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July 31, 1997 Letter from Don Ryan to Steve Galson


July 31, 1997

MEM TO: Steve Galson, M.D.

Office of Children's Health Protection


FROM: Don Ryan

I hope that you are doing well. This is to call to your attention an issue now pending decision before EPA that I think offers a potential win for public health. The issue is a "Project XL" application from the City of Portland, OR to forgo optimum treatment to reduce lead in drinking water in favor of strategies to reduce lead-based paint and dust hazards in housing.

I call this to your attention for two reasons. First, this seems like just the kind of cross cutting issue that may present an opportunity for your office to weigh in and make a real difference. Second, I have through the grapevine that some within EPA have expressed skepticism that this proposal effectively amounts to "giving up real environmental controls in drinking water for a little health education."

I do not know enough about the proposal to offer an unqualified endorsement. But everything I have heard about it from a number of sources suggests that it may offer real promise. In any event, I think the proposal deserves very careful consideration by EPA, and I would hope that your office might be helpful in elevating this issue to ensure that it gets proper attention.

I do know that this issue has been the subject of an ongoing public dialogue within Portland for more than a year. Chris Johnson of the Health Department is a very solid public health guy and a progressive thinker whose judgment I trust. The motivations of the folks at the utility also strike me as legitimate. The fact that they have already gone ahead and put up the matching funds for the ClearCorps project indicates that they care about more than simply the bottom line of cost avoidance.

Portland has done fairly intensive blood lead screening and has a pretty good handle on the nature of their lead poisoning problem, which is overwhelmingly associated with deteriorating lead paint and improperly conducted housing renovations. It seems indisputable to me that the potential public health payoff in terms of blood lead reductions in Portland is far greater through control of lead-based paint hazards than through further drinking water treatment.

The Alliance is very sensitive to the tendency of some to look to education as the easy answer to childhood lead poisoning. Were this proposal simply a public education program aimed at raising parents' awareness of lead poisoning and urging hand-washing and high calcium diets, it would definitely not have our support. But it is my impression that the health department, the water authority, the city council, and the community at large have a much broader and more meaningful program in mind to control lead-based paint hazards in housing.

It seems to me that there is a real opportunity here for Portland to use this Project XL approval to make cutting-edge progress in demonstrating that fundamental changes can be made city-wide in controlling and preventing lead-based paint hazards. In addition to the conventional public awareness education through PSAs and such, this could involve such strategies as:

. Training in lead safety for apartment maintenance staff. (Next week HUD and EPA officially unveil an excellent one-day "basic training" course developed specifically for apartment maintenance staff which could be widely offered by the health department, adult education centers, by community groups, etc.)

. Training in lead safety for painters and remodelers. This could be offered in concert with local unions, contractor associations, community organizations, etc.

. Jobs training in lead hazard evaluation and control for workers from those communities hardest hit by lead poisoning and assistance to small contractors in overcoming barriers to entry, such as liability insurance. (I understand that Portland is applying for the current round of HUD lead hazard control grants of up to $4,000,000.)

. An intensive program of education through hardware and paint stores about unsafe paint removal practices. (The interest that Home Depot, Sears, and Lowe's have each expressed in this nationally, might "catch on fire" in Portland if it were part of a broader, intensive local effort.)

. Continuation and expansion of the recently launched ClearCorps project to control lead hazards in high risk homes using Americorps teams.

. Establishment of a "lead-safe housing registry" to help at-risk families find safe housing (and to aid in the relocation of families of EBL children if hazards cannot be promptly controlled).

Of course, the people of Portland need to decide upon which strategies for controlling lead hazards in housing make the most sense to them. I offer the above ideas simply to illustrate that this project has the potential of accomplishing much, much more than pushing hand-washing PSAs aired after children are asleep. A program encompassing just a few of the strategies above would be more ambitious than any existing models. This kind of training of property owners, contractors, painters, and home owners would well lead to voluntary adoption of Essential Maintenance Practices by rental property owner associations or incorporation in the health or housing codes. When I shared these ideas with folks from Portland in a brainstorming mode at a recent meeting, I found them genuinely receptive.

While I can imagine that EPA's Office of Drinking Water may have some anxiety about the precedent that approval of this XL Project might establish, I would urge the Agency to take a hard, objective look at this project's potential for bringing about substantial, structural changes that would greatly reduce exposures to lead-based paint hazards in housing and make a real dent in childhood lead poisoning in Portland. We have been searching for a community that is willing to make a broad scale effort to change the way that lead-based paint in older housing is managed. Portland just might be that place.

Please pass on my regards to Phil Landrigan. And I would be happy for you to share this note with the folks in Drinking Water, the Administrator's office, Region X, or elsewhere within EPA. I would also be delighted to discuss this further with any EPA staff who are interested. I look forward to seeing you soon.

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