Virtual Public Listening Sessions on EPA's draft Lead Strategy to Reduce Lead Exposures and Disparities in U.S. Communities
Docket ID: EPA-HQ-OLEM-2021-0762
R3 Public Listening Session 
Date: March 3, 2022
Start Time: 6:00 PM ET 
Record of Public Comments
(To view a recording of the listening session, please visit: https://youtu.be/QkFc5HyTPTo)

36:37
[Neil Boyer, NAACP-Washington, DC Branch] Neil Boyer: Thank you.
36:39
Neil Boyer: My comment is
36:42
Neil Boyer: You know, on December 16th, you know, the EPA talked about using the statu -statutory authority under the safe drinking water act to protect all Americans from lead in drinking water and this is in consistent with President Biden's goal to remove 100% of lead server pipes.
37:00
Neil Boyer: Now, I'm calling from Washington DC and our first challenges is we have differences in estimating the number of lead water service lines there are. The water utility says there were 28,000 lead water service line serving district homes, yet the office of the chief financial officer
37:21
Neil Boyer: assumes that they have 48,000 service parts which are made of lead. So my question to EPA is, what measures can EPA take to ensure that water utilities, such as DC water, providing accurate count of the number of lead service lines?
37:42
Neil Boyer: My second question is, we know that lead is a dangerous neurotoxin,
37:49
Neil Boyer: especially dangerous to children. In 20 - 2021, 29.4% of ward eight residents where age 17 and younger, and 26.9% of ward seven residents were age 17 or younger. These wards are significantly younger than the city as a whole. These are also the wards with the largest African-American populations.
38:13
Neil Boyer: So my question is, if EPA is advocating the complete removal of all lead service lines by 2030, what provisions are envisaged to ensure that effected residents have access to lead-free water, while the lead pipe replacement programs are underway?
38:33
Neil Boyer: Why doesn't EPA mandate that water utilities provide lead water filters or portable water alternatives, at no cost to their customers until such a time that lead service lines connected to these residences are fully replaced and they are no longer at risk?
38:56
Neil Boyer: According to the DC Department of Energy and Environment, 151 children under the age of six, in Washington DC, had elevated blood lead levels in 2021. 143 in 2018. 144 in 2020. 135 in 2019.
39:16
Neil Boyer: Just over the past four years, an average of 143 families in Washington DC have had to deal with members of their households being affected by lead exposure and poisoning.
39:31
Neil Boyer: Thank you.
40:00
[Carla Campbell, Private Citizen] Carla Campbell: Good evening, I'm Dr. Carla Campbell. I'm a retired pediatrician, trained in environmental medicine.
40:08
Carla Campbell: I directed or co-directed the lead evaluation clinic at the Children's Hospital of Philadelphia, during which I cared for children with lead poisoning, some with extremely high lead levels.
40:23
Carla Campbell: I also acted as a pediatric consultant for the Childhood Lead Poisoning Prevention Program of the Philadelphia Department of Public Health.
40:37
Carla Campbell: I was on the advisory committee for Childhood Lead Poisoning Prevention for the Department of Health and Human Services and the CDC
40:49
Carla Campbell: for eight years. During which I chaired the Committee for six years. Therefore, I have been very involved in childhood lead poisoning prevention and treatment throughout the course of my career.
41:04
Carla Campbell: I think, in general, there should be an emphasis on primary prevention of lead toxicity by screening homes prior to pregnant women and young children moving into them.
41:18
Carla Campbell: And updating standards for lead in house dust and soil and yards. I would also like to see some prevention work for lead exposure in air, water and soil,
41:33
Carla Campbell: as well as the elimination of aviation gas as a source of exposure. The national ambient air quality standards for lead have not been updated in quite some time,
41:49
Carla Campbell: as is the case for the EPA standard for lead in water. Lastly, exposures to cultural products such as Asian and Hispanic foods, spices, ceramics, cookware, cosmetics, etc, need to be explored and prevented.
42:13
Carla Campbell: I am a member of Project TENDR - stands for Targeting Environmental Neuro-Developmental Risks. This is a group of 50 to 60 scientists, clinicians, and childrens' advocates.
42:29
Carla Campbell: This group will be creating written testimony, in conjunction with Earth Justice, and more specific comments regarding the draft summary. I will be helping to formulate these comments to the EPA prior to the March 16
42:48
Carla Campbell: deadline. Thank you for letting me present these comments.
43:19
[Julia Cohen, Plastic Pollution Coalition] Julia Cohen, Plastic Pollution Coalition (PPC): Hi, Thank you so much,- great. Thank you so much for for holding the sessions and
43:25
Julia Cohen, Plastic Pollution Coalition (PPC): I'm Julia Cohen, from the Plastic Pollution Coalition. We are a 13-year old coalition of over 1200 organizations and businesses from around the world.
43:34
Julia Cohen, Plastic Pollution Coalition (PPC): The majority of which are in the United States. I'm personally based in Washington DC and have just had my pipes changed on my own street so,
43:42
Julia Cohen, Plastic Pollution Coalition (PPC): this is - um, feeling very, very personal, as well as the work that we do. It's great to replace all lead service lines and it's long overdue, I'm sure you guys all agree.
43:54
Julia Cohen, Plastic Pollution Coalition (PPC): However, I wanna make sure that - that we don't replace one thing with another long-term problem, and that the replace pipes are not replaced with PVC,
44:04
Julia Cohen, Plastic Pollution Coalition (PPC): or any kind of plastic pipes. You know, it's - it continues to be an environmental justice issue and it's not just the pipes when they're in use, but it's the creation of the pipes, the manufacturer of plastic pipes - PVC pipes is, you know - happens in - at the fenceline and frontline communities,
44:22
Julia Cohen, Plastic Pollution Coalition (PPC): and causes toxic pollution in the air, in the water, in those communities as well, let alone, what is known already to leach from those pipes so,
44:33
Julia Cohen, Plastic Pollution Coalition (PPC): I think it's hugely important to add that, to follow the guidance in the mix that there is a recommendation against the use of plastic replacement pipes. Um, and that you can't leave this to each state - that this has to come from the EPA. It has come from the federal level.
44:53
Julia Cohen, Plastic Pollution Coalition (PPC): And then, I would also say, there's - you know, examples. Like Newark, New Jersey replaced with copper pipes. And yes, it's more expensive but it is a long-term health - major health prevention
45:04
Julia Cohen, Plastic Pollution Coalition (PPC): problem - issue. So that said, I also think, in the meantime it's really important that what communities who know have high lead issues and lead pipe issues
45:16
Julia Cohen, Plastic Pollution Coalition (PPC): are provided with filtration and not plastic bottles of water. I was glad to hear that the EPA will not allow the federal funding to be used to purchase single-use plastic water bottles
45:27
Julia Cohen, Plastic Pollution Coalition (PPC): when in-house water is not available during installation. But what about communities that - you know, are going to spend their own money on it? I think there needs to be a recommendation that they don't do that.
45:38
Julia Cohen, Plastic Pollution Coalition (PPC): And then there also needs to be a provision made to support access to filters, for filtered water.
45:43
Julia Cohen, Plastic Pollution Coalition (PPC): And then, what about the recommendations and support during the lag time from detection and inventory, to when
45:50
Julia Cohen, Plastic Pollution Coalition (PPC): the remediation actually is finally in place? And even the guidelines that, for six months after replacement you need to be filtering your water? So that's me. That's us. Those are our concerns. Thank you so much for including them and listening - appreciate you what to do.
46:34
[Kevin Kauffman, UPMC Lead Poisoning Prevention & Ed.] Kevin Kauffman: Good evening, my name is Kevin Kauffman. I'm with UPMC Lead Poisoning Prevention and Education Program. We cover a 15-county area in south central Pennsylvania, doing lead risk assessments for children with elevated blood lead levels.
46:50
Kevin Kauffman: Um, the only three points that I wanted to ask about with this draft legislation is the first one that we talked about with the enhanced lead-safe work practices through education and outreach.
47:04
Kevin Kauffman: It looks like a lot of the education is going towards contractors, but I would suggest that we should also look at focusing education towards municipalities, specifically ones that conduct their own permitting for work that's being conducted on pre- 78' houses.
47:23
Kevin Kauffman: Um, another point was for the water safety water qualities.
47:29
Kevin Kauffman: EPA still does not regulate private wells. There's still a lot of people that do utilize private wells, so the curiosity, for me, is if EPA would step in for private wells if there is a upstream source of contamination for lead in the private well water system?
47:53
Kevin Kauffman: Um, and the last thing I just wanted to point out was with a lot of the education and materials that are brought in the country now, specifically talking about refugees that have been coming over from
48:09
Kevin Kauffman: countries as far as Nepal, Afghanistan, and African nations. We found at least with our work, that a lot of times they'll bring something with them that may be contaminated. Things like, for Afghani families,
48:25
Kevin Kauffman: coal, or bindeez from Nepali and Burmese families, or tie jeans from places such as Morocco.
48:36
Kevin Kauffman: It - I don't really see anything in the draft legislation referring to the education on those, and I definitely think with the number of refugees that we're receiving year by year
48:46
Kevin Kauffman: that should be something that should be added into the education. That's all that I have, thank you for your time.
50:32
[Talor Musil, Women for a Healthy Environment] Talor Musil, Women for a Healthy Environment: Good evening, my name is Talor Musil and I'm the health policy manager at the nonprofit called Women for a Healthy Environment,
50:40
Talor Musil, Women for a Healthy Environment: and we address environmental exposures, including lead, that impact public health, and believe everyone, especially children should have healthy spaces to live, learn, play, and grow.
50:51
Talor Musil, Women for a Healthy Environment: And our organization has distributed water filters, tested and remediated schools, and launched a cross-sector coalition in the Pittsburgh area.
51:00
Talor Musil, Women for a Healthy Environment: Between 2016 and 2020, nearly 2200 children were lead-poisoned in our community - all facing a lifetime of physiological, social and economic setbacks. And we are much like our fellow rust belt cities, when it comes to lead.
51:17
Talor Musil, Women for a Healthy Environment: Our long industrial history and associated pollution continues today with the US steel facility just outside of Pittsburgh admitting
51:25
Talor Musil, Women for a Healthy Environment: the third greatest amount of airborne lead in Pennsylvania and 97% of the lead air pollution in our county.
51:32
Talor Musil, Women for a Healthy Environment: In the late 20th century 20 - 279,000 residents left our area due to disinvestment and the foreclosure crisis, and this resulted in blight and in some cases, demolitions of older buildings, leaving lead-contaminated soil.
51:47
Talor Musil, Women for a Healthy Environment: More than 80% of our housing was built before 1978, yet low wealth and [indisernable] communities are at greatest risk of exposure to paint and dust hazards due to redlining and other structural issues mentioned in the strategy.
52:03
Talor Musil, Women for a Healthy Environment: Lead and drinking water is also top of mind for Pittsburghers. A recent report found that 80% of our water systems had detectable levels of lead.
52:12
Talor Musil, Women for a Healthy Environment: And the draft strategy, in our opinion excellently articulate the environmental justice of lead,
52:18
Talor Musil, Women for a Healthy Environment: but unfortunately, lacks urgency in the face of great opportunity for primary prevention. We'll provide full comments in writing but wanted to share a few recommendations.
52:28
Talor Musil, Women for a Healthy Environment: Revising the lead and copper rule to explicitly ban partial lead service line placements; sharing information about who the 11 priority communities are for the rrp outreach;
52:39
Talor Musil, Women for a Healthy Environment: defining how EJ communities can get in touch with the EPA and access support;
52:47
Talor Musil, Women for a Healthy Environment: including demolitions as a major contributor to airborne lead exposure and set stronger OSHA standards for lead-safe demolitions; promoting filters first at schools who cannot afford to replace lead service lines.
53:00
Talor Musil, Women for a Healthy Environment: And establishing programs for five lab testing for uninsured children and pregnant persons.
53:06
Talor Musil, Women for a Healthy Environment: In closing, we must reckon with all the sources of lead, starting in communities poisoned in part through racist and classist government policies,
53:14
Talor Musil, Women for a Healthy Environment: by moving beyond articulations of the problem and presenting equitable and specific action steps that will be accomplished on a publicly available timeline; and we're hopeful for our work together moving forward. Thank you.
55:55
[Mark Smith, The Clorox Company] Mark Smith: Ah well, first of all thank you so much for allowing us to comment. I'm Mark Smith. I'm the director for government affairs of the Clorox company. Um, we're very interested in the water space, because we own the number one consumer brand in water filtration, a the Brita brand.
56:15
Mark Smith: In our brand purpose is um, - you know, to have provide better water for people on the planet.
56:22
Mark Smith: We're currently partnering with municipalities all over United States to provide point of use filters to protect people
56:31
Mark Smith: while the larger infrastructure projects are ongoing to replace lead lines. And - and that's sort of the subject that I'd like to talk about today.
56:44
Mark Smith: If you look at the - the infrastructure bill, specifically the part on disadvantaged communities, one of the big changes was to allow
56:55
Mark Smith: for funds to be spent on point of use filters to - to protect people. And the lead and copper rule,
57:05
Mark Smith: the only mandate is to protect people for six months after the lead service line is replaced, and my question is, why should we wait? I think a number of our speakers have discussed, um the very serious health consequences of - of lead, particularly for - for children.
57:24
Mark Smith: And we have funding now. If you look at the appendix before the recent memorandum that has been put out by the head of water at the EPA,
57:34
Mark Smith: which makes point of use filters, um - you know, eligible for the $15 billion in the infrastructure bill, that's going to be flowing out to the States,
57:44
Mark Smith: we should be prioritizing protecting people using point of use filters. For $30, we can protect somebody for for six months, and with an additional filter,
57:56
Mark Smith: you know, we can provide a whole year of protection for around $50. There's no reason why we shouldn't be doing that, particularly for all the disadvantaged communities
58:06
Mark Smith: around the country where we know there are issues with their lead in their water, while these longer term infrastructure projects are ongoing.
58:15
Mark Smith: The other piece that I'd like to speak about is the environmental impact of addressing urgent problems with lead with single use bottled water.
58:26
Mark Smith: Oftentimes we find in communities that the first go-to is single use bottled water, which, as we know, has
58:34
Mark Smith: terrible consequences, both for the environment in the production of plastic, and then in the environment in terms of how those are disposed of, particularly in the oceans and waterways.
58:44
Mark Smith: So there's no reason why we shouldn't use that funding to provide point of use filters and we would suggest that the EPA, um
58:53
Mark Smith: warehouse those, such they could be used for emergency situation. So, thank you very much for this opportunity to comment.
67:40
[Joyce Ravinskas, UPMC PINNACLE LEAD PREVENTION PROGRAM] 1570****523: Thank you very much.
67:42
1570****523: I have been lead program manager for - you can see the - hold on one second.
67:53
1570****523: I have been the lead program manager for UPMC
67:59
1570****523: Lead Poisoning Prevention and Education Program, located in Harrisburg, for almost 20 years. I am a lead risk assessor and Kevin Kauffman who spoke earlier
68:08
1570****523: is my colleague and he brought up some concerns that I shared with him too.
68:14
1570****523: I also have an additional concern, and I think it affects all - all lead poisoning children, the families of PCPs and any future occupants of a lead home.
68:24
1570****523: I'm going to explain. When I receive a lead-elevated lead referral from a physician - a physician's office,
68:32
1570****523: a call is made to the parents, I introduce myself and lead education is conducted. And then we make our reasons to do a home business for and
68:40
1570****523: An ELI, which is Environmental Lead Investigation, at the home. We use an SRF, testing all painted and stain varnish areas, inside and outside of the home and
68:51
1570****523: any outbuildings and common areas. We do soil samples, we do water samples. It basically takes about two to three hours, depending on the size of the home.
69:01
and, um
69:03
1570****523: then we ask tough questions that the parents have, we reinforce the education that we've already conducted on the phone. A lot is done. We take the
69:12
1570****523: um, samples, and we take our SRF back, and we download it and we create a report and letter, and then the samples are sent out to a lab and the turn-around time is quick.
69:24
1570****523: The letters are all, then, once we get them back, the letters are all sent out to all parties, meaning the parents, the landlord, the
69:34
1570****523: um, physican, the state health nurse, and the codes department. Here's where the problem lies, so we can do all of that, - everybody could come together and do their part and do their best for that child that has a lead
69:48
1570****523: - lead problem, but codes - city codes is our backbone. We have no enforcement powers to make the landlord correct any lead issues. Now, Philadelphia, Lancaster city,
69:59
1570****523: Williamsport, Allentown, Hazleton, Bethlehem, Pittsburgh, and a handful of other towns, have a codes department that will, you know, - take the report and they enforce it, however most towns do not.
70:14
1570****523: They either do not have a codes department or the codes department does not want to be bothered with lead.
70:19
1570****523: Often, saying they're not going to do anything about it, um - so, there we go. And, we've made so many great strides in - so far - in lead, and we're making more with the help - great help of EPA too.
70:33
1570****523: Um, we've lower the level to 3.5. More doctors are testing and there's more involvement, - you know, in all different agencies across - you know, this area.
70:44
1570****523: My concern, though, is the houses that did not have a codes department enforce that - that work be done, and too often I receive another lead referral from an address we have already conducted a year or so ago.
70:58
1570****523: But it's a different family referred now, and the leaded home was never abated or remediated, and now has become a revolving door for more families to become lead-poisoned.
71:10
1570****523: Thank you.
72:29
[Robert Germann, Private Citizen] Robert Germann: Great, and I appreciate you letting me come on too late. I had a prior appointment and I'm glad I made it because
72:36
Robert Germann: I, uh
72:37
Robert Germann: I'm - I'm gonna give you some history. I live in San Diego, retired teamster truck driver.
72:43
Robert Germann: Uhm, I would, I am and my
72:46
Robert Germann: concern which is - leaded av gas. It is utterly amazing to me that this is still in existence.
72:55
Robert Germann: As being a retired teamster truck driver, and in our sector of the transportation industry, we - our trucks have been under EPA scrutiny for decades.
73:10
Robert Germann: For decades! We parked our trucks if they did not pass the sniff - sniffer test, outside the gate. And yet we have these small general aviation aircraft
73:25
Robert Germann: burning lead over our houses. In my particular situation, they're two or three hundred feet - and I have - over our houses and our schools, and yet it seems like the EPA is dependent on the FAA for any kind of guidance, which is
73:44
Robert Germann: - I'm I'm dumbfounded. I I just can't believe it when you compare it to other transportation sectors.
73:54
Robert Germann: The bottom line is that what I repeatedly hear from the FAA is the pilot in command decides on whether to fly, and how to fly. The FAA cannot tell these guys
74:08
Robert Germann: what to use, but they can recommend. So if the pilot in command decides that unleaded fuel wouldn't work in his aircraft, that's his choice. If he doesn't like to burn unleaded fuel
74:25
Robert Germann: and he feels that his aircraft is unsafe burning unleaded fuel and can only burn leaded fuel, then guess what - the plane does not take off!
74:36
Robert Germann: This is so simple! If you compare it, like I said, to the trucking industry we couldn't leave the yard, so if he's not burning unleaded he doesn't leave the airport.
74:51
Robert Germann: This - this is - this is simple. You've applied the same procedures and principles to trucking - and cars, apply it to aircraft. The country is not going to go broke if the small general aviation aircraft do not take off. Park 'em. it's real simple. Ban leaded fuel.
75:16
Robert Germann: If they don't want to use unleaded, then they don't fly.
75:23
Robert Germann: I don't know - I think my two-year old could understand this. Okay, that's my comment.
75:29
Robert Germann: And I really appreciate you having this, and for letting me come on. Hopefully, I made some sense and I just didn't ramble. I didn't have my glass of wine, so I probably didn't make any sense. Anyway, thank you.
75:41
Robert Germann: Bye.
76:12
[Kirsten Tiller, Private Citizen] Kirsten: Yes, hi my name is Kirsten Tiller. Um, so I have a couple comments on various things.
76:20
Kirsten: There's a lot of things that I want to say. Um, I guess starting off pretty, um
76:25
Kirsten: I'll just start off, like, with stakeholders. So I mean, I know that you talk about community engagement, right? And having a lot of stakeholders to the tables, but what does that exactly
76:36
Kirsten: mean? Can you explicitly state who they're - who they're going to be? Are you really going to be going to communities down on the ground level? Like, how
76:44
Kirsten: how is it really going to be? Is it just going to be a listening room, or is it going to be an active role
76:50
Kirsten: right? one of partnership. When I think that that will be the best way to really get things going. And we talked a little bit about water filters. I think that's huge but also like five gallon
77:01
Kirsten: water exchange programs. I think it's really important that the cost doesn't go to the consumers. Like, it's not our fault that
77:09
Kirsten: lead pipes, - you know, exist. Right? So, I don't think that that burden should fall to the consumers. And the duration, like we talked about, right? We know that there can be lead. It takes a while.
77:19
Kirsten: It can take a while to figure out that there is lead in the system, right? So we don't want people consuming lead in the meantime.
77:26
Kirsten: And we don't want, you know, months - however long it takes to replace it right, - we don't want them consuming lead, and then the six months after, whatever, so, we want to make sure that there's no consumption of lead, during that time period.
77:38
Kirsten: Another thing that I think is really important is just the knowledge about lead exposure. I think there are a lot of misconceptions and misinformation about lead.
77:47
Kirsten: That I really think there needs to be a really active campaign on and that just really hasn't been done in a while.
77:53
Kirsten: I think that people think 'oh it's just a Flint thing' 'oh it's just this thing' but it's a lot more serious than that, right?
78:00
Kirsten: Um, I also think that there's a lot of distrust in communities surrounding water. If you take DC, for example, a lot of people
78:07
Kirsten: um boil water, right, in DC, because of various health issues that came out. But, you know, actually that's pretty dangerous when you think about it, because
78:16
Kirsten: boiling water causes the lead to make it worse, and then you end up having higher levels of lead, um
78:23
Kirsten: in the water. So it's just, like I think that there needs to be active campaigns around this making sure that people understand what they can do, and that they don't end up making things worse, um, trying to help the situation. And I think also another problem I've seen is
78:41
Kirsten: some leadership and the water community, - some of them have denied that partial lead pipe removal is a problem, and I think that can be really serious.
78:53
Kirsten: So, if there could just be, if the EPA could just really strongly state that you know,
78:59
Kirsten: partial lead pipe removal does, - if you do that, it causes increases in lead exposure. I think that'll be really,
79:06
Kirsten: really important. So I'm sorry for going too fast, I know I had a lot of things I wanted to say. So I'll just, kind of, just hit the points again: the stakeholders; like I was saying, water filters; misinformation about lead; and distrust in communities. Thank you so much.
81:22
[Mark Smith, The Clorox Company] Mark Smith: Yeah, hi. Um, Thank you so much. Since there wasn't any other comments, there were a couple of items that I wanted - I didn't get a chance to address, that I think are important.
81:33
Mark Smith: Just to add on to my - my earlier comments, the other - so, one piece is around schools and daycares. And so, in the - in the draft strategy, there's - there's a focus on testing.
81:48
Mark Smith: But, um, testing is great, but what you need is testing and treatment. And so, in a lot of times we find with the WIIN grants, there are
82:00
Mark Smith: funds to do testing, but not funds to actually solve the issues, once the test show that there are lead issues in, for example, a daycare or school. And so, um, that I think is a really important piece
82:14
Mark Smith: that should be addressed in the policy. The other piece that I wanted to mention may be a little non-traditional, but I think it's important, particularly given all the supply chain issues that we're dealing with
82:28
Mark Smith: here in this country.
82:30
Mark Smith: It's that, um - you know, the water filtration, particularly point of use filters are subject to China
82:39
Mark Smith: 3 O 1 tariffs, which basically end up doubling their price, and so, um
82:46
Mark Smith: that's an issue that I believe EPA should be aware of as they're thinking about how to protect communities all over the United States. Obviously,
82:56
Mark Smith: for us, that's an important additional source of capacity for - for point of use filters. It's not our primary source, but if we really are committed to protecting people
83:09
Mark Smith: we need to be sourcing as many point of use filters proactively, as possible. And that is an important part of that overall strategy, so I think that's an important piece to note as well. So thank you for the additional time.

