COMMENTS SUBMITTED TO U.S. ENVIRONMENTAL PROTECTION AGENCY Public Comment Draft of the EPA Strategy to Reduce Lead Exposures and Disparities in U.S. Communities

The document argues that the EPA's Draft Strategy to Reduce Lead Exposures and Disparities in U.S. Communities is too tentative and fails to commit to the necessary regulatory changes to protect public health. The authors demand the strengthening of the Lead and Copper Rule, the adoption of health-based lead hazard standards for dust and soil, the phase-out of leaded aviation gasoline, and more rigorous cleanup of Superfund sites. They emphasize that lead exposure disproportionately affects communities of color and low-wealth populations, constituting a significant environmental injustice. The coalition calls for a 'whole of government' approach involving the FDA, HUD, and CDC to address lead in food, housing, and pediatric testing.

• The authors argue that the EPA's Draft Lead Strategy is characterized by 'tentativeness, not resolve,' and fails to commit to essential regulatory changes required by court orders and statutory deadlines.
• The coalition asserts that the Lead and Copper Rule (LCR) is 'fundamentally broken' and 'utterly ineffective,' noting that recent revisions narrowed the definition of 'lead service line' to exclude joints and connectors, which may mislead the public and delay remediation.
• The document demands that the EPA adopt health-based lead hazard standards of zero (0) μg/ft2 for all surfaces regarding dust-lead and zero (0) parts per million for soil-lead, arguing that any amount of lead in dust is a condition resulting in adverse health effects.
• The authors identify leaded aviation gasoline (avgas) as the 'single largest source of lead to the air,' contributing approximately 70 percent of the National Emission Inventory in 2017, and urge a swift regulatory phase-out.
• The coalition calls for stricter air toxics rules for industrial sources, specifically mentioning secondary lead smelters, lead acid batteries, primary copper smelters, steel manufacturers, and coal/oil-burning power plants.
• The document criticizes the EPA's management of Superfund sites, specifically the USS Lead Site in East Chicago, where it claims residents were not informed for decades that their housing was built on a lead smelter footprint.
• The authors urge the EPA to collaborate with the FDA to set enforceable, health-protective regulatory limits for lead in baby food, bottled water, and food contact articles, noting that current standards have not been updated in decades.
• The coalition highlights a systemic environmental injustice, stating that Black children's blood lead levels were the highest among children with the highest levels in 2013-16, and that lifetime earnings lost due to childhood lead exposure are 46-55% higher for Black children than for white or Hispanic children.
• The document requests that the EPA provide specific estimates on the number of full-time employees, costs, and time required to complete each necessary rulemaking to ensure the agency has sufficient staff capacity.

APA

Earthjustice (2022). COMMENTS SUBMITTED TO U.S. ENVIRONMENTAL PROTECTION AGENCY Public Comment Draft of the EPA Strategy to Reduce Lead Exposures and Disparities in U.S. Communities. https://earthjustice.org/wp-content/uploads/2023/10/comments-submitted-to-epa-public-comment-draft-of-the-epa-strategy-to-docket-epa-hq-olem-2021-0762-.pdf

Chicago

Earthjustice. COMMENTS SUBMITTED TO U.S. ENVIRONMENTAL PROTECTION AGENCY Public Comment Draft of the EPA Strategy to Reduce Lead Exposures and Disparities in U.S. Communities. 2022. https://earthjustice.org/wp-content/uploads/2023/10/comments-submitted-to-epa-public-comment-draft-of-the-epa-strategy-to-docket-epa-hq-olem-2021-0762-.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=COMMENTS SUBMITTED TO U.S. ENVIRONMENTAL PROTECTION AGENCY Public Comment Draft of the EPA Strategy to Reduce Lead Exposures and Disparities in U.S. Communities |date=16 March 2022 |url=https://earthjustice.org/wp-content/uploads/2023/10/comments-submitted-to-epa-public-comment-draft-of-the-epa-strategy-to-docket-epa-hq-olem-2021-0762-.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2022comments, author = {{Earthjustice}}, title = {{COMMENTS SUBMITTED TO U.S. ENVIRONMENTAL PROTECTION AGENCY Public Comment Draft of the EPA Strategy to Reduce Lead Exposures and Disparities in U.S. Communities}}, publisher = {Earthjustice}, year = {2022}, month = mar, url = {https://earthjustice.org/wp-content/uploads/2023/10/comments-submitted-to-epa-public-comment-draft-of-the-epa-strategy-to-docket-epa-hq-olem-2021-0762-.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }