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So I would only caution that we do not mathematically translate the city study into a universal study.

Senator SCHWEIKER. Yes; you are saying that it is an estimate, but by the same token it is probably the only estimate that we have really had on this problem. If repurchase was necessary under the FDĂ Hazardous Substance Act, 0.06 lead, I gather this would cost considerable money. I wonder whether you had a figure estimating that?

Dr. DUĎAL. We had roughly estimating at $2 billion.
Senator SCHWEIKER. How much?
Dr. DU VAL. $2 billion.
Senator SCHWEIKER. $2 billion ?
Mr. Du Val. Yes.

Senator SCHWEIKER. I'm going to ask the council here to ask this question because it relates to financing. It is rather complex.

Mr. BATEs. In reference to section 301 and the appropriations shown in the law passed August 10, 1971, the Lead Based Paint Poisoning Prevention Act was appropriated $7.5 million except for section 301. Now section 301 of the authorizing legislation refers to the Housing and Urban Development and to the Department of Health, Education, and Welfare.

However, under section 201 of the authorizing legislation the Department of Health, Education, and Welfare is authorized to make grants for programs that will test and detect that the presence of lead poisoning on the surfaces of residential housing, and programs that will provide for the elimination of lead based paints from all interior surfaces, porches, and exterior surfaces to which children may be exposed. So that while section 301 has been excepted from the Appropriations Act, Health, Education, and Welfare is still authorized and appropriated funds to do that work.

Dr. Du Val. I will ask Mr. Novick to respond since he is in the granting business.

Mr. Novick. The amount of moneys appropriated did not exceed the authorization for title I, and in view of the restraint in the House and Senate conference report, directing us to use the moneys exclusively for screening and treating of children, and in view of our own approach to the child based strategy, we elected in writing the regulations to instruct the applicants to place emphasis on title I, the screening and treating of children.

Mr. BATES. And not to carry out any of the provisions of section 201?

Mr. Novick. Title II, no, except for innovative projects.

Senator SCHWEIKER. I mentioned a moment ago the pediatricians' stand on this, and I was wondering whether you folks took any basic issue with their contention of how they arrived at what they feel is a safe level. In other words, what is your Department's position relative to their expert testimony in terms of what a level of sa fe lead is at this point?

Dr. DuVAL. Mr. Chairman, I think it was hopefully reflected accurately in my testimony. We also set up a committee of our own to examine this issue, as we called it the DPI committee, daily permissible intake committee, and they have upon investigation sustained the position taken by the American Academy of Pediatrics, and we as a consequence through the regulatory arm of Public Health Service, FDA, have gone ahead and made the decisioon that we will embrace the conclusion reached by the American Academy of Pediatrics, the DPI committee, and other sources.

Senator SCHWEIKER. I had that general feeling from the tone of your testimony, but I just wanted to make that definite in my own mind.

The first effect of your new FDA regulation would begin to operate when in terms of reduction?

Dr. Du Val. In a manner of speaking it would become operational in terms of the first forced reduction, that is to say banning would become effective after December 31, 1972, in other words in 9 months.

Senator SCHWEIKER. From that point it takes how long to get down to 0.06?

Dr. DUVAL. We are suggesting that it be accomplished completely

within 1 year.

Senator SCHWEIKER. One year, all right. One other point. As it was brought out in our other testimony, one loophole in the present situation seemed to be the matter of pigments, and the matter of custom blending of paints. A manufacturer, for example, might well meet the tolerance of whatever the new standard might be, in this case it was 1 percent. Yet when a custom blender, someone who sold the paint in essence, at retail, would mix a pigment and paint together and cause high concentrations of lead in pigment and amount of pigment that went into that particular paint, this would obviate the good that the manufacturer might have done by following the standard. I wondered if your new regulation addressed itself to that specific problem where you have a local custom blending situation which is not unusual in the way the paint is handled today.

Dr. DŮVAL. We have what we hope will be as nearly a complete answer as possible. I think we would have to concede the point there is always the opportunity for some escape from this. Let me phrase it this way: as long as the paint after it is in the can, even having been reblended crosses Štate line, then this must hold. If it is customized for a specific customer right on that spot and resealed, we cannot control that as far as I know.

On the other hand, the type of situation one gets into where one customizes paint on that basis by and large is the single homeownertype person at a time, and we do not run into a situation of large units, housing developments and large construction matters where this of course for economic reasons cannot be done in that way.

Mr. Hutt. Dr. Du Val, I might add one comment. If the components, to be used in customized paints are shipped in interstate commerce for use in custom blending, the resulting paint would be required to meet these limits. As a result, basically, it would prohibit the interstate shipment of lead-based pigment for use in paints for household use.

Mr. SCHWEIKER. That is my next question. As I understand it as a layman from mixing pigments, are you going to require 0.06 level for the pigment because the pigment can vary in any paint depending upon the hue that the mixer wants? Are you setting one level for pigment? You have got a totally different problem here for the pigment and the paint. I think this is enough of a problem that you really have not fully addressed yourself to it. Maybe you folks have.

Mr. Hutt. Pigment would have to contain a low enough level of lead so that when mixed into a paint formulation, the final paint with which it is mixed would meet the requirements of the statute.

Senator SCHWEIKER. Would that be 0.06, or how do you determine that?

Mr. Hutt. That would be 0.05 at the end of the year and 0.06 at the end of the coming year.

Senator SCHWEIKER. Your regulation as proposed would apply to pigment as well as paint we are saying now. Is that very specifically the case ?

Mr. HUTT. Yes, sir.

Mr. SCHWEIKER. That is all the questions I have. I certainly thank you very much for being witnesses today.

Dr. DuVal. Thank you, Mr. Chairman.

Senator SCHWEIKER. Next we have Dr. Stanley M. Greenfield representing the Environmental Portection Agency, Assistant Administrator for Research and Monitoring.

Prior to his present appointment, Dr. Greenfield was head of the Department of Environmental Sciences and manager of the program environmental studies at Rand Corporation. Graduate of New York University, University of California at Los Angeles, he works primarily in the field of geophysics in the upper atmosphere.

We are very glad to welcome you today. I wonder if you would introduce your associates for the record.

STATEMENT OF DR. STANLEY M. GREENFIELD, ENVIRONMENTAL

PROTECTION AGENCY, ACCOMPANIED BY DR. VAUN NEWILL, SPECIAL ASSISTANT FOR HEALTH EFFECTS, OFFICE OF RESEARCH AND MONITORING, EPA; AND DR. KENNETH BRIDBORD, ASSISTANT TO DR. NEWILL

Mr. GREENFIELD. Thank you, Mr. Chairman. On my right is Dr. Vaun Newill, who is my assistant for health effects, and on my left is Dr. Kenneth Bridbord, who is Dr. Newill's assistant, and senior author of the draft technical report which has already appeared in extension of remarks in the Congressional Record on the question of control strategy for lead in paint.

Senator SCHWEIKER. You may go ahead with your statement, gentlemen.

Mr. GREENFIELD. Mr. Chairman, it is a pleasure to be here this morning to discuss with you the very serious problem of lead-based paint poisoning. The committee is to be commended for the interest and concern it has shown for this problem, evidenced by these hearings, which we trust will shed a great deal of light on the problem and its solutions. The Environmental Protection Agency is concerned with all aspects of environmental quality and with the elimination and prevention of hazards and threats to our environment.

I will address in my statement the seven questions that you have posed with respect to lead-based paint poisoning and the role of the Environmental Protection Agency as it relates to that problem.

Primary responsibility for limiting the amount of lead in paint and related research activities rests with HEW and HUD. EPA has expertise with regard to trace metal pollutant burden research in general and thus can contribute as a consultant to HEW and HUD with regard to the problem of lead in paint. When evaluating any environmental pollutant EPA must consider all sources of known or potential human exposure. In this regard, contributions to lead body burden resulting from lead-based paint ingestion are included in our analysis of lead exposures from other environmental sources.

Formal coordination between EPA, HUD and HEW regarding the problem of lead-based paint poisoning occurs via two committees; the Lead Liaison Committee and the OST-CEQ jointly sponsored Ad Hoc Committee for Coordination of Environmental Health Research. In addition to these formal coordinating mechanisms a great deal of informal contact exists. Included in this informal interchange are discussions of current research programs as well as identification of specific problem areas potentially requiring further study.

The primary thrust of EPA pollutant burden research is to evaluate environmental exposures to many trace substances from a variety of sources. Populations included in these studies are not those from whom much information concerning the presence of lead paint in homes can be derived. These same study techniques, however, can potentially be adapted to furnish this information.

Adults with no unusual sources of lead exposure ingest this substance primarily through food, through water and via the air. Although exact contributions from each of these sources to blood lead and to lead body burden in this group are somewhat variable, a general approximation can be made. Assuming that adults inhale approximately 23 cubic meters of air each day containing 2 micrograms of lead per cubic meter, of which approximately one-third is absorbed, and assuming that the average adult ingests 300 micrograms of lead each day from food and water-mostly from food from which 10 percent is absorbed, we conclude that a total of 45 micrograms of lead, that is, 30 micrograms from food and water and 15 micrograms from air, constitute the average adult daily lead absorption. Continued daily lead absorption at this rate of 45 micrograms would result in a blood lead level of approximately 22 micrograms per 100 grams. This is well within the expected normal blood lead range. However, as sources of lead absorption increase blood leads would rise acordingly. Thus, under these circumstances approximately one-third of lead absorbed in nonoccupationally exposed adults would come from air and the remaining two-thirds from food and water.

For children this breakdown is slightly different. Using average figures for a 10- to 18-kilogram, 1- to 3-year-old child, we conclude that a total of 17 micrograms of lead, that is, 13 micrograms from food and water and 4 micrograms from air, constitutes the average daily lead absorption.

This again assumes a 10-percent absorption from an average daily oral intake of 130 micrograms of lead and one-third absorption of inhaled lead at 2 micrograms lead per cubic meter with an average inhalation of 6 cubic meters of air each day.

Thus, under these circumstances and in a child with no significant additional sources of lead exposure approximately one-quarter of absorbed lead comes from the air and the remaining three quarters from food and water. Of critical importance is the recognition that especially for children additional sources of lead exposure via either oral or respiratory routes will contribute significantly to elevations in blood lead and body burden.

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Unquestionably the prime contributing factor to lead poisoning in children is peeling paint from deteriorating housing. Repeatedly surveys have shown that 80-90 percent of reported cases of clinical lead poisoning are associated with deteriorating housing containing leadbased paint. Ingestion by children of even minute quantities of peeling paint containing lead constitutes a significant health risk.

Under the assumption that body burden dynamics in children are similar to those in adults, a daily oral intake of 43 micrograms of lead per kilogram—with an absorption of 10 percent of 4.3 micrograms per kilogram per day—if continued only 4 months will increase blood lead above 50 micrograms per 100 grams. Regular daily ingestion for an additional 4 months would result in a blood lead level in excess of 80 micrograms per 100 grams, a level consistent with clinical lead poisoning in children.

Estimates of lead ingestion from peeling paint are readily available. Intake of only one lead paint chip per day with a surface area of 1 square centimeter and containing six layers of 1-percent lead paint corresponds to an ingestion of 400 micrograms of lead per day, or 40 micrograms per kilogram in a 10 kilogram child. As explained above, based upon data extrapolated from adults, continued ingestion at this level for only 4 months would produce a dangerous elevated blood lead level. Further, children this age often ingest many more than one such paint chip per day and/or single chips much larger than 1 square centimeter containing more than six layers of lead paint. Clearly on this basis paint containing considerably less than 1 percent lead will not eliminate the problem of lead poisoning in future generations.

EPA is concerned with the problem of reducing all unnecessary environmental lead exposures. Although clearly HEW and HUD have primary responsibility for dealing with lead based paint poisoning EPA felt obliged to respond to a request for comments regarding an FDA proposal to “label as hazardous interior paint in excess of 0.5 percent lead” (Federal Register, November 2, 1971). EPA scientists thus conducted a theoretical analysis based upon the best currently available data to determine the maximum safe amounts of lead in paints for interior residential surfaces. A first draft copy of this inhouse technical report entitled "A Control Strategy for Lead in Paint" appeared in the February 9, 1972, Congressional Record Extension of Remarks, pages 1010–1011. We would like to make a copy of that draft report available to you for the record.

Mr. SCHWEIKER. We would like to have it. Thank you. (The information referred to follows:)

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