Below is testimony that Clean Air Watch presented today at a U.S. EPA hearing on proposed new national lead standards:
Statement on EPA proposed NAAQS standards lead
Docket number EPA-HQ-OAR-2006-0735
June 12, 2008
My name is Frank O’Donnell and I am president of Clean Air Watch, a non-profit, non-partisan clean air watchdog organization.
Thank you for the opportunity to speak today. I will be very brief.
I am here to urge you to strengthen your proposal. Unless you make this proposal better, children will remain at risk of seeing their IQs stolen away -- just so some polluting companies can save a little money.
Before I go into details, let me point out that your scientific review of this pollutant has already achieved some positive results. Several years ago, Clean Air Watch led an effort to eliminate a prime source of lead emissions – from the leaded fuel used in NASCAR races.
EPA’s so-called criteria document noted that race car drivers, fans and even nearby residents faced a risk from lead exposure. We pointed out this document to the head of EPA, Stephen Johnson, and in a letter called on him to monitor pollution levels at NASCAR tracks. The day after our letter became public, NASCAR abruptly stopped years of stonewalling, and announced it would eliminate use of leaded gasoline.
So one step towards cleaner air. But there are other lead threats out there.
When the U.S. EPA set the current lead standard – almost 30 years ago – we knew a lot less about this toxin than we do today.
We know now that even very tiny amounts of lead on children’s blood can cause neurological problems – making it harder for children to learn.
And even though EPA has proposed to make the old standard stronger, once again the Administrator has proposed a range that includes levels weaker than those recommended by EPA’s independent science advisers.
We saw this with EPA’s standards for fine particle soot. We saw this with EPA’s standards for ozone. We hope this won’t happen yet again.
The upper bound of the range suggested by your science advisers was 0.2 micrograms per cubic meter. Yet EPA has proposed a range that could permit at least 50 percent more lead in the air.
Your proposal seems both illogical and at odds with the science. In theory, you are seeking to make sure that levels of lead in children’s blood are not harming them – that there is no “neurological deficit.”
But your proposal would permit levels of lead in the air that by your own analysis would permit unhealthful levels of lead in the blood. Both your own scientists and the independent scientists reported that 0.2 was absolutely the upper limit – and your own scientists even recommended a range that considered an order of magnitude lower.
The upper end of your proposal has no margin of safety. It would not adequately protect children.
So we urge you not even to consider a standard higher than 0.2 micrograms per cubic meter, averaged on a monthly basis.
And because of the scientific evidence for enhanced effects at lower levels of exposure, and the need to ensure that all children have a safe blood lead level, with an adequate margin of safety, we recommend that EPA set a final standard below 0.1 microgram per cubic meter.