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Can we call the issue of lead exposure an ‘environmental justice issue’, and if so in what ways? And what kinds of policies have been enacted or proposed to address it?

10/15/2019

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Introduction
Lead exposure, since the Roman Empire, has been known to cause strange behavior in people. At first glance, the cause of this behavior was never found. Fortunately, the advancements from scientific understanding that is provided from Greek scientists, the ancient Romans were able to learn how their everyday essentials were causing strange behaviors. Romans have documented that they used lead for pipes, cooking pots, tank linings, and in the aqueducts constructed to bring water into urban areas. It was used for roofing many churches and cathedrals and was made into the guttering and downpipes, often with decorated hoppers as patterns were easily beaten into the soft metal. As time progressed, the uses of lead also did. Lead can still be found in paint, drinking water pipes and many other essentials. Despite the knowledge of how unsafe lead is and that 2 ppb[1] of lead exposure is unsafe through research studies, the Environmental Protection Agency (EPA) allows 15 ppb of lead in our drinking water through the Lead Copper Rule. With this brief understanding of how ancient Romans used a toxic substance for everyday essentials and how our government chooses to handle the lead crisis, we must acknowledge the timeline for the implementation of laws and regulations that acknowledge the hazard that lead poses on the environment and the health of the people who occupy these environments. The purpose of this essay is to introduce the beginning of lead exposure policy and the associated situation for whether this exposure is an injustice to our environments. Lead exposure is an environmental justice issue because of many reasons. First, lead exposure can onset lead poisoning. Second, lead exposure primarily exists within low-income more impoverished communities of color. Thirdly, the limitations and regulations for lead exposure are not developed to mitigate, improve, or solve the problem of the lead infestation within these more deprived communities.

​Sources of lead (plumbum), and what are its properties?
      Furthermore, lead is a chemical element in the periodic table of elements scientifically known as Plumbum[2]. The first account of lead being extracted from the Earth’s crust in North America was during 1621. This extraction was sound for understanding the physical properties of lead in America. It is found that lead is a naturally occurring toxic metal with a visible blue-ish gray color that is very malleable, making it ideal for building structures and overall very flexible in constructing most structures. Other than the previously mentioned past about lead in Rome, lead is widely known for its deadly properties when exposed at unusually high levels. The EPA even states that “Lead can be found in all parts of our environment – the air, the soil, the water, and even inside our homes. Much of our exposure comes from human activities including the use of fossil fuels including past use of leaded gasoline, some types of industrial facilities, and past use of lead-based paint in homes. Lead and lead compounds have been used in a wide variety of products found in and around our homes, including paint, ceramics, pipes and plumbing materials, solders, gasoline, batteries, ammunition, and cosmetics.” (EPA, 2019). Considering this and that lead does not break down, and lead compounds are changed by sunlight, air, and water we know lead is a hazardous toxic element if exposed at high levels with no mitigation practices or prevention methods. From modern scientific knowledge, there is an understanding that once lead falls onto the soil; it stays in that soil. Besides, when the lead is consumed, either through breathing or swallowing, it is in the body and with an extreme exposure of this consumption an individual may possess' symptoms of lead poisoning.
Sources of lead exposure
 “A child’s environment is full of lead.” (EPA, 2019) The EPA states this first on their government webpage about the sources of lead exposure. The EPA follows that statement by explaining where lead can be found. Such as, in paint, gasoline, solder, consumer products, air, food, water, dust, and soil. According to the EPA, lead-based paint is the most widespread and dangerous high-dose source of lead exposure for young children.

Lead Poisoning
 Lead poisoning occurs when lead accumulates in the body, over time. Small amounts of lead may even cause serious health problems. At very high levels, lead poisoning can be fatal. The Environmental Protection Agency (EPA) explicitly states There have been many accounts of lead exposure leading to elevated risks of lead poisoning, one account of this occurred in Syracuse, NY in a refugee population. The study describes the current lead levels of refugee children upon their "arrival and post-resettlement in Syracuse, NY." (Lupone et all, 2019) The research methods used to receive data was a cross-sectional retrospective chart analysis of all pediatric patients aging to 16 years of age. All pediatric patients attended the Pediatric Refugee Clinic at SUNY Upstate Medical University between May 31, 3013 and June 01, 2017. The findings of this research study showed that there were noticeable increases in blood lead levels (BLL) from younger female (0-4.9 years). The difference was 20.0% BLL in younger females rather than 4.9% which was found in the older females. This study is one of many examples of how having lead exposure can onset lead poisoning.
Also, the Lead and Copper Rule (LCR)  are two federal regulations that limit how much lead and copper are acceptable in tap water before causing any harmful effects. These regulations establish a treatment technique. All that is considered when treating for lead or copper are if the requirements for corrosion control treatment, source water treatment, lead service line replacement and public education are being met. An example of when this failed, and onset lead poisoning was recently in Flint, Michigan. Due to Flint’s Water Advisory not sampling water from homes, as required by the LCR, these homes lead, and copper levels were not measured, and mitigation from the high levels of exposure of lead they were receiving could not be completed. There was no implementation of corrosion control systems all contributing to the lead poisoning in Flint.
This is a concern because, lead exposure can cause an adult body [3] to develop memory loss, lack of concentration, headaches, irritability, depression, higher blood pressure, abnormal kidney functions and significant damage to the nervous system. In a child’s body[4], lead exposure can damage the nervous system, cause anemia, damage the kidneys, limit bone and muscular growth, brain-behavioral problems, lower IQ scores, hearing loss, and learning disabilities.

Lead exposure primarily exists within low-income more impoverished communities of color
Moving forward, lead exposure is more prevalent in communities that are lower-income and predominately home to minorities, mainly African American minority. Even the EPA states, "lead exposure is not equal among all children–national data suggest minority children, children living in families below the poverty level, and children living in older housing have a significantly higher risk for elevated blood lead levels. No safe blood lead level in children has been identified." (EPA 2019). Another supporter of this claim is Dr. Sandy Lane, a professor that teaches Public Health related courses at Syracuse University. Lane supports the reasoning that lead exposure is more prevalent in these communities of lower-income minorities. In her educational book 'Why Are Our Babies Dying,' Lane takes an Ecosystem Approach to illustrate the impact of a host of social and environmental conditions on the health and well-being of affected communities at substantial and specific health-related outcomes. Lane also introduces in her book the Structural Violence Theory. Defined by Lane as "preventable harm or damage … where no actor is committing the violence or where it is not meant to search for the actor(s); such violence emerges from the unequal distribution of power and resources or, in other words, is said to be built into the structures." (Lane, 2016). Structural violence encompasses institutional racism. Relative deprivation in food or health care, disease-ridden environments, and stigmatizing social norms. From Lane's book, we can understand that minorities residing in lower-income communities typically are residents in distressed housing, which is a residential property in poor physical condition, or likely to fall into poor condition because of deferred maintenance. These deferred maintenances, according to the Centers for Disease Control and Prevention (CDC), a federal agency under the Department of Health and Human Services, are code violations and lead hazards, in housing that are older or occupied by 'very low' income households or abandoned. The CDC also created some recommendations from their Advisory Committee on Childhood Lead Poisoning Prevention. Preventing Lead Exposure in Young Children is a housed based approach to primary prevention of lead poisoning that presents eight elements of a comprehensive program for primary prevention of childhood lead poisoning. These eight elements are: (1) identify high-risk area, populations, and activities associated with housing-based lead exposure, (2) use local data and expertise to expand resources and motivate action for primary prevention., (3) develop strategies and ensure services for creating lead-safe housing, (4) develop and codify specifications for lead-safe housing treatments, (5) strengthen regulatory infrastructure necessary to create lead-safe housing, (6) engage in collaborative plans and programs with housing and other appropriate agencies, (7) evaluate and redesign existing CLPPP elements to achieve primary prevention goals while ensuring adequate secondary interventions, (8) evaluate primary prevention progress and identify research opportunities. 
According to Lane, a youth’s most significant exposure to lead comes from old paint in dilapidated buildings, which are buildings in a state of disrepair or ruin as a result of age or neglect, that they reside in, go to school in, practically encounter every minute of their day. Proven from statistics, the individuals who reside in these dilapidated buildings are the minority. The Syracuse Open Date provides open Lead Violations by zip code in Syracuse, New York cited by the Onondaga County Health Department. In sum, the ten zip codes in Syracuse, NY that have open violations are 13202​, 13203​, 13204​, 13205​, 13206​, 13207​, 13208​. 13210​, and 13224. In 13202, there is a population of 5,438 individuals. Of this population, 56.3% are minority black individuals that reside in over 600 homes that have been built in 1939 or earlier. The individuals are considered minority because the average household income is below 14, 537. This is an injustice because these community members are exposed to the health issues associated with lead exposure and despite the apparent knowledge of this exposure little is being done to eliminate the lead.

The limitations and regulations for lead exposure
The limitations and regulations for lead exposure are not developed to mitigate, improve, or solve the problem of the lead infestation within these more impoverished communities. Regulations that exist aim to reduce lead in paint, water, air, waste and clean up, lead reporting for the Toxics Release Inventory. Current policies in place require the NYS health officials to test the bll of children. Taking a small-scale examination of some governmental agencies and their actions can develop this understanding that the recommendations are not strong enough to fight the lead exposure in all communities. The EPA has created the Implementation Status Report for EPA Actions under the December 2018 Federal Action Plan to Reduce Childhood Lead Exposures and Associated Health Impacts. The vision of this report is for the United States to become a place where children, especially those in vulnerable communities, live learn and play protected from the harmful effects of lead exposure. This report introduces the EPA's, states, tribal and local government actions to reduce lead exposures. The report is continually updated and created by the EPA and the Department of Health and Human Services (HHS). This Federal Lead Action Plan outlines and explains the four interconnected goals with supporting priority actions. The first goal of this plan is to reduce the child's exposure to lead sources. This is done by objectives such as reducing the exposure to lead paint in housing, reducing lead exposure in drinking water, reducing lead exposure in soil and reducing exposure to lead associated with emissions to ambient air. The plan to accomplish the first objective is to consider revisions to the dust-lead hazard standards to address childhood exposures to lead-contaminated dust generated from lead-based paint. They plan to continue the implementation of regulations relevant to authorities that require lead-based paint abatement, risk assessment or inspection to be appropriately trained and certified, training programs to be accredited and to be reliable, safe and effective. The second objective to reduce exposure to lead from drinking water is to revise the LCR based on input that they have EPA recently received from state, tribal, and local partners. The third objective for this step is to assist schools and child cares centers with a "3T's Approach (Training, Testing and Taking action) to reduce lead in drinking water and increase the number of schools and child care centers that test and provide parents with information on how to minimize children’s exposure to lead in drinking water. The second goal of the report is to identify lead-exposed children and improve their health outcomes. This report does not list much about their plan to address this other than providing a link for updates on this goal. The third goal, to communicate more effectively with stakeholders by creating an online portal to enhance. Then to consolidate and streamline federal-wide communication to the public, provide periodic updates on the progress of implementing the Federal Lead Action Plan on the online portal, enhancing local partnerships with community organizers, local health agencies, faith-based organizations, and private philanthropies to raise awareness of exposures to lead-based paint and the dangers it brings. The last goal, goal 4 supports and conducts critical research to inform efforts to reduce lead exposures and related health risks. Most of the objectives of this report are on track to complete their objective other than the efforts to finalize regulatory changes to the definition of lead-free plumbing products and make other conforming changes.
The CDC efforts to limit and reduce lead exposure through their creation and implementation of the Lead Contamination Control Act of 1988 to initiate program efforts to eliminate childhood lead poisoning in the United States. The CDC also have agendas such as Adult Blood Lead Epidemiology and Surveillance (ABLES). ABLES reduces the rate of adults who have BLL equal to or greater than ten micrograms per deciliter as a result of work-related- lead exposure. ABLES works with states and encourages them to develop effective working relationships with the lead exposure prevention programs in their states. Another effort is through the Healthy People, which aims to create a healthy world through science-based objectives. Healthy People 2020 aims to (1) identify nationwide health improvement priorities, (2) increase public awareness and understanding of the determinants of health, disease, and disability and the opportunities for progress, (3) provide measurable objectives and goals that are applicable at the national, State, and local levels, (4) engage multiple sectors to take actions to strengthen policies and improve practices that are driven by the best available evidence and knowledge, and (5) identify critical research, evaluation, and data collection needs. According to the brochure, the goals are to “attain high-quality, longer lives free of preventable disease, disability, injury, and premature death to health equity, eliminate disparities, and improve the health of all groups. Create social and physical environments that promote good health for all. Promote quality of life, healthy development, and healthy behaviors across all life stages.” [5]
Despite how promising these goals are for the EPA and the CDC they do not fulfill what the aim or plan. Considering this, these are not adequately serving America nor serving any environmental justice for all communities.

​Conclusion
      Lead is a known chemical that adversely affects the body of maturing youth and developed adults. Lead exposure is an environmental justice issue after analyzing and assessing the effectiveness of the efforts made to prevent exposure. Lead exposure can onset of lead poisoning. Which likely occurs and primarily exists within low-income more impoverished communities of color. Lastly, the limitations and regulations for lead exposure are not developed to mitigate, improve, or solve the problem of the lead infestation within these more impoverished communities. Arguments claimed by Lane, and the EPA supports and suggests that many of the efforts made are not enough to fix something, especially something created by concepts like the structural violence theory. 
 

Work Cited
H.R. Doc.L. Congressional Research Service-RL31243 at 1-27 (2017).
E. (2015, February 09). CDC's Childhood Lead Poisoning Prevention Program. Retrieved May 05, 2019, from https://www.cdc.gov/nceh/lead/about/program.htm?CDC_AA_refVal=https://www.cdc.gov/nceh/lead/acclpp/acclpp_main.htm
E. (n.d.). Chemicals in Your Community(pp. 1-29, Rep. No. 550-K-99-001). Environmental Protection Agency.
Enforcing Lead Laws and Regulations. (2019, February 20). Retrieved from https://www.epa.gov/enforcement/enforcing-lead-laws-and-regulations
Fatal Pediatric Lead Poisoning --- New Hampshire, 2000. (n.d.). Retrieved from https://www.cdc.gov/mmwr/preview/mmwrhtml/mm5022a1.htm
E. (2017, August 08). History of the Clean Water Act. Retrieved May 08, 2019, from https://www.epa.gov/laws-regulations/history-clean-water-act
Implementation Status Report for EPA Actions under the December 2018 Federal Action Plan to Reduce Childhood Lead Exposures and Associated Health Impacts(pp. 1-32, Publication No. 100-R-19-003). (n.d.). EPA.
Lane, S. D. (2016). Why are our babies dying?: Pregnancy, birth, and death in America. London: Routledge.
Lead Laws and Regulations. (2019, March 19). Retrieved from https://www.epa.gov/lead/lead-laws-and-regulations
Lead Violations Data. (n.d.). Retrieved from http://data.syrgov.net/datasets/c15a39a8a00e48b1a60c826c8a2cb3e0_0?orderBy=property_zip&page=20
Legislation. (2018, December 27). Retrieved from https://www.who.int/gho/phe/chemical_safety/lead_paint_regulations/en/
Special timeline: Leaded gasoline. (2015, March 13). Retrieved from http://environmentalhistory.org/about/ethyl-leaded-gasoline/lead-history-timeline/
Summary of the Clean Air Act. (2017, August 24). Retrieved from https://www.epa.gov/laws-regulations/summary-clean-air-act
Summary of the Clean Water Act. (2019, March 11). Retrieved from https://www.epa.gov/laws-regulations/summary-clean-water-act
Summary of the Comprehensive Environmental Response, Compensation, and Liability Act (Superfund). (2018, August 15). Retrieved from https://www.epa.gov/laws-regulations/summary-comprehensive-environmental-response-compensation-and-liability-act
Summary of the Resource Conservation and Recovery Act. (2018, August 15). Retrieved from https://www.epa.gov/laws-regulations/summary-resource-conservation-and-recovery-act
Summary of the Safe Drinking Water Act. (2017, August 24). Retrieved from https://www.epa.gov/laws-regulations/summary-safe-drinking-water-act
Summary of the Toxic Substances Control Act. (2018, September 19). Retrieved from https://www.epa.gov/laws-regulations/summary-toxic-substances-control-act


[1] PPB- parts per billion

[2] Plumbum- lead—symbol Pb

[3] Adult body- 16 years or older

[4]15 years or younger

[5]Healthy People 2020

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    Donnella Monk is an undergraduate researcher at State University of New York College of Environmental Science and Forestry. 

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