Children’s Environmental Health in Michigan
Lead, a naturally occurring element, is a metal added to paint and other products including lead-glazed pottery, brass fittings, ammunition, cable covers and many pipe fixtures (Goyer & Clarkston 2001, ASTDR 2005). Lead is also added to stabilize plastic, and is a component of electronics and metal parts of some toys and electronics (Schmidt 2008). Among its many uses, the largest use of lead in the United States is in storage batteries in automobiles (ASTDR 2005). In addition to its use in consumer products, lead can also be emitted into the air from mining and smelting sites, waste treatment plants, incinerators and other industrial processes such as battery manufacturing or metals processing (Levin et al. 2008). A long history of federal and state policy action surrounds the use of lead, preceded by a much longer history of its recognition as a toxicant. The deity associated with lead in the ancient world was Saturn, “the ghoulish titan who devoured his own young.” (EPA. 1985) There are contemporaneous accounts of lead poisoning in ancient Rome, with a range of health impacts described including neurotoxicity. In Greece in the mid-second century BC, the Alexipharmaca (II.74ff) of Nicander, notes some neurological effects of lead poisoning. The first law banning lead was enacted in Germany in 1696 to prevent wine contamination. Childhood lead poisoning was first described in Australia in 1892; and, in an effort to reduce childhood lead exposure, lead was banned from house paint in Australia in 1914 (Needleman 1999). The U.S. effectively did not ban lead in paint until 1978 (CPSC 1977).
There is now strong evidence that there is no safe threshold for lead exposure, even lower-level exposure, including prenatal exposures, has been linked to decrements in intellectual function.
Given that lead has been shown to cause adverse effects in the neurodevelopment of children, a decrease in lead exposure therefore has the potential to contribute to improvements in neurological functions including Intelligence Quotients (IQ). Lead exposure reduction in American children has resulted in an estimated annual benefit to society of $110-$319 billion, due to the intelligence and productivity benefits of lower blood lead levels (Grosse et al. 2002).
Legislative and regulatory measures exist on the state level in Michigan and in other states to protect human health and the environment. This section will briefly summarize lead exposures and associated health effects, present leading policy practices from other states, and recommend steps to minimize childhood lead exposure in Michigan.
- 1 Background Information
- 2 Policy Summary and Analysis
- 3 Summary of Recommendations for Lead Policy in Michigan
- 4 References
- 5 Environmental Protection Agency (EPA) May 1985 Lead EPA Journal: “Lead Poisoning:
- 6 A Historical Perspective” by Jack Lewis
Sources of Lead
Lead exposure for all Americans has dropped substantially since the 1970’s, due primarily to the phase-out of leaded gasoline (EPA 2009). Currently, most lead exposure is attributable to lead-based paints in residential buildings that were built before 1978, after which lead levels in paint were more strictly regulated. Additional prevalent sources of exposure include soils contaminated from historic use of leaded paint and gasoline, lead pipes in municipal water systems, and industrial airborne releases of lead and contaminated dust from smelters and waste treatment plants (ATSDR 2005; Levin et al. 2008). According to the U.S. Toxic Release Inventory, lead and lead compounds accounted for 98 percent, or 446 million pounds, of the total persistent bioaccumulative toxic chemicals (PBTs) reportedly released or disposed of in 2006 (EPA 2006b). The EPA has authorized lead abatement programs in several states, including Michigan, in order to reduce lead exposure in homes through removal of lead paint and lead-contaminated dusts (EPA 2005).
Childhood Exposure to Lead
Childhood lead exposure may occur via ingestion or inhalation. Ingestion of lead-based paint or of contaminated soils, dust, foods or drinking water may result in elevated exposures. Inhalation of contaminated air may result in lead exposure, particularly for children living near emission sources such as waste incinerators (Levin et al. 2008). While direct ingestion of lead-based paint is the exposure route that receives the most attention during abatement and screening processes, recent data suggests that more than 30% of children with elevated blood lead levels do not have direct exposure to a lead paint source (Levin et al. 2008). These data suggest that other exposure routes and additional sources in the environment may be significant contributors to childhood lead poisoning. A child’s cumulative exposure to all sources of lead, which individually may be considered “safe,” may collectively put a child’s neurological system at risk (Weil 2007). A child’s cumulative exposure may come from the combined exposure to lead in paint chips, soil, air, household dust, jewelry, and toys (Weil 2007; Charneyet al. 1983). Both current and past maternal exposures contribute to lead levels in a mother’s breastmilk, and even low concentrations of lead in breast milk can influence a baby’s blood lead level (Levin et al. 2008). An unborn child can also be exposed to lead in utero. Fetal exposure can occur as a result of a mother’s current exposure to lead during pregnancy. Lead concentrations in fetal tissues are proportional to the mother’s blood lead levels during pregnancy (Goyer and Clarkston 2001). Furthermore, lead stored in the mother’s bones (from past exposures) can be mobilized during pregnancy, thus resulting in potentially significant exposure to the developing fetus (Huet al. 2006). There are several characteristics unique to young children that make them particularly vulnerable to exposure to lead in the environment. Children engage in frequent hand-to-mouth behavior that begins almost immediately after birth; this behavior is common until around age 3 or 4 years (Goyer, Clarkston 2001). Furthermore, children are low to the ground, so they can more easily ingest or inhale toxicants that are in the soil, on the floor, or even in house dust (Hu 2007; Schettler 2009). Additionally, the developing nervous system is more vulnerable to lead exposure than a mature nervous system (Needleman 2004). These characteristics, coupled with the fact that young children absorb lead more efficiently than adults and older children (Levin et al. 2008; Goyer, Clarkston 2001; Needleman 2004), make young children particularly vulnerable to lead exposure, and make minimizing early life exposures a top priority in reducing the overall effect of lead on the population. Exposure can be reduced by simple exposure-reducing behaviors and practices. One study in homes with lead-contaminated dust had the homes extensively cleaned and the children residing in them engaged in frequent hand washing showed that blood lead levels can drop significantly after one year given these exposure-reducing practices (Charneyet al. 1983). Other factors influencing the likelihood of a child’s exposure to lead include income level, age of housing, location of residence, country of origin, parental occupation, time of year/season, nutrition (such as iron, calcium, and zinc status), and the presence of tobacco smoke in the child’s environment(Levin et al. 2008; Goyer, Clarkston 2001). Many of these factors are interrelated, which can lead to disproportionate exposure in some population subgroups.
Childhood Exposure to Lead in the U.S.
Children’s blood lead levels have continuously declined in the U.S. since the phase-out of lead-based gasoline (Schettler 2005). In fact, the decrease in average child blood lead concentration in the U.S. closely follows the decline in total lead used per year in gasoline (Figure 1). Figure 1. Decline in average blood lead levels in U.S. children and in total lead used per year in gasoline for years 1974-1992 (adapted from U.S. EPA 1999). Despite this substantial decline in average blood lead levels (BLL) in the U.S. due to decreases in atmospheric emissions, childhood lead poisoning remains a significant public health problem in the U.S., particularly for certain groups. It has been estimated that the cognitive impacts of lead poisoning (decreased IQ, productivity, and life time earnings) cost more than $43 billion each year in the U.S., although childhood lead poisoning is entirely preventable (Landriganet al. 2002). A recent report by the Michigan Network for Children’s Environmental Health estimated the annual cost in Michigan as a result of childhood lead exposure to be $4.85 billion(range: $3.2 to 4.85 billion) (Glaser et al. 2010). Furthermore, Gould (2009) estimated that, for every dollar spent on lead paint hazard control nationally, the returns would range from $17-$221; these returns would come from reductions in costs associated with health care, crime, and special education, as well as from increased future tax revenue. As such, there are both direct (ie. health care), and indirect costs associated with lead exposure in children. Special education serves as one example of an indirect cost associated with lead poisoning. For instance, an increased prevalence of elevated blood lead levels has been observed in special education classes relative to non-special education classes at Detroit Public Schools (Tarr et al., 2009). Due to a need for specialists to teach children in special education classes, the cost of educating special needs students can be quite a bit higher than that of educating other students (Gould 2009). In 2006, the state-specific costs of special education in Michigan were approximately $12,000/child/year amounting to $2.7 billion/year in Michigan (14.4% of children in the Michigan public school system were in special education) (Weil 2007). As previously stated, certain age groups are particularly vulnerable to lead exposure. This vulnerability is demonstrated through data on childhood blood lead levels in the U.S. For example, the 2001-2002 National Health and Nutrition Examination Survey (NHANES), conducted by the Centers for Disease Control (CDC), estimated that 1.7% of all children in the U.S. between the ages of 1 and 5 have blood-lead levels above the 10 g/dl (10 micrograms of lead per 1 deciliter of blood), the threshold set by the CDC (CDC 2007). This percentage is a decrease from the NHANES III (phase 2, 1991-1994), which reported that 4.4% of children had BLL above 10 g/dl (Pirkle et al. 1998). The 2001-2002 NHANES also reported that younger children (age 1-5) had higher mean blood lead levels than children aged 6-11 years, who had higher levels than those 12-19 years (CDC 2005). Childhood lead exposure in the U.S. is also dependent on age of housing and family income. Results from a study conducted in all 50 states between 1998 and 2000 suggest that although the estimated number of housing units in the U.S. with lead-based paint has decreased, 35% of low-income housing still had lead-based paint hazards (Jacobs et al. 2002). This study also conferred that dust lead levels and soil lead levels may contribute to overall exposure, as 16% of all houses had dust lead levels above current guidelines, and 7% of houses had soil lead levels exceeding recommended levels (Jacobs et al. 2002). Additionally, blood lead levels vary by race and ethnicity (Levin et al. 2008). For example, blood lead levels are typically higher in the U.S. for black, non-Hispanic children than for Mexican American or white children (Figure 2) (CDC 2005). Much of this disparity is attributed to a larger percentage of children residing in lower-income, pre-1970’s housing with lead paint (CDC 1992). Additionally, the use of certain herbal remedies, cosmetics, or folk medicines among some ethnicities may potentially influence blood lead levels, as may refugee status (Levin et al. 2008). In fact, according to the CDC, blood lead levels were elevated in 45% of refugee children shortly after resettlement. One hypothesis for this is that this is due to a higher prevalence of iron deficiency in refugee children, as lead absorption rates are higher among iron-deficient children (Levin et al. 2008). Authors of other studies on elevated blood lead levels in refugee children hypothesize that leaded gasoline in home countries (such as those in sub-Saharan Africa, where leaded gasoline was phased out as late as 2006), resettlement into old housing stock, and use of traditional home remedies containing lead may be other factors in elevated blood lead levels in refugee children (Eisenberg et al., 2011; Plotinsky et al. 2008; Ritchey et al., 2011). Figure 2. Percentage of children in three NHANES survey periods with blood lead levels greater than 10 µg/dl, by race/ethnicity (CDC 2005).
Childhood Exposure to Lead in Michigan
Potential Sources of Exposure in Michigan
In Michigan, the most common source of lead exposure is lead-based paint in older homes or apartments built before 1978. Seventy percent (70%) of the homes in the state were built prior to 1978. (Kusch 2006). While accidental ingestion of lead paint chips is an obvious source of exposure, the less obvious (but much more prevalent) source is ordinary household dust. Children who grow up in houses with dust contaminated by tiny particles of lead from deteriorating paint can swallow enough lead to cause serious health problems (Nadakavukaren 2000). Assessment of lead in housing units is done on a voluntary basis, and therefore Michigan homes have not been systematically or thoroughly remediated for lead-based paint (Michigan Childhood Lead Poisoning Prevention and Control Commission [MCLPPCC] 2007). Although roughly 1,500 homes have been abated for lead hazards in Michigan, it is estimated that over 1.3 million housing units in Michigan still present a lead paint hazard (MCLPPCC 2007).
According to the Michigan Department of Community Health’s 2007 Critical Health Indicators report, lead poisoning in Michigan follows national trends in that cases tend to be concentrated in more urban areas with older housing units (MDCH 2007). Although children living in the city of Detroit are particularly at risk, roughly half of Michigan’s zip codes are identified as being high risk. High risk areas are identified by the percentage of pre-1950s housing, as children can be at risk for lead poisoning due to deteriorating paint and/or renovations of these older homes (MDCH 2007). While legislation prohibiting lead from interior surfaces did not take effect until 1978, many structures built or renovated between 1960 and 1978 had already voluntarily remediated and/or non lead-based paint was selected; as such, pre-1950s housing carries a higher risk of leading to lead poisoning (Jabobset al. 2002). While lead paint particles remain the primary sources of exposure (Nadakavukaren 2000), Michigan’s children are potentially exposed to lead from a variety of other sources, including the many contaminated sites throughout the state. According to Michigan DEQ’s Part 201 Site List, out of 3,257 polluted sites in Michigan, 623 sites are reported to be contaminated with lead (MDEQ 2008). Furthermore, in the 2005 Michigan Toxic Chemical Release Inventory summary report, 320 facilities in Michigan released lead or lead compounds into the environment (MDEQ 2005). The 2005 Michigan Toxic Chemical Release Inventory (updated in 2007) indicated that more than 34,700 pounds of lead and lead compounds were released into the air (MDEQ 2005). It also indicated that over 2,000 pounds were released into the state’s water sources and nearly 280,000 pounds of lead were released/disposed of on land in 2006 (Figure 3). In total, approximately 3,671,057 pounds of lead and lead compounds were released in Michigan during 2005 (MDEQ 2005). In the same year, the U.S. released 18,434,233 pounds of lead (EPA 2005). Figure 3: Reported release (lbs/year) of lead and lead compounds into Michigan’s environment in 2005 as summarized by Michigan Toxic Chemical Release Inventory (TRI) (Source: MDEQ 2005).
Childhood Blood Lead Levels and Screening in Michigan
Michigan ranks 6th worst in the nation in the percentage of lead poisoned children (MCLPPCC2007). In efforts to improve this statistic, the Childhood Lead Poisoning Prevention Program, through the Michigan Department of Community Health, works to coordinate lead poisoning surveillance and prevention for Michigan’s children. Under this program, children under the age of 6 and pregnant women are targeted for lead poisoning prevention. Many of the statistics provided in this section are compiled through this program. In 2008, 35.0% of Michigan children between the ages of 1 and 2 years (of a total population group of 253,207 children), and 20.1% of children under the age of 6 (of a total population group of 764,176 children) were tested for blood lead. Of those children tested, 9.8% had blood lead levels (BLL) greater than 5 µg/dl (5 micrograms of lead per deciliter of blood), and 1.1% of children had BLL greater than 10 µg/dl (MDCH 2008a). These percentages held irrespective of age strata (Figure 4). Figure 4. Stratified blood lead levels greater than 5 µg/dl (micrograms of lead per deciliter of blood) in Michigan children screened for lead (Source: MDCH 2008a).
|===== Blood Lead Levels =====|
|===== Number =====|
|BLL ≥5 µg/dl|
|BLL ≥10 µg/dl|
|BLL 10-14 µg/dl|
|BLL 15-19 µg/dl|
|BLL 20-44 µg/dl|
|BLL ≥45 µg/dl|
* Refers to percent of children tested
A notable success story lies in the lowering of children’s blood lead levels in response to public health interventions. In 2005, just 3 years prior to the above data, 17.2% of Michigan children tested (under the age of 6) had blood lead levels (BLL) greater than 5 µg/dl, and 2.4% (compared to 1.1%) of children had BLL greater than 10 µg/dl. Similar to national trends (Figure 1), the percentage of children with elevated blood lead levels has decreased in the state of Michigan during the past decade (Figure 5) – while rates of testing have increased in most, but not all, areas. Figure 5. Trends in elevated blood lead levels in Michigan children under age 6 tested from 1998 to 2008. Notes: Each line reflects the portion of all children who tested at that level and above. EBLL = Elevated Blood Lead Levels. (MDCH 2010). In 2005, the Michigan Department of Community Health (MDCH) projected that the number of children screened, and the number of children with elevated blood lead levels (defined as ≥10 µg/dl), would decline rapidly over the next several years (Figure 6). The 2006 MDCH report revealed that while the number of children with elevated blood levels decreased even further than their projection (1.6% of children tested had elevated BLLs compared to the 2% projection), the number of children that were tested fell short of the agency’s goal (MDCH 2006). Since 2004, the numbers of children tested have not met MDCH’s goal of a 10% annual increase (Figure 6). Figure 7 shows the number of children (less than 6 years of age) who received blood lead testing in Michigan, broken down by children who were Medicaid-enrolled or not Medicaid-enrolled. Although much of the testing is covered by insurance, significant state budget cuts and Medicaid reimbursement cuts will further impact the state’s ability to raise public awareness about the importance of testing and the ability of children on Medicaid to get tested. For example, in Kent County, Michigan, there was a 26% decrease in lead testing from 2004 to 2008 (Paul Haan - personal communication with the Ecology Center, 2009). Figure 6. Elevated blood lead levels (EBLL) (≥10 µg/dl) in Michigan children less than 6 years old in numbers and as a percentage of children tested. Data from 2001-2005, and projected data for years 2006-2010 (MDCH 2005). Figure 7. Number of children under six years of age tested for blood lead levels, 1998-2009. (MDCH 2010) Figure 8 indicates the extent of childhood lead poisoning among children age 6 and younger in the city of Detroit from 1998-2004. The percentage of children with elevated blood lead levels (EBLL, referring to levels ≥10 µg/dl) in Detroit, 18.7%, was well above the U.S. average of 7.6% in 1998 (CDC 2000). This is consistent with other findings that children in urban areas face a disproportionate risk of lead poisoning. The proportion of children with EBLL among those tested decreased from 18.7% in 1998 to 6% in 2004 (Figure 8). Yet, Detroit children have consistently been at higher risk for EBLL over the years, and in 2011 the majority of lead poisoned children in the state were in the Detroit metropolitan area (Figures 9 & 10). In 2004, for instance, 2.5% of children under the age of six had EBLLs throughout the state, while 6% had EBLLs in Detroit. Of children under the age of six tested in Michigan in 2008, 1.1% had EBLLs (levels ≥10 µg/dl). However, of fourteen communities considered to be of particular risk, children in ten of them were above the Michigan average (MDCH 2008b). Figure 8. Extent of lead poisoning in the City of Detroit, 1998-2004.Total number of children age 6 and younger tested for lead and the number found with blood lead levels (BLL) of 10µg/dL (micrograms of lead per deciliter of blood) or above (EPA 2007).
Figure 9. Lead Poisoning in Detroit Compared with Michigan statewide, 1998-2004. Percent of children age 6 and younger tested for lead with blood lead levels of 10 µg/dL (micrograms of lead per deciliter of blood) or above (Sources of Data: MDCH 2005 and EPA 2007). Note: the Detroit Data includes children age 6, while the statewide data does not. Figure 10: Map of elevated blood lead levels among children less than six years of age in Michigan. (MDCH 2009) Despite declining numbers of children with elevated blood lead levels, childhood lead exposure is still a public health concern in Michigan. Exposure to lead during childhood places both a burden on a child’s health and development, and a social and economic burden on the state. It has been estimated that the education and human services necessary to address social and learning problems associated with lead exposure in Michigan present a lifetime cost of over $45,000 per lead-poisoned child (MCLPPCC 2007). By comparison, it costs approximately $600-700 to assess a Michigan residence for lead in the commercial market, with the average cost of abatement being roughly $9,000 per residence (MCLPPCC 2007). In 2007, the Michigan Childhood Lead Poisoning Prevention and Control Commission estimated that over 1.3 million occupied housing units in the state of Michigan contained lead paint hazards. The low costs of lead assessment and abatement in residences, relative to the high cost of lead poisoning, indicates that the state should consider prioritizing these measures as a means of reducing childhood lead exposures. Currently, several other states have programs in place which offer grants, loans, or tax credits in order to incentivize lead abatement in residences (ALM GL ch. 111, § 197E, § 701.337 R.S.Mo., N.J. Stat. § 52:27D-437.4, Minn. Stat. § 144.9512, R.I. Gen. Laws § 44-30.3-1).
Neurotoxicity and Lead
Children under the age of 6 are at highest risk of lead poisoning because their bodies are not fully developed. Developing nervous systems, both during gestation and infancy, do not have an adequate blood brain barrier, and therefore lead can easily pass into the brain (ATSDR 2005).Lead affects the nervous system through several mechanisms, each of which can be critical to a developing brain. Specifically, lead can impair cellular signaling, which can lead to changes in neuronal circuitry (Goyer and Clarkson 2001). Lead alters neuron cell structure and neurotransmitter levels in the brain (acetylcholine, dopamine, glutamate) (Goyer and Clarkson 2001). Lead can also inhibit NMDA (glutamate) receptors in the brain (GBPSR 2000). Furthermore, lead can disrupt calcium homeostasis and impair calcium intake (ATSDR 2005; Goyer and Clarkson 2001). Calcium is critical to nerve signal transmission, so these interferences with calcium can result in a variety of negative impacts, including a decrease in available energy necessary for brain functioning and disruption of signaling necessary for cell communications (Goyer and Clarkson 2001). Lead poisoning can cause permanent and irreversible damage to the nervous system. Its effects include hearing and vision loss, reductions in cognitive development and attention span, hyperactivity, aggressive behavior, loss of IQ, learning disabilities, developmental delay, coma and even death (EPA COI 2007; MCLPPCC 2007). Many human and animal studies have directly linked elevated lead body burden with neurological impacts, and there is even some evidence that these impacts may begin to materialize in utero. An unborn child can be exposed prenatally to lead from the mother’s gestational exposures and from mobilization of stored blood lead during pregnancy (Hu et al. 2006). The timing of lead exposure during pregnancy may influence health outcomes later in life. A recent study reported that fetal exposure during the first trimester (higher maternal blood lead levels) may result in a lower Mental Development Index (MDI) at 24 months of age (Hu et al. 2006). Additionally, there is evidence linking children’s lead body burden with several different indicators of neurological impacts. For example, in a study conducted in Boston, MA, elevated blood lead levels were correlated with behavioral changes in children, such as distractibility, frustration, attention deficit, and impulsivity(Tuthill 1996). Other studies have shown correlation with aggressive and destructive behavior (GBPSR 2000). Figure 10 (below) demonstrates a dose-dependent association between lead body burden in children and behavioral traits possibly associated with ADHD. The first graph in Figure 10 is extracted from an often-cited study conducted in 1979, in which teacher-evaluated student behavior was correlated with dentine lead levels (Needleman et al. 1979). The graph shows a dose-response relationship between dentine lead levels and percent of children exhibiting the behaviors of interest (Figure 11). The second graph is adapted from a similar study conducted in 1984 (Yule et al. 1984), and also demonstrates an association between childhood lead body burden and decreased classroom performance. Figure 11. Association between student lead body burden and teacher ratings. The bars represent the percent of students in each lead category considered by their teachers to have the corresponding challenges. Graphics adapted from: Needleman et al. 1979 and Yule W, et al. 1984. Recent studies have similarly indicated that subtle behavioral effects may be linked to lead exposure. A 2008 study in Syracuse, NY found elevated childhood blood lead levels (>20 μg/dl) to be associated with repeat teen pregnanciesas well as tobacco use (Lane et al. 2008). The authors explain that lead poisoning can delay cognitive development as well as executive functioning in young women. These results indicate that lead poisoning may have a long-lasting impact on children’s functioning, development, and behavior. Another study confirmed that lead can have long lasting effects on behavior by showing that early-life exposure to lead is associated with adult criminal behavior. That long-term study found that increased prenatal and postnatal blood lead concentrations are associated with higher rates of total arrests and/or arrests for offenses involving violence (Wright et al. 2008).Another study correlated preschool lead exposure with criminal behavior 20 years later (the peak age for index crime rates). This study was also able to correlate the high levels of lead in the air in larger cities with higher crime rates for the years following their peak air lead levels (Nevin 2007).
Policy Summary and Analysis
Since 1991, the blood lead concentration of concern in children has been 10 µg/dL (micrograms per deciliter) as determined by the Centers for Disease Control and Prevention (CDC) (Levin et al. 2008). However, subsequent studies have shown that blood lead levels as low as 2 µg/dL are associated with adverse effects, and therefore the CDC recommends abatement of any lead sources in the home (Levin et al. 2008). Ultimately, it is critical to control all potential sources of childhood lead exposure, as discussed above, because a child’s exposure to lead is cumulative. This section summarizes current Michigan policies related to childhood lead poisoning, and provides recommendations for improving these policies to minimize childhood exposure to lead and to improve mitigation strategies.
- Michigan Policy Highlights
- In Michigan, only children enrolled in the special supplemental food program for women, infants, and children (WIC) or Medicaid are statutorily required to be tested for elevated lead levels. Children enrolled in Medicaid are required to receive a screening blood lead test at 12 and 24 months of age, and children between the ages of 36 and 72 months must receive a blood lead test if they have not been previously screened. The MDCH recommends that children enrolled in WIC be tested at 12 and 24 months of age (children enrolled in WIC are required under law to be tested, however there isn’t an age requirement in the provision, hence the recommendation).
- Currently, the Michigan Department of Community Health (MDCH) strongly recommends testing of blood lead levels in children living in “high-risk communities”(Battle Creek, Benton Harbor, Dearborn, Detroit, Flint, Grand Rapids, Hamtramck, Highland Park, Jackson, Kalamazoo, Lansing, Muskegon/Muskegon Heights, Pontiac, and Saginaw) at 12 and 24 months of age. Furthermore, they recommend that untested children between 25 and 72 months of age in those areas should be tested as soon as possible.
- As a result of legislation passed in 2006, the MDCH was given the responsibility to expand the Michigan Care Improvement Registry (formerly the Michigan Child Immunization Registry) to include the reporting and recording of childhood lead testing (MCL § 333.9227).
- When a tested child has a blood lead level>20g/dL or persistent blood lead levels 15-19g/dL, Michigan has a defined action plan, and certain individuals with children that have EBLL may apply for abatement funding under the MDCH Lead Safe Home Program (see ‘Policy Highlights’ under ‘Lead Abatement Assistance’).
- Analysis and Policy Highlights from Other States
- The MDCH plan has been endorsed by the Centers for Disease Control and Prevention and the American Academy of Pediatrics. Many states, such as New York, go further than these proposed guidelines by requiring screening of all children, by statute, at 12 and 24 months (or later) (NY CLS Pub Health § 1370-c). Connecticut requires all children 9-35 months to be screened for lead at least annually, requires screening of all children 36-72 months who have not previously been screened, requires a medical risk assessment to be conducted at least annually for children 36-72 months, and allows for medical risk assessments to be conducted at the physician’s discretion on children under 36 months (Conn. Gen. Stat. § 19a-111g).
- Many states require lead screening or risk assessment as a condition of attending day care or schools, in keeping with the requirements for immunizations. This is one way in which Michigan environmental policy can be improved be improved to reflect the policy environment in other states. HB 4495, which died in committee during the 2001 Legislative Session, would have required screening as a condition of children entering pre-school.
- Evaluation and Recommendations
Michigan has a policy consistent with the CDC guidelines regarding lead screening, though it does not require universal lead testing for all children. The state should consider extending the requirements to all children at one and two years of age, in order to better identify children who may also be at risk for health impacts due to lead exposure, as is done in New York. Michigan should also require insurers to reimburse for capillary testing, a practice currently not common and an obstacle to getting children tested.
Lead Data Tracking
- Michigan Policy Highlights
- All laboratories in Michigan have been required to report all blood lead results to MDCH since 1997.
- CLPPP must submit all blood lead test results to the department, and in cases where levels equal or exceed 10 µg/dL, the department will contact the child’s physician and/or local health department.
- The numbers of cases of elevated blood lead levels involving children age six or younger shall be compiled into a report for the legislature at the end of each fiscal year. The report shall then be compared to previous fiscal years to note improvement or lack thereof, and to consider any measures, monetary or otherwise, that may be taken to improve the effectiveness of the law.
- The MDCH Lead-safe Housing Registry is a listing of single-family homes, duplexes, apartments, and daycare centers which have received professional lead services, which may include lead hazard inspection (which can occur upon the discovery of elevated blood lead levels) or abatement.
- Analysis and Policy Highlights from Other States
- Michigan’s requirement that blood lead levels be reported to the Department of Community Health is consistent with the standards of many states. However, Kentucky sets the reporting threshold at 2.3 µg/dL (Kentucky Revised Statutes § 211.902, Maryland Environment Code § 6-30, Minnesota Statute § 144.9502, New Hampshire Revised Statutes Annotated 130-A: 3, New York Consolidated Laws Service Public Health § 1370-e, North Carolina General Statutes § 130A-131.8, Rhode Island General Laws § 23-24.6-21, 18 Vermont Statutes Annotated § 1755).
- Evaluation and Recommendations
Michigan has established reporting requirements for reporting children’s blood lead levels, but can go further to better protect children’s health. Michigan has launched the Lead Safe Housing Registry, however the statuses of assessed properties are not all recorded currently: Michigan should work to ensure that all properties at risk for lead contamination are assessed and the status are reported in the Lead Safe House Registry.
Lead Abatement Assistance
- Michigan Policy Highlights
- Currently, Michigan has limited programs in place to assist with lead abatement in residential housing.
- The MDCH Lead Safe Home program offers residential lead-abatement funding for low-moderate income families meeting certain criteria (living in Calhoun, Ingham, Kalamazoo, Muskegon, Oakland, Saginaw [excluding the city of Saginaw] or the city of Detroit, or if the child of the parent/caregiver has a blood lead level 10g/dL, and the home that is owned or rented was built before 1978). This program provides full inspections/risk assessments at no costs. If hazardous lead is detected the program provides $2,000 to $8,000 per unit for abatement costs (cleaning, painting, window and door replacement, etc), depending on certain criteria of the property. Residents must contribute in some way (by money or labor) to the project in order to receive funding; contributions may also come from other programs in the area (housing/community agencies, churches, etc).
- Lead abatement can be used as a criterion for qualifying for assistance under “brownfield” development to improve substandard housing (MCL § 208.38g (208.1437) & § 125.2663).
- A Michigan bill to provide a tax credit equal to 25% of the cost of lead abatement passed the Michigan House in 2003, but failed to pass the Senate (HB 4443), and Lead Abatement Tax Credit legislation failed to pass in the previous Michigan legislative session (HB 4409).
- Analysis and Policy Highlights from Other States
- A small number of states are offering loans (Massachusetts, Missouri, and New Jersey), grants (Minnesota), or tax credits (Rhode Island as well as Massachusetts which currently has the most progressive tax credit program) to assist home owners in lead abatement (ALM GL ch. 111, § 197E, § 701.337 R.S.Mo., N.J. Stat. § 52:27D-437.4, Minn. Stat. § 144.9512, R.I. Gen. Laws § 44-30.3-1). By statute, New York’s Lead Poisoning Advisory Board is authorized to “recommend...ways to financially assist property owners in abating environmental lead, such as tax credits, loan funds, and other approaches”.
- Evaluation and Recommendations
- Michigan should strongly consider providing economic incentives for voluntary lead abatement for those homeowners who cannot qualify for the Michigan Lead Safe Home Program. Tax credits towards homeowners and residential rental property owners to have lead paint in their homes removed would be one such way to provide an incentive. Furthermore, considerations should be placed upon providing similar incentives for lead abatement in day care facilities. Such an investment now in protecting children from the potentially life-long impacts of lead poisoning could save the state hundreds of millions of dollars annually over the coming decades (Glaser 2010).
- Michigan could provide funding for the Lead Safe Home Program and any other residential lead abatement incentive program that is passed through charging a fee to paint manufacturers of $0.25 per gallon sold, as is currently practiced in Maine and has been recommended by the Childhood Lead Poisoning Prevention and Control Commission. This would net (MCLPPCC 2007).
- Michigan Policy Highlights
- The Childhood Lead Poisoning Prevention Program (CLPPP), under the Michigan Department of Community Health (MDCH), was statutorily created to develop a “coordinated and comprehensive plan to prevent childhood lead poisoning and to minimize exposure of the general public to lead-based paint hazards” (MCL § 333.5474). The program is authorized to undertake education efforts to instruct health care providers, landlords, tenants, parents of young children, and operators of schools and day care facilities about the risks of lead (MCL § 333.5474). HB 4936, which became Public Act 162 in December 2007, reinstated the Childhood Lead Poisoning Prevention and Control Commission until July 2010 in part to “study and report on the environmental threats of lead poisoning to children’s health, including, but not limited to, the incidence of exposure, source of exposure, and degree of exposure.” The commission is also charged with evaluating the state’s lead poisoning prevention and the new standard set by a companion bill to restrict the concentration of lead in children’s products to 600ppm (see section “e” below).
- Additionally, the MDCH is authorized to establish a program to educate property owners, managers, and maintenance staff in lead-safe practices and to devise “appropriate maintenance practices” that are designed to prevent lead poisoning (MCL § 333.5473a).
- Analysis and Policy Highlights from Other States
- Most states have some type of lead prevention program whose primary component is to educate the population about lead hazards. A number of states, however, go further in their prevention efforts. For example, Maine (22 M.R.S. § 1319-C) requires the testing of child-care facilities to ensure that they are lead-safe; Missouri (§ 701.306 R.& 701.308 S.Mo.) requires written notification to owners of residential properties or child care facilities if lead hazard is found (and requires subsequent abatement); Minnesota (Minn. Stat. § 144.9504) requires lead assessments if a child or pregnant woman has elevated blood lead levels; Rhode Island (R.I. Gen. Laws § 23-24.6-14) requires that schools, day-care facilities, and playgrounds certify that they are “lead-safe,”. Connecticut (Sec. 19a-111f) has established an “environmentally safe housing” pilot program, Georgia (O.C.G.A. § 31-41-17) requires written educational materials be sent to the home of any child who tests for elevated blood lead levels, and Vermont (18 V.S.A. § 1758) has established a “lead free” housing registry and requires the removal of deteriorating lead paint whenever there is a change of tenant (18 V.S.A. § 1759). Maryland requires all pre-1950 rental housing to be inspected for lead and made lead-safe prior to being given a certificate of occupancy, so long as it is designated for permanent residence (Maryland Code, Environment, Sec, 6-801- 6-852).
- Evaluation and Recommendations
The current statutory requirements for lead prevention in Michigan provide important benefits in terms of education, and continuing these programs is crucial. More targeted outreach and abatement efforts would have a more significant effect in terms of preventing lead poisoning and the state should consider additional prevention measures. Such measures may include: testing of child care facilities and family homes that may serve as child care facilities (but contain fewer than twelve children--testing is required in day care centers that service more than 12 children) to ensure that they are lead-safe, creating a better “lead free” housing registry, and requiring the removal of deteriorating lead paint whenever there is a change of tenant (as is already done in Hamtramck and Benton Harbor). The state should also require the testing of rental properties.
Lead Paint and Lead in Products
- Michigan Policy Highlights
- By statute, Michigan defines lead paint as “"paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter or more than 0.5% by weight” (MCL § 333.5458). It is a crime in Michigan to knowingly use lead-paint in violation of statute (MCL § 333.5477), and a crime to rent residential housing if the landlord knows about the lead paint hazard and a child in the home tests for lead levels above 10 µg/dl (MCL § 333.5475a). However, attempts to allow civil actions against those who knowingly rent property containing lead hazards or to impose criminal penalties against landlords who rent lead-hazard containing units without informing tenants have failed to pass the legislature (HB4182 & HB5115).
- In 2007, Michigan passed into law three bills (Public Acts 159, 160, and 161) to prohibit the sale of toys and other children’s products made for young children. The bills prohibit the sale or manufacture of toys and childcare articles, jewelry, and lunchboxes that contain lead at concentrations above 0.06% or 600 parts per million (ppm). However, 600 ppm was equivalent to the long-held federal voluntary recall threshold for lead in paint in children’s products until passage of the 2008 U.S. Consumer Product Safety Improvement Act (see below). The American Academy of Pediatrics recommended in 2007 that 40 ppm (based on background levels) should be the threshold for lead in children’s products – providing a basis for a much stronger level of protection for children.
- The Michigan House passed a bill in May 2007 that would have banned disposal of lead-acid batteries in municipal solid waste incinerators (HB4485); however, the Michigan Senate did not act on the bill.
- The Children’s Safe Products Act (HB 4763-4769), which passed out of the Michigan House in 2008, would require the state to create and regularly update a comprehensive list of chemicals of concern and a list of chemicals of highest concern. Manufacturers of children’s products sold in Michigan would be required to identify whether chemicals of highest concern are in these products, and if so, in what quantities. MDCH would be required to make this information accessible to the public. While this Act would not regulate any chemicals, it would be an important step toward providing consumers the right to know what chemicals are in products designed for use by or for children 12 years of age and younger.
- Analysis and Policy Highlights from Other States
- Michigan’s statutory definition of lead paint is consistent with that of most states. Stronger penalties for those who sell or rent units containing lead-hazards would likely result in greater efforts at lead abatement by landlords. However, many states have more stringent bans on the use of lead-paint. Many states ban the use of lead paint in interior or exterior surfaces accessible to children, and on toys, furniture, indoor fixtures, household appliances, and cooking utensils (Arizona Revised Statutes § 36-1674, District of Columbia Code § 8-115.03, Louisiana Revised Statutes § 40:1299.26, Kentucky Revised Statutes XVIII:217.801, Maine Revised Statutes 22 §1316, Maryland ENVIRONMENT Code Ann. § 6-301, Annotated Laws of Massachusetts General Law ch. 111, § 196, New Hampshire X:130-A:4, New Jersey Statutes § 24:14A-1 & 2, Ohio Revised Code Ann. 3742.02, Wisconsin Statutes § 254.12).
- In 2008, Congress passed the U.S. Consumer Product Safety Improvement Act, setting the maximum allowable level of lead in children’s products (regardless of material) at 600 ppm, 300 ppm, and eventually 100 ppm over a 3-year period. It is not as protective as the recommendation of the American Academy of Pediatrics for a ceiling of 40 ppm of lead in children’s products.
- Evaluation and Recommendations
Michigan should continue to pursue measures to protect children from all sources of lead, whether in lead-based paint or in other product materials. Michigan should adopt the American Academy of Pediatrics recommendation of a 40 ppm threshold for lead in any products intended for use by or with children 12 years of age or younger. The Michigan legislature should swiftly adopt the Children’s Safe Products Act (HB 4763-4769).
Summary of Recommendations for Lead Policy in Michigan
Overall, Michigan has taken positive steps to address lead exposure. However, to further reduce exposure to lead, Michigan should strongly consider the following measures:
- Extend the testing goal to 100% of children in the state tested between the ages of 1 and 3.
- All children with blood lead levels above >5 µg/dL should receive follow-up testing at appropriate intervals
- All children with blood levels at 10 µg/dL or greater receive the prescribed medical intervention appropriate to their needs.
Lead Data Tracking
- Establish an official lead poisoning registry and database. While Michigan has created a registry of homes treated for lead poisoning and a registry of children who have tested positive for elevated blood lead levels, it should expand the registry to properties that have housed children with elevated blood lead levels and have not been treated.
Lead Abatement Assistance
- Provide economic incentives for voluntary lead abatement, such as tax credits.
- Continue to fund lead abatement activities in the Michigan Healthy Homes Program.
- Identify a dedicated revenue source for home lead abatement assistance.
- Continue the to further the goals of childhood lead poisoning prevention in the Michigan Healthy Homes Program
- MDCH should launch a state-wide public awareness campaign aimed at parents, focusing on the high-risk ZIP codes.
- MDCH should engage state medical and nursing organizations in a large-scale provider education campaign, focusing on the web-based course developed by the Childhood Lead Poisoning Prevention Program and available at www.training.mihealth.org (MCLPPCC 2007).
- Implement stricter prevention measures such as:
- Testing of child-care facilities to ensure that they are lead-safe, as done in Maine
- Sending written educational materials to the home of any child who tests for elevated blood lead levels, as done in Georgia
- Creating a “lead free” housing registry.
- Requiring the removal of deteriorating lead paint whenever there is a change of tenant, as done in Vermont
- Continuing to pursue measure to remove exposure from all sources (such as toys and lunchboxes), in addition to lead paint
Lead Paint and Lead Paint in Products
- Michigan should adopt the American Academy of Pediatrics recommendation of a 40 ppm threshold for lead in any products intended for use by or with children 12 years of age or younger.
- Health care programs and insurers should cover the cost of all medical, nursing, and educational interventions, according to CDC recommendations, for children with elevated (>10 µg/d) blood lead. If a child has an elevated blood lead level, their health care provider must ensure that the child receives follow-up testing and that the parent or caregiver receives guidance on lead poisoning prevention.
- Funding for lead poisoning prevention and control should be stable and secure until the problem in Michigan is resolved. To the fullest extent possible, funding should reside in a public health trust, where it can grow interest and be distributed according to community need.
- Michigan should assess a $.25 fee upon manufacturer of paint for each gallon of paint sold in the state. Estimated revenue: $4,700,000 per year (MCLPPCC 2007).
- Michigan should aggressively pursue the earmarking of settlement funds for lead poisoning prevention and control, in cooperation with a public health trust. Over a ten year period, the California Trust collected $200 million in revenue, and allocated large sums for lead hazard work.”
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- Numerous studies have shown that blood lead concentrations in children greater than 10 µg/dl are associated with adverse neurological outcomes including intellectual development, functioning and behavior (Canfield et al. 2003). More recent studies have found that children who have blood lead levels lower than 10 µg/dl suffer intellectual impairment from the exposure, indicating that the 10 µg/dl guideline may not be a true safety threshold (Canfield et al. 2003).
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