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because the doctors and other health professionals are unfamiliar with analyzing this kind of problem.

I do not question the fact that many of the poor rural communities do not have paint, and I think your other analysis is right. I think it would be useful if we could try as best we can to find out what is going on in these rural communities.

Mr. FINGER. I think your assumption is probably correct, as one factor that is involved in this difference. For one thing, there are not many large cities that have full-scale screening programs, and I think there is less of a chance of getting lead screening tests in rural areas where there is not quite the Government organization to conduct such tests, nor the funds available.

The Surgeon General has cited estimates that approximately 400,000 children have a blood lead level of 40 micrograms/100 milliliters or above, a condition which he has defined as excessive.

The NBS analysis indicates the number may be as high as 600,000. But this is based on an extrapolation of limited data obtained in cities with lead-screening programs. Our analysis also shows that 50,000 to 100,000 of these children may have so much lead in their bodies that they require treatment.

The identification of specific dwelling units in which there is an existing lead-based paint hazard involves, first, the detection of hazardous amounts of lead on surfaces and, second, an evaluation of the accessibility of the lead to the child. Both of these points are considered and discussed in great detail in the NBS reports.

A number of physical and chemical procedures for the quantitative determination of hazardous amounts of lead and their suitability in lead poisoning control programs have been considered. These techniques have been evaluated in terms of their ability to detect lead at 1 percent lead levels, their cost, portability, and other performance characteristics which one must consider in the selection of a suitable instrument.

As a general conclusion, it is found that the portable methods such as chemical spot tests and X-ray fluorescence units which are relatively expensive in initial cost—they run about $4,000 each, which is not in itself expensive, but there would have to be quite a few units that the local community would need in conducting an inspection program. But in any case, they are comparatively inexpensive to apply because it is possible to use relatively unskilled personnel.

I might indicate the inspection is not as severe from a cost point of view as the cost of removing or eliminating the hazard.

Since the portable X-ray fluorescence instrument has found widespread use in lead poisoning control programs, special emphasis is being given to the evaluation of these instruments. The NBS is undertaking a field evaluation of the available commercial instruments and will provide us with a report on their use and limitations. At the present time, however, the X-ray instruments do not provide sufficient sensitivity for levels of lead below 10 to 15 percent. Further development is still needed.

The laboratory instruments which are available provide sufficient accuracy at the lower, hazardous, lead levels but have the disadvantages of high capital cost of the equipment, the necessity for sample collec

tion, and the need for relatively skilled personnel to perform the analysis.

Obviously, central laboratories would minimize the cost to any community, and that is one of the proposed changes from the original bill made in S. 3080.

The cost per analysis using the field methods are below 25 cents per sample, while those using the laboratory instruments are above the $1 per sample, with an additional $2 per sample for collection costs; going out and actually taking the samples back to a laboratory.

About 20 samples are required to check out a dwelling unit. Obviously properly trained volunteers could do some of the sample collection, and central laboratories could do the analysis.

Although improvements are needed in this area, I believe inspection methods do exist, and we do have ways of measuring the amount of lead on walls.

The importance of the condition of the painted surface in contributing to a hazardous condition has been indicated. In one New York City study, 76 percent of a group of children with lead poisoning lived in dwelling units with peeling paint. In a matched control group of children with normal blood lead levels, 38 percent of the children lived under similar conditions. Our research reports discuss in detail conditions which can be defined as hazardous and the various alternatives for the elimination of the hazard.

Obviously, a child with an elevated blood level should not be returned to a hazardous environment. The elimination of the existing lead hazard is necessary for this child but the elimination of lead hazards from all housing units represents the ultimate preventative approach to lead-based paint poisoning.

The main problem in hazard elimination is the high cost of using the available technology. Many existing and potential methods for hazard elimination have been identified and evaluated by our research.

The methods have been evaluated as to their cost, the work involved in eliminating the hazard and the acceptability of the end result.

Basically, the methods fall into two categories: Total removal of the hazard or covering of the hazard with some other material. Some of these methods are comparatively inexpensive but have other problems.

Incidentally, all of these hazard elimination methods are very expensive when they are compared with the cost of inspecting the units to determine whether they have hazardous lead levels.

For example, paint removal using solvents or sanding or burning off the paint may present hazards such as flammability or poisonous fumes or lead dust-hazardous to the workmen-as a result in some cities they are prohibited by law. Trained workmen should be able to use such methods with proper precautions.

In other techniques, such as the use of wallboard coverings, the basic material is inexpensive but a fair amount of skilled labor may be required to obtain an acceptable job, which adds considerable cost to the method.

The cost of hazard elimination is high. The square footage costs for most of the hazard elimination techniques range from 50 cents to $1.50 per square foot. The city of Chicago spends about 80 cents to $1 per square foot for hazard removal. The total cost for a dwelling unit may vary considerably depending on how much work is done. Washington, D.C., reports estimated spending of about $300 per dwelling unit, while Chicago costs run as high as $2,000 a unit. It is not known at this time how effective each of these is in eliminating the hazard.

Senator KENNEDY. Did you not do something of that in title III of the act? We asked HUD to really research and come up with some definitive recommendation specifically in this area.

Mr. FINGER. Yes; I will continue on this point to give more of an impression than firm definitive conclusions on the costs involved.

We do need more work in this and should go on to developing methods, but if we assume the 7 million units that we have estimated as the number of units that offer a present lead hazard, then if we simply use these costs, the total cost of removal or covering, using the methods used in Washington and Chicago, would be $2 billion to $14 billion for elimination of the hazard.

The Bureau of Standards has estimated dollar costs substantially higher than that for actual removal or covering of units, going up to $5,000 and maybe even $10,000 a unit.

Senator SCHWEIKER. What would their figures come out to?

Mr. FINGER. The NBS figures have gone as high as $5,000 to $10,000 a unit.

Senator SCHWEIKER. What would the total be?

Mr. FINGER. Multiply that by the 7 billion units and that would then be $70 billion as a maximum; $35 billion for the lower number that they have; if we use the Chicago methods, which we have not fully evaluated yet, it is $14 billion.

I think, though, what that indicates is that the cost requirement to actually remove all paint or cover all paint that may have lead may not be a realistic approach in terms of the revenues that are available to local communities or dwelling owners.

Therefore, there may be other approaches we should be emphasizing related more to code enforcement and maintenance programs that remove peeling paint and warning programs that, as I will go on to indicate, warn residents of dwelling units in which lead paint exists of the potential hazards, and the precautions that ought to be taken in the event there is peeling paint or if a child ingests it.

Greater awareness created at the local level about the possibility that a hazard exists is what we are really suggesting.

Senator KENNEDY. It certainly shows the importance of the program that we are talking about. When we start talking about figures as high as $70 billion, $5 million, just to try to find out the best way of coping with the problem, seems to be a very modest investment that may have extremely broad-based implications.

Nr. FINGER. I think it is very important to do research, development and demonstration work.

Senator KENNEDY. I know you are a little more than two-thirds of the way through your statement. I am going to have to leave for just a few minutes to go to the Judiciary Committee. Senator Hughes will be here and then I will return, hopefully in time to catch up with the latter part of your testimony.


There are just a couple of areas, if I might ask you about these, please, Mr. Finger.

Are you prepared, or is the Department prepared, to support a lead level in paint at this time?

Mr. FINGER. We have not really determined the full validity, frankly, for the lead level that is included within S. 3080. We do have some questions about the way that was determined, and I have gone back to some of the documents that were issued by the American Academy of Pediatrics in that area.

I think here there has to be a match between what the hazardous level is and what we can achieve, and it seems to me it is a dynamic situation that we are still in. We are still conducting research and analysis of both the hazards and the paint technology, and there is, I think, going to be a changing and improving capability to cut the lead level.

The industry itself, I think, has gone very far and this is indicated by our analysis of paints, where most of the paints we have tested have been at lead levels below a tenth of a percent; so we are beginning to get close, but there is still some paint that is above a 1-percent lead level.

We think it is a complex problem. We really are not ready to specify what that number should be.

We also think the daily permissible intake number should be a medically determined number. We do not think we are really the ones to judge that.

However, going from that medical level, converting it to the amount of lead in paint on walls, and the amount of lead in paint in the canmaking that transition—is a process that we should be involved in.

Senator KENNEDY. You see that even under your test here—which we just received from you—the results of the survey show that 80 percent of those paints that are being used are complying with less than 1 percent; 20 percent of the samples are in excess of 1 percent. Some of the violations have been in labeling. And some of the labeling according to your measures—and I think according to our information is misleading.

Mr. FINGER. Yes.

Senator KENNEDY. Perhaps we can get into that, but certainly 80 percent of those that have been surveyed-I want to be careful to point out that survey was not a random sampling-I think it would be a pretty fair and reasonable survey; 80 percent are in compliance with the 1 percent lead requirement.

The current legislation requires 1 percent. That does not go as far as the AAP would like to go. But I think certainly, in terms of legislation in this area, we are going to ask HEW their views about it, and I think it would be important as well if we get some indication by HUD based upon the material that is available, as to where they think that breakoff point ought to be.

Mr. FINGER. Yes. I do not think there is any question but the level can and should be below 1 percent lead level.

I think it can be kept at half a percent lead level, from everything that we have seen and from my understanding of it.

The industry certainly accepts that range as well.

The American Academy of Pediatrics also indicates that the .06 percent they suggested includes a factor safety of five for adverse effect on metabolic performance, and a factor of 20 on really serious illness.

Dr. Chisolm, I am sure, will talk about that further; but that does indicate that some margin can be applied.

Senator KENNEDY. Then your suggestion is that we go down below the 1 percent

Mr. FINGER. I think we could and should.

Senator KENNEDY (continuing). But as to the .06 percent or the .05 percent?

Mr. FINGER. I think a .05 percent is a number that we could establish without any problem.

Dr. BILLICK. That is correct.
Mr. FINGER. From everything we have seen.

Mr. Chairman, I do have an addition to the samples analysis that were referred to in the Secretary's letter to you, in response to your request; we do have another hundred samples that have been taken, and that too indicates generally the same result as the first 98 samples that we analyzed.

The indication there too is that a large amount of the paint has lead levels below half a percent, but also there is a discrepancy in the labeling process for paints with greater than 1 percent lead.

Senator KENNEDY. I would like to ask if you could not reach a Department position on that exact percentage. We are going to try to move this legislation along as rapidly as we can, but it would be helpful at least to have your position.

We will get it from HEW as well; but after this week, we are going to move the legislation, as I say, so could you try to see what you can do in terms of a number as specific as possible?

We, as you know, have taken the AAP recommendation in terms of our legislation. This is a different one obviously. It goes a long way from the 1 percent that is in the current law, the 0.05 or the 0.06 percent which you have suggested here.

Mr. FINGER. We will do that, Mr. Chairman. We will be meeting with HEW, and we will try to arrive at a joint agreement.

I might mention, though, that I think a number set at this point ought to be a number that we reasonably are assured is a good control level from the medical point of view; but also one that is achievable with paints that are available or can be available in the reasonably near future.

There might be some kind of stipulation that suggests under the Hazardous Substances Authority that there ought to be an effort to cut below 0.5 percent on a continuing basis.

Senator KENNEDY. We will hear from you to get your position on that. Let me ask this. Did HUD request any funds in 1972? Are you prepared to request funds for 1973 ?

Mr. FINGER. Mr. Chairman, we have included funds within our single research appropriations activities that cover all of the areas that are important in the housing and community development functions that we have.

Included within our single research appropriations, therefore, are funds for work in this area. We have basically relied on our broad research and demonstration authority to include those funds.


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