the child." Over the past decade, six federal agencies acting under eight separate laws have developed control-strategy regulations, or are carrying on screening programs designed to pro tect the public from the hazards of lead. Despite these efforts and a multimillion-dollar research program, a new National Academy of Sciences report finds that "Every member of the general population of the U.S. is exposed to elevated levels of lead in air, drinking water, and foods." Especially at risk are urban children who eat leaded paint chips or lead laden dust and soil, adults exposed to lead in the workplace, and pregnant women. Lead is not a natural constituent of the human body, and has no known role in normal human physiology. Yet, because it has been mined, smelted, and manufactured into useful products for thousands of years, members of industrialized so cieties are grossly contaminated by this highly toxic metal. Its hazards have been known since antiquity. Instructions for separating lead from silver ore can be found in the Old Testament, The first clear de scription of lead colic symptoms comes from the second century BC Greek poet/physician Nicander, Pliny warned of the hazards of breathing lead fumes, but touted the virtues of leaden wine kegs. The Romans mined silver ore for coinage, and used the by-product lead for wine vessels and their intricate plumbing system. In fact, some historians link the fall of Rome to the lower birth rates and madness of the ruling class, the probable result of increased lead in take from wine and water. Today, U.S. industry consumes 1.3 million tons of lead annually to make such products as batteries, pigments, solders, pottery, and the antiknock agent in. leaded gasoline. Smelting and fabricating lead for these prod ucts, and burning leaded gasoline to drive our mobile societies can expose workers to high lead levels, and send more than 600,000 tons of lead into the atmosphere to be inhaled or-- aftef deposition on food crops, in fresh water, and on soils and streets--to be ingested by the general population. Food also can be contaminated by lead from the solder in tin cans, pes ticide sprays, and cooking utensils. In older homes where the plumbing consists of lead pipes, and the water is acidic and low in mineral content, lead may leach into the water supplies. Weathering of lead-laden paint and putty in older homes con taminates dust with lead, which can he inhaled or ingested; chipping, peeling, and flaking paint in these homes may offer a child a tempting but dangerous morsel. That tempting morsel, once in gested, can result in a very high body burden of lead that can severely damage the developing nervous sys tem. Controlled animal studies have duplicated the neural effects ob served in lead-poisoned children. At the other end of the spectrum, Needleman,' in a widely discussed study of over 2000 "normal" first- and second-grade children, was able to relate lead levels in deciduous teeth to behavioral and intellectual problems in the children. He found no thresh old, but a continuum of effects/ As dentine lead levels increased, per formance on standard intelligence, auditory, and language-skill tests decreased--whereas negative be havioral patterns, as noted by teach ers, increased. The laboratory correlate to Needleman's study is Ellen SilbeTgeld's rat model. At the National Institutes of Health, Silbergeld has developed an animal model of childhood lead poisoning. Her rats receive low levels of lead--levels that would be asymptomatic or subclinical in chil dren--in their drinking water for the first 30 days of life (the equivalent of a child's first five years). On this reg imen of lead exposure, the rats dis play distinct rieurohehavioral and learning disorders. Significantly, Silbergeld has been able to show that in these rats, lead gets inside the nerve cells where it tenaciously remains, first affecting the energy metabolism of the cells, but more important altering the concentration and, flow of crucial ions, thereby disrupting the release of ->2B C&EN June 23, 1980 DUP050033428 * neurotransmitlcrs-- (lie chemical "undue lead absorption"--are prev- Still another possible solution to coinmunication links between nerve alent. According to the academy's the fragmentation between parts of. cells. report, a growing body of evidence HUD and CDC is a Congressional Dovetailed. Silbergeld and Nee- "suggests that commonplace expo- amendment to the 1971 act that dlemanb studies add io the mounting sure to lead in urban environments would consolidate authority for de evidence that lead at low levels is a may be associated with detrimental cisions about the control oflead paint very serious health problem, and one effects on the intellectual develop- hazards under one health-oriented that requires a "strategy of preven- ment and behavior of children." regulatory agency. This would remove lion," Silbergeld says. The NAS report attributes the HUD from the picture, an outcome The social implications of this re- limited results from the federal effort some in CDC would welcome because search are vast, Silbergeld points to to nonintegration and noncoordina- they consider HUD's Environmental the loss of self-esteem in a child be- tion among current laws: No single Hazards Research Program as an hind his age group in school, and the federal agency is empowered "to deal obstacle to the protection of chil effect that might have on him in later with total exposure in an integrated dren's health. years. Clair Patterson, a California fashion." Ana, as a result, policies are The turf, fighting that the lead Institute of Technology geochemist, "fragmented and sometimes incon- panel perceived among agencies re in his minority report to the 488-page sistent." sponsible for solving various parts of NAS study op "Lead in the Human To remedy this fragmentation, the the lead problem is a story not found Environment," takes a still wider, 12-member panel of lead experts in the academy^ report. Lead, it more alarmist view. Some time in the recommends the token academy so- turns out, is not only a metal that is future, he says, the average adult in lution: Chuck out all the old laws and molded into useful products, but it is the U.S. will have been found to "ex- write a new, comprehensive statute, a molder of activists--a catalyst that perience a variety of significant The logical sequel to this politically transforms scientists and medical physiological and intellectual dys- naive solution, some suggest, is the researchers into political advocates. functions caused by long-term formation of a Department of Lead to From this activism has come labile chronic lead insult to their bodies and execute the law. alliances and shifting priorities. minds which results from excess ex- Short of such sweeping action, the Abrasive personalities, fragmented posures to industrial lead that are panel suggests the creation of a for- mandates, seemingly unsolvable 500-fold above natural levels of lead mal coorqinative mechanism such as problems, and staggering economies exposure, and that such dysfunctions the Interagency Regulatory Liaison have combined to pit research scien on this massive scale may have sig- Group, Why this recommendation tist against medical researcher, nificanllv influenced the course of when IRLG already has a task force agency against agency, industry American history." There are no on lead, the agencies of IRLG have a against government. unexposed control groups, he common research agenda on lead, and This activism has encouraged buck argues. these agencies coordinate regulatory ^ passing, even though the academy All is not gloom, however. The activities? One reason is that the v legitimized conventional wisdom federal effort has resulted in a dra- Department of Housing & Urban when it said that all important envi matic decrease in the number of cases Development and the Department of ronmental sources contribute to ele of severe lead poisoning like that ex- Health & Human Services' Center for vated lead body burdens. For exam-' perienced by Needleman's three- Disease Control (CDC)--agencies pie, the lead industries blame lead in year-old patient. But asymptomatic that have responsibility for portions paint as the source of the problem; children with blood-lead levels -of the lead problem under the 1971 the food industry cites paint and at greater than 30 micrograrns per 100 Lead-based Paint Poisoning Pre- mospheric emissions; and the director mi and elevated red-blood-cell pro- vention Act--are not now, but ac- of HUD's lead research group indicts toporphyrin levels--the marker for cording to the panel should be, in leaded gasoline, thereby passing'the cluded in IRLG activities concerned problem on to the Environmental Protection Agency, The tale began in 1971 when Coil- fress passed the Lead-based Paint 'oisoning Prevention Act, and split responsibility for portions of the law between the then-Deparlment of Health, Education & Welfare--which was to search for lead-poisoned chil dren, treat them, and remove the source of lead--and HUD, which was to seek ways to abate and correct the hazards of lead-based paint. HEW/ CDC began an outreach screening program in major urban cities. HUD sponsored research On abatement techniques and, with mainly HEW- generated data, began to conduct studies on blood-lead levels and the environmental sources of lend. . . . The HEW-gathered data came from the screening programs, and were never meant to he used as re search data and, according to CDC's director of environmental health services Vernon Houk, "cannot be j used for that purpose." Nevertheless, TEH 0532341 June 23, 1980 C&EN 29 DUP050033429 HEW data that show that if lead paint is taken off the walls, children's blood-lead levels will go down in 75% of the cases and up in 25% of the cases, but the game percentages hold -v . if the paint is not taken off the walls. He further cites preliminary data t&s-. - from a HUD-sponsored New York City study indicating that blood-lead vfi -/ * s?^ 'U:\ ml values appear to be unaffected by the different intervention techniques tested, including total lead paint re moval. More to the point, Billick admits to C&EN that he does not feel that i'3 lead-based paint is a health hazard to children, but he emphasizes that he is speaking for himself and not for his agency. Furthermore, he believes that tne correct government action would be one that Towered blood-lead values Darfr areas are lead deposits in mito chondria of neonatal rats . for the least cost. His studies have convinced him that taking leaded paint off the walls of old housing stock may not be the these were frequently the only most efficacious expenditure of tax blood-lead data available to HUD, payers' dollars. From his studies on and they are, in the main, the data leaded gasoline and blooddead levels, that Irwin Billick, then director of and his dedicated promotion of these HUD*s lead-based paint poisoning studies, some have come to believe research and now. director of HUD's that Billick believes most children environmental hazards research, used would benefit from removing lead in his quest for an association be from gasoline, whereas only a i'ew tween a specific action and a decrease children would benefit from solving in blood-lead levels. the lead-paint problem; therefore, the In his studies, Billick finds corre "biggest bang for the bucks" would be lations between air-lead levels and achieved by pursuing the former blood-lead levels, and between gaso strategy, Billick, however, is very line-lead levels and blood-lead levels, careful not to state explicitly this but not between lead in paint and implication, sidestepping the issue by lead in blood. In fact, he says, in ma saying that it is a "political decision" nipulating the available medical data outside his bailiwick. on children, he has found "inconsis Billick came to NAS in June 1978 tencies with the generally accepted ..asking for a quick assessment of wisdom that lead in paint is the major HUD'S seven-year, multimillion- cause of lead in blood." dollar research program, which he For example, be cites unpublished hoped to use in his fiscal budget ex ercise in the fall. According to Ted Schad, NAS deputy executive direc tor of the Commission on Natural Resources, who was present at that first meeting, Billick expressed his belief that lead in paint is not a health problem, and that he hoped the academy's eventual report would support his position; For political reasons, such a finding by the acade my would support. Billick's efforts to reallocate funds from lead-based paint research to other efforts with out raising cries that HUD was abandoning the inner city". However, Billick'was told that even if the academy undertook a study, it could never he completed by the fall of 1978; that any study undertaken would have to address all environ mental pathways of lead that affect health; and that there was no guar antee the panel assembled by the academy's Environmental Studies Board would reach the conclusion that lead-based paint was not a health risk to children. Billick accepted these conditions, and in late June 1978, when HUD defined the scope of work and sup plied $254,000 to support the effort, NAS began the study. In December 1979, HUD received the completed report, and was sorely dissatisfied with it. So much so, that Billick and his colleague V. Eugene Gray have resorted to attempts at discrediting the report before it receives wide cir culation. Several weeks ago, a scathing, im politic internal memorandum written by Gray to Billick just"happened" to fall into the hands of the Associated Press. Accor4tng to Billick, the AP story--which contained such Gray rhetoric as, "I am at a loss for words to describe my nausea" and "This report is a good example of the intellectual masturbatory activities engaged in by NAS at federal agency expense"-- was printed in 100 newspapers. This leak was timed to coincide with the academy's woes over the widely criticized, controversial Food & Nutrition Board's "Toward Healthful Diets," Earlier, C&EN was given Gray's memo to read. His final paragraph clearly reveals the environmental hazards research division's assess ment of lead-based paint research. Since researchers are not gleaning anything new from their $18 million, three-year effort, and "there are very few cases of lead poisoning anymore, let's transfer that $18 million from lead research to other research on more important problems," Gray writes. . .- Not all of HUD agrees with Gray, The policy arm, for instance, headed by deputy assistant secretary for regulatory functions Patricia Worthy, will "carry out its statutory and Congressional mandate to deal with lead-based paint hazards." Worthy's group is beginning to develop close working relationships with Health & Human Services disease cont rol cen ters throughout the country. Under' this arrangement, Worthy says, HHS will alert HUD to lead-poisoned children living in HUD-associated housing. HUD then will move in to remove the source of the lead from the children's environment. This" cooperation between HHS and Worthy's group at HUD docs not, however, extend to Billick's research group. CDC's Vernon Houk and Bil lick have been at odds ever since .Bil lick "decided to prove that lead-based paint is no problem, when in fact it is a major problem," Houk says. Houk sharply objected to Billick and Gray's report, "Lead Based Paint Poisoning Research: Review and Evaluation 30 C&EN June 23. 1380 TEH 0532342 DUP050033430 1971-1977," which assessed HUD's $8.8 million research effort, an effort that'has now climbed to about 310 million. Houk's objections to that report are in accord with Needleman, who in a letter to HUD Secretary Patricia R. Harris wrote that the Billick and G ray document "will serve as a justi fication for further delay in the re moval of lead from housing stock," Billick and Honk are in agreement that lead is a multisource problem. But they part ways on the significance of lead-based paint. For a discrete segment of children in this coun try--those living in the so-called poor, inner-city lead belts--the most hazardous high-dose source of lead is paint, followed by soil and dust con taminated from "previous land use, lead-based paint, and fallout from industrial and automotive emissions," Houk declares. However, Billick can find no association between lead in paint and blood-lead levels in the young populations he studies. According to the former principal staff officer of NAS's lead panel, Ed ward Groth III, who worked with both men, Houk is less .concerned about whether Billick is correct scientifi cally than he is by the possibility that ifBillick is taken as correct politically, children will continue to suffer from lead poisoning, and appropriations to eliminate this hazard will dry up be cause of the presumption that the problem has been solved. Although Houk and Billick have disagreed publicly and vehemently, Billick has been able to maintain symbiotic relationships with scien tists at the Environmental Protection Agency and staff members on the President's Council on Environmen tal Quality. His cooperation was so successful with CEQ that he got the Billick: lead-based paint n ot a hazard '-gjjg ||J|gP te*&s S^^eS' J^ ^OvJf SPf nSrd^r sSa^^.., evef- iius Pvgert^wJS*5!3 S"f!t CIRCLE 41 ON READER SERVICE CARD staff to report only his data on the relationship of pediatric blood-lead values to lead in gasoline in the council's 10th annual report pub lished in December 1979. Because no other data were reported in the fivepage section on lead, the reader is left with the impression that lead in gas oline--rather than lead in paint or lead from both sources--is princi pally responsible for elevated bloodlead levels in children. After reading this report, Needleman wrote a letter to CEQ chairman Gus Speth expressing his "conster nation." He called the lead section "unscientific and tendentious,'' and a disservice "to the children living in leaded housing." And he charged Billick's research group with at tempting "to diminish the role of lead paint as a source of hazardous expo sure for children," because it has "been unequal to its appointed task-improving housing stock. Rather than expend the energy and funds to tackle this formidable job, it has made it disappear by the magic of inferior biostatistics." Du Pont, one of four U.S. produc ers of lead additives for gasoline, agrees with Needleman s assessment of the statistics. So does Donald Lynam of the Lead Industries Asso ciation, who says "HUD has made more out of these data than is scien- tifically valid." Although Lynam concedes that lead is a multimedia problem, he claims that lead in paint "is by far the most significant source." Even though the inclusion ofonly Billick's data in the CEQ annual re port made for a less than compre hensive discussion of the lead issue--a condition that CEQ member Robert Harris tells C&EN will be rectified in the next annual report-- the Same data were used by EPA to ward off industry and the Energy Department's attacks on EPA's ef forts to phase out lead in gasoline. Because of the presumed gasoline shortage in 1979, EPA relaxed but did not rescind its lead plvase-down pro gram. By October 19S0, the- final lead-in-gasoline standard of O.o gram per gal is to go into effect. .. EthyljCorp,, the major U-S. pro ducer of the antiknock compound tetraethyllead, along with Du Pont is fighting this final phase-down effort. The addition of the additive to a gal lon of gasoline does extend that gallon 6%, and Ethyl has taken this fact to the American public. In newspaper ads, Ethyl says that S4.71 of it s com pound in gasoline can conserve a barrel of crude oil, thereby improving U.S. balance pf payments, increasing TEH 0532343 jUne 23. tseo c &en 31 DUP050033431 gasoline availability, and adding to t he petrochemical feedstocks. Du Pont is taking a quieter tack. In a long critique of Billick's study on the association of blood-lead values and gasoline-lead levels, Du Pont tells EPA that: _ "HUD used the wrong data to represent gasoline lead use in New York City. The HUD blood-lead data are seriously flawed by sampling irregu larities, procedure changes, and data handling inconsistencies--all of which affect blood-lead values. HUD's treatment of the blood- lead data suffers from serious defi ciencies. - HUD's blood-lead/gasoline-lead relationship is unreliable." Also joining the fray is NAS, which finds that "empirical correlations between measurements of lead in the body and lead in the air, water, soil, or gasoline are valuable qualitative in dicators of source contributions, but they rest on too few data and too many unproven assumptions to be accepted as being quantitatively re liable." At first glance the finding appears to support Du Pont's posi tion. However, the lead panel's call for continued control of all sources of lead, including lead in gasoline, ef fectively neutralizes that support. If anything, the academy's report is likely to support EPA's ambient lead and lead-in-gasoline programs. EPA now estimates that from 1970 to notice of proposed rule-making on 1977, airborne-lead levels have lead in food as a first step in setting dropped 26%; during this same period "action levels" to reduce lead intake lead consumed for gasoline sales has 50% in five years from lead-soldered decli ned 30%. Although it is not pos cans, the only source of lead FDA sible to break out the contribution of believes it can control through regu various sources to ambient lead levels, lation. Replying to this notice, Con EPA estimates that vehicle emissions sumers Union applauded the move, account for more than 88% of total but argued that the agency is moving lead emissions. too slowly, and that its goal of reduc Diet is still another major source of ing lead exposure&f children to less .body-burden lead, especially in than 100 micrograms per day is not 'adults. According to the Food & Drug adequate for health protection. A safe Administration, most of the lead in maximum exposure range, the con food and water is there as a result of sumer's group argues, is from 0.6 to 10 natural background levels and pol micrograms per day for infants and lution--airborne lead from industry young children, and from 10 to 78 and vehicles r.edeposiling. on crops micrograms per day for pregnant and soils and in drinking water women, the two most vulnerable supplies. A portion of the lead is groups. present as a result. of food pro In a March issue of Science maga cessing. zine, Patterson published an article FDA, the agency charged with en- . on lead in tuna that was widely dis suring the public a safe food su pply, cussed in the general press. In this has never said what's a safe lead level paper, geochemist Patterson argues in food. But that does not mean it has that ind ustrial lead is so pervasive in been totally silent on the issue. Since the environment that it "masquer 1973 it has moved slowly to persuade ades as natural lead in foods before industry to decrease voluntarily lead they are processed." This so-called levels in milk and in baby foods and "natural" level plus additional con formulas--a program that in some tamination from processing and instances has resulted in a 9.0% drop canning has elevated the lead con in lead levels. centration in today's U.S. diet 100- Last year FDA issued an advance fold over prehistoric diets, he says. This, in turn, has contributed to the 1000-fold increase in the lead burden carried by people today over their prehistoric ancestors. Using sophisticated analytic tech niques in an ultraclean laboratory, one fresh tuna sample and a small number of canned tuna samples, Patterson finds much higher lead concentrations in the commercially processed tuna. He, therefore, calls for a ban on all lead-soldered cans. FDA director of the Bureau of Foods Sanford A. Miller takes issue with Patterson's sample size, sam pling technique, and the "involved analytical techniques," which he says have not been validated for loud measurements and arc not "pract ical to meet the needs of regulatory agencies such as FDA for monitoring the higher levels of lead encountered in the food supply." Kathryn R. Mahaffey, FDA nutri tional biochemist, expert on lead, and member along with Patterson of the NAS lead panel, recognizes Patter son's sincerity and intensity of con cern, but she contends that tills con cern does not reflect the realities of food handling, processing, and mar keting, or the broader aspects of public health. Nutritionally deprived individuals < TEH 0532344 June 23, IS30 CSF.N 33 DUP050033432