Document Z4RrjKgqbKBVKV0eMJ41mqRvV

Louis V. Lombardo - 365-0412 I PRESS RELEASE FOR RELEASE SUNDAY, AUGUST 27, 1972 . The Public Interest Campaign, a citizen organization working for consumer and environmental protection has uncovered additional evidence linking leaded gasoline with the lead poisoning of children. As a ras-ult of an investigation of New York City's lead poisoning control program The Campaign disclosed in a letter to the Environmental Protection Agency a finding that: Along with 60% reductions in the lead content of gasoline sold in New York City in 1972, there has been both a 50% reduction in lead air pollution levels and a 50% reduction in lead poisonings among New York City children. Nationwide some 600, 000 children are estimated to have dangerously high blood lead levels. The Public Interest Campaign urged EPA Administrator, William Ruckelshaus to take this new evidence into consideration in promulgating regulations limiting the lead content of gasoline. The Campaign has recommended a lead phase-out schedule which would eliminate all lead in gasoline by no later than 1977. Louis V. Lombardo, Director of The Campaign stated, "By 1977 for about a penny more per gallon, Americans can significantly reduce their lead poisoning problem and get both lead free gasoline and lead free lungs. Moreover, the added cost of lead free gasoline would be offset by savings due to longer muffler life, less sparkplug fouling and less frequent oil and oil filter changes.'4 ; LIA-76081 The;.'Public Interest Campaign August 23, 1972 ! Louis V. Lombirdo, Director ij ij New Hampshire Ave. Washington, D. C. aoojfi (3l) 365-041 Mr. William D. Ruckelshaus Administrator ' Environmental Protection Agency "Waterside Mall . Washington, D. C. 20460 .' `. ....... , . 1 Dear Mr, Ruckelshaus: This is to provide EPA with additional information for consideration in the promulgation of a rule regulating the lead . content of gasoline. While the'official deadline for comment ha.s passed, I feel oux most recent findings are too significant to be overlooked in your deliberations on the lead regulation. As part of our investigation into the lead poisoning problem I recently examined the records of New' York City's Department of Air Resources and New York City's Lead Poisoning Control Program. The records revealed the three following findings. . * I. The lead content of gasoline sold in New York City since January of 1972, by city ordinance, has been 60%lower than in previous years. II. Ambient air concentrations of lead measured at various stations in New York City in 1972 are on the order of 50% lower than in previous years. ' *- i' /" III. The incidence of lead poisoning cases (children found . to have a blood lead level of 60 ugPb/100 ml blood) in New York `\ City in 1972 is on the order of 50% lower than in previous years, as shown in the following table. i\ . . >' .' Incidence of Lead Poisoning Among New York City Children 1----------------------------------; -- - ~ ^----------------;-------------------- . Blood Sampling Period Number of Lead Poisoning Cases January 19 - July 15, 1970 January 1 - July 15, 1971 f " January I - July 14, 1972 . 929 1,030 .429 LIA-7.6082 1A lead poisoning case is defined as a blood lead level equal to or . greater than 60 ug Pb/100 ml blood. . As one who has had responsibility for the protection of the public health I urge you to weigh this new' evidence carefully on the side of the people. In your rulemaking follow the public health axiom, that if you must err, prudence dictates that you err on the side of public health protection rather than the protection of economic interests. Furthermore, I understand your Office of General Counsel is of the.'opinion that upon promulgation of a Federal regulation all state and local regulations must be preempted. Such a construction of the law is likely to result in allowance of an increase in leaded gasoline usage in New York City. I therefore urge yon to promulgate a rule, or construe the law in such a manner as to not permit such a detrimental consequence. Additional evidence uncovered during the investigation shows the incidence of lead poisoning to fall most heavily on the black population. I have enclosed a graph which shows a July 1911 peak incidence of lead poisoning cases ci among black 2 year old children tested. The graph also shows that among New York City Puerto P.ican. children the peak July incidence is 3%, still high but considerably lower than the incidence among blacks. This confirms one of the main findings of your Task Force on Environmental Problems of the Urban Poor*. , The nation and the 120, 000 New York children at risk: = can be grateful to the officials of New York City for having success fully-reduced the lead content of gasoline in New York. But it is a sad commentary on Federal leadership that the only thanks people in other Fast Coast cities can have is for the rainy spring and summer which reduced the load content of street dirt and dust. Sincerely, e. f / Louis V. Lombardo LI&-76033