National Ambient Air Quality Standards for Lead, 71488-71544 [E7-23884]
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ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 50
[EPA–HQ–OAR–2006–0735; FRL–8503–8 ]
RIN 2060–AN83
National Ambient Air Quality
Standards for Lead
Environmental Protection
Agency (EPA).
ACTION: Advance notice of proposed
rulemaking (ANPR).
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AGENCY:
SUMMARY: EPA is issuing this ANPR to
invite comment from all interested
parties on policy options and other
issues related to the Agency’s ongoing
review of the national ambient air
quality standards (NAAQS) for lead
(Pb). Consistent with recent
modifications the Agency has made to
its process for reviewing NAAQS, we
are seeking broad public comment at
this time to help inform the Agency’s
future proposed decisions on the
adequacy of the current Pb NAAQS and
on any revisions of the Pb NAAQS that
may be appropriate. EPA is also
soliciting comment on retaining Pb on
the list of criteria pollutants and on
maintaining NAAQS for Pb.
As part of this review, the Agency has
released several key documents that will
inform the Agency’s rulemaking. These
documents include the Air Quality
Criteria for Lead, released in 2006,
which critically assesses and integrates
relevant scientific information; risk
assessment reports including the most
recent report, Lead: Human Exposure
and Health Risk Assessment for
Selected Case Studies, which
documents quantitative exposure
analyses and risk assessments
conducted for this review; and a
recently released Staff Paper, Review of
the National Ambient Air Quality
Standards for Lead: Policy Assessment
of Scientific and Technical Information,
which presents an evaluation by staff in
EPA’s Office of Air Quality Planning
and Standards (OAQPS) of the policy
implications of the scientific
information and quantitative
assessments and OAQPS staff
conclusions and recommendations on a
range of policy options for the Agency’s
consideration.
Under the terms of a court order, the
Administrator will sign by September 1,
2008 a Notice of Final Rulemaking for
publication in the Federal Register. To
meet this schedule, we anticipate the
Administrator will sign a Notice of
Proposed Rulemaking in March 2008 for
publication in the Federal Register, at
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which time further opportunity for
public comment will be provided.
DATES: Comments must be received by
January 16, 2008.
ADDRESSES: Submit your comments,
identified by Docket ID No. EPA–HQ–
OAR–2006–0735 by one of the following
methods:
• https://www.regulations.gov: Follow
the on-line instructions for submitting
comments.
• E-mail: a-and-r-Docket@epa.gov.
• Fax: 202–566–9744.
• Mail: Docket No. EPA–HQ–OAR–
2006–0735, Environmental Protection
Agency, Mail code 6102T, 1200
Pennsylvania Ave., NW., Washington,
DC 20460. Please include a total of two
copies.
• Hand Delivery: Docket No. EPA–
HQ–OAR–2006–0735, Environmental
Protection Agency, EPA West, Room
3334, 1301 Constitution Ave., NW.,
Washington, DC. Such deliveries are
only accepted during the Docket’s
normal hours of operation, and special
arrangements should be made for
deliveries of boxed information.
Instructions: Direct your comments to
Docket ID No. EPA–HQ–OAR–2006–
0735. The EPA’s policy is that all
comments received will be included in
the public docket without change and
may be made available online at
https://www.regulations.gov, including
any personal information provided,
unless the comment includes
information claimed to be Confidential
Business Information (CBI) or other
information whose disclosure is
restricted by statute. Do not submit
information that you consider to be CBI
or otherwise protected through https://
www.regulations.gov or e-mail. The
https://www.regulations.gov Web site is
an ‘‘anonymous access’’ system, which
means EPA will not know your identity
or contact information unless you
provide it in the body of your comment.
If you send an e-mail comment directly
to EPA without going through https://
www.regulations.gov, your e-mail
address will be automatically captured
and included as part of the comment
that is placed in the public docket and
made available on the Internet. If you
submit an electronic comment, EPA
recommends that you include your
name and other contact information in
the body of your comment and with any
disk or CD–ROM you submit. If EPA
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, EPA may not be
able to consider your comment.
Electronic files should avoid the use of
special characters, any form of
encryption, and be free of any defects or
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viruses. For additional information
about EPA’s public docket, visit the EPA
Docket Center homepage at https://
www.epa.gov/epahome/dockets.htm.
Docket: All documents in the docket
are listed in the https://
www.regulations.gov index. Although
listed in the index, some information is
not publicly available, e.g., CBI or other
information whose disclosure is
restricted by statute. Certain other
material, such as copyrighted material,
will be publicly available only in hard
copy. Publicly available docket
materials are available either
electronically in https://
www.regulations.gov or in hard copy at
the Air and Radiation Docket and
Information Center, EPA/DC, EPA West,
Room 3334, 1301 Constitution Ave.,
NW., Washington, DC. The Public
Reading Room is open from 8:30 a.m. to
4:30 p.m., Monday through Friday,
excluding legal holidays. The telephone
number for the Public Reading Room is
(202) 566–1744 and the telephone
number for the Air and Radiation
Docket and Information Center is (202)
566–1742.
FOR FURTHER INFORMATION CONTACT: Dr.
Deirdre Murphy, Health and
Environmental Impacts Division, Office
of Air Quality Planning and Standards,
U.S. Environmental Protection Agency,
Mail code C504–06, Research Triangle
Park, NC 27711; telephone: 919–541–
0729; fax: 919–541–0237; e-mail:
Murphy.deirdre@epa.gov.
SUPPLEMENTARY INFORMATION:
General Information
What Should I Consider as I Prepare My
Comments for EPA?
1. Submitting CBI. Do not submit this
information to EPA through https://
www.regulations.gov or e-mail. Clearly
mark the part or all of the information
that you claim to be CBI. For CBI
information in a disk or CD ROM that
you mail to EPA, mark the outside of the
disk or CD ROM as CBI and then
identify electronically within the disk or
CD ROM the specific information that is
claimed as CBI. In addition to one
complete version of the comment that
includes information claimed as CBI, a
copy of the comment that does not
contain the information claimed as CBI
must be submitted for inclusion in the
public docket. Information so marked
will not be disclosed except in
accordance with procedures set forth in
40 CFR part 2.
2. Tips for Preparing Your Comments.
When submitting comments, remember
to:
• Identify the rulemaking by docket
number and other identifying
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information (subject heading, Federal
Register date and page number).
• Follow directions—the agency may
ask you to respond to specific questions
or organize comments by referencing a
Code of Federal Regulations (CFR) part
or section number.
• Explain why you agree or disagree,
suggest alternatives, and substitute
language for your requested changes.
• Describe any assumptions and
provide any technical information and/
or data that you used.
• If you estimate potential costs or
burdens, explain how you arrived at
your estimate in sufficient detail to
allow for it to be reproduced.
• Provide specific examples to
illustrate your concerns, and suggest
alternatives.
• Explain your views as clearly as
possible, avoiding the use of profanity
or personal threats.
• Make sure to submit your
comments by the comment period
deadline identified.
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Availability of Related Information
A number of documents relevant to
this rulemaking, including the Air
Quality Criteria for Lead (Criteria
Document) (USEPA, 2006a), the Staff
Paper, related risk assessment reports,
and other related technical documents
are available on EPA’s Office of Air
Quality Planning and Standards
(OAQPS) Technology Transfer Network
(TTN) Web site at https://www.epa.gov/
ttn/naaqs/standards/pb/
s_pb_index.html. These and other
related documents are also available for
inspection and copying in the EPA
docket identified above.
Table of Contents
The following topics are discussed in this
preamble:
I. Introduction
II. Background
A. Legislative Requirements
B. History of Lead NAAQS Reviews
C. Current Related Lead Control Programs
D. Current Lead NAAQS Review
E. Implementation Considerations
III. The Primary Standard
A. Health Effects Information
1. Internal Disposition—Blood Lead as
Dose Metric
2. Nature of Effects
3. Lead-Related Impacts on Public Health
a. At-Risk Subpopulations
b. Potential Public Health Impacts
4. Key Observations
B. Human Exposure and Health Risk
Assessments
1. Overview of Risk Assessment From Last
Review
2. Design Aspects of Exposure and Risk
Assessments
a. CASAC Advice
b. Health Endpoint, Risk Metric and
Concentration-Response Functions
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c. Case Study Approach
d. Air Quality Scenarios
e. Categorization of Policy-Relevant
Exposure Pathways
f. Analytical Steps
g. Generating Multiple Sets of Risk Results
h. Key Limitations and Uncertainties
3. Summary of Results
a. Blood Pb Estimates
b. IQ Loss Estimates
C. Considerations in Review of the
Standard
1. Background on the Current Standard
a. Basis for Setting the Current Standard
b. Policy Options Considered in the Last
Review
2. Approach for Current Review
3. Adequacy of the Current Standard
a. Evidence-Based Considerations
b. Exposure- and Risk-Based
Considerations
c. CASAC Advice and Recommendations
d. Policy Options
4. Elements of the Standard
a. Indicator
b. Averaging Time and Form
c. Level
IV. The Secondary Standard
A. Welfare Effects Information
B. Screening Level Ecological Risk
Assessment
1. Design Aspects of the Assessment and
Associated Uncertanties
2. Summary of Results
C. Considerations in Review of the
Standard
1. Background on the Current Standard
2. Approach for Current Review
3. Adequacy of the Current Standard
a. Evidence-Based Considerations
b. Risk-Based Considerations
c. CASAC Advice and Recommendations
d. Policy Options
4. Elements of the Standard
V. Considerations for Ambient Monitoring
A. Sampling and Analysis Methods
B. Network Design
C. Sampling Schedule
D. Data Handling
E. Monitoring for the Secondary NAAQS
VI. Solicitation of Comment
VII. Statutory and Executive Order Reviews
References
I. Introduction
In the past year EPA has instituted a
number of changes to the process that
the Agency uses in reviewing the
NAAQS to help to improve the
efficiency of the process while ensuring
that the Agency’s decisions are
informed by the best available science
and broad participation among experts
in the scientific community and the
public (described at https://
www.epa.gov/ttn/naaqs/). These
changes apply to the four major
components of the NAAQS review
process: planning, science assessment,
risk/exposure assessment, and policy
assessment/rulemaking. The process
improvements will help the Agency
meet the goal of reviewing each NAAQS
on a 5-year cycle as required by the
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Clean Air Act (CAA) without
compromising the scientific integrity of
the process. These changes are being
incorporated into the various ongoing
NAAQS reviews being conducted by the
Agency, including the current review of
the Pb NAAQS.
The issuance of this ANPR is one of
the key features of the new NAAQS
review process. Historically, a policy
assessment that evaluates the policy
implications of the available scientific
information and risk/exposure
assessments has been presented in the
form of a Staff Paper, prepared by staff
in EPA’s OAQPS, which included
OAQPS staff conclusions and
recommendations on a range of policy
options for the Agency’s consideration.
The new process will enable broader
participation of the scientific
community and the public early in the
NAAQS review by providing scientific
information, risk/exposure assessments,
and policy options in an ANPR rather
than a Staff Paper. The purpose of the
ANPR is to identify conceptual
evidence- and risk-based approaches for
reaching policy judgments, discuss what
the science and risk/exposure
assessments say about the adequacy of
the current standards, and describe a
range of options for standard setting, in
terms of indicators, averaging times,
forms, and ranges of levels for any
alternative standards. Discussion of
alternative standards is to include a
description of the underlying
interpretations of the scientific evidence
and risk/exposure information that
might support such alternative
standards and that could be considered
by the Administrator in making NAAQS
decisions. The issuance of an ANPR
provides the opportunity for the Clean
Air Scientific Advisory Committee
(CASAC) 1 and the public to evaluate
and provide comment on a broad range
of policy options being considered by
the Administrator.
In the case of this Pb NAAQS review,
which was initiated well before changes
were instituted to the NAAQS review
process, both an OAQPS Staff Paper and
an ANPR are being issued. As discussed
below in section II, the issuance of both
documents reflects the terms of a court
order that governs this review and
requires that a final OAQPS Staff Paper
be issued. As a consequence, in addition
to soliciting comment, this ANPR
summarizes information from the
OAQPS Staff Paper (referred to as Staff
Paper throughout this notice) and from
1 As discussed below in section II, CASAC is the
independent scientific review committee that
provides advice and recommendations to the EPA
Administrator related to periodic reviews of
NAAQS, as mandated by the Clean Air Act.
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the Agency’s risk assessment and
Criteria Document. This ANPR is
structured such that policy options on
adequacy of the current standards and
aspects of potential alternative
standards are discussed in Sections III.C
and IV.C. Preceding those policy
discussions are sections focused on
health and welfare effects in Sections
III.A and IV.A, respectively, and on
human exposure and risk and ecological
risk in Sections III.B and IV.B,
respectively.
II. Background
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A. Legislative Requirements
Two sections of the Clean Air Act
(Act) govern the establishment and
revision of the NAAQS. Section 108 (42
U.S.C. 7408) directs the Administrator
to identify and list each air pollutant
that ‘‘in his judgment, cause or
contribute to air pollution which may
reasonably be anticipated to endanger
public health and welfare’’ and whose
‘‘presence * * * in the ambient air
results from numerous or diverse mobile
or stationary sources’’ and to issue air
quality criteria for those that are listed.
Air quality criteria are to ‘‘accurately
reflect the latest scientific knowledge
useful in indicating the kind and extent
of all identifiable effects on public
health or welfare which may be
expected from the presence of [a]
pollutant in ambient air * * *’’. Section
108 also states that the Administrator
‘‘shall, from time to time * * * revise
a list’’ that includes these pollutants,
which provides the authority for a
pollutant to be removed from or added
to the list of criteria pollutants.
Section 109 (42 U.S.C. 7409) directs
the Administrator to propose and
promulgate ‘‘primary’’ and ‘‘secondary’’
NAAQS for pollutants listed under
section 108. Section 109(b)(1) defines a
primary standard as one ‘‘the attainment
and maintenance of which in the
judgment of the Administrator, based on
[air quality] criteria and allowing an
adequate margin of safety, are requisite
to protect the public health.’’ 2 A
secondary standard, as defined in
Section 109(b)(2), must ‘‘specify a level
of air quality the attainment and
maintenance of which, in the judgment
of the Administrator, based on criteria,
is requisite to protect the public welfare
from any known or anticipated adverse
2 The legislative history of section 109 indicates
that a primary standard is to be set at ‘‘the
maximum permissible ambient air level * * *
which will protect the health of any [sensitive]
group of the population,’’ and that for this purpose
‘‘reference should be made to a representative
sample of persons comprising the sensitive group
rather than to a single person in such a group.’’ S.
Rep. No. 91–1196, 91st Cong., 2d Sess. 10 (1970)
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effects associated with the presence of
[the] pollutant in the ambient air.’’ 3
The requirement that primary
standards include an adequate margin of
safety was intended to address
uncertainties associated with
inconclusive scientific and technical
information available at the time of
standard setting. It was also intended to
provide a reasonable degree of
protection against hazards that research
has not yet identified. Lead Industries
Association v. EPA, 647 F.2d 1130, 1154
(DC Cir 1980), cert. denied, 449 U.S.
1042 (1980); American Petroleum
Institute v. Costle, 665 F.2d 1176, 1186
(D.C. Cir. 1981), cert. denied, 455 U.S.
1034 (1982). Both kinds of uncertainties
are components of the risk associated
with pollution at levels below those at
which human health effects can be said
to occur with reasonable scientific
certainty. Thus, in selecting primary
standards that include an adequate
margin of safety, the Administrator is
seeking not only to prevent pollution
levels that have been demonstrated to be
harmful but also to prevent lower
pollutant levels that may pose an
unacceptable risk of harm, even if the
risk is not precisely identified as to
nature or degree.
In selecting a margin of safety, EPA
considers such factors as the nature and
severity of the health effects involved,
the size of the sensitive population(s) at
risk, and the kind and degree of the
uncertainties that must be addressed.
The selection of any particular approach
to providing an adequate margin of
safety is a policy choice left specifically
to the Administrator’s judgment. Lead
Industries Association v. EPA, supra,
647 F.2d at 1161–62.
In setting standards that are
‘‘requisite’’ to protect public health and
welfare, as provided in section 109(b),
EPA’s task is to establish standards that
are neither more nor less stringent than
necessary for these purposes. In so
doing, EPA may not consider the costs
of implementing the standards. See
generally Whitman v. American
Trucking Associations, 531 U.S. 457,
471, 475–76 (2001).
Section 109(d)(1) of the Act requires
that ‘‘Not later than December 31, 1980,
and at 5-year intervals thereafter, the
Administrator shall complete a
thorough review of the criteria
published under section 108 and the
3 Welfare effects as defined in section 302(h) (42
U.S.C. 7602(h)) include, but are not limited to,
‘‘effects on soils, water, crops, vegetation, manmade materials, animals, wildlife, weather,
visibility and climate, damage to and deterioration
of property, and hazards to transportation, as well
as effects on economic values and on personal
comfort and well-being.’’
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national ambient air quality standards
promulgated under this section and
shall make such revisions in such
criteria and standards and promulgate
such new standards as may be
appropriate in accordance with section
108 and subsection (b) of this section.
The Administrator may review and
revise criteria or promulgate new
standards earlier or more frequently
than required under this paragraph.’’
Section 109(d)(2)(A) requires that ‘‘The
Administrator shall appoint an
independent scientific review
committee composed of seven members
including at least one member of the
National Academy of Sciences, one
physician, and one person representing
State air pollution control agencies.’’
Section 109(d)(2)(B) requires that, ‘‘Not
later than January 1, 1980, and at fiveyear intervals thereafter, the committee
referred to in subparagraph (A) shall
complete a review of the criteria
published under section 108 and the
national primary and secondary ambient
air quality standards promulgated under
this section and shall recommend to the
Administrator any new national
ambient air quality standards and
revisions of existing criteria and
standards as may be appropriate under
section 108 and subsection (b) of this
section.’’ 4 Since the early 1980’s, this
independent review function has been
performed by the Clean Air Scientific
Advisory Committee (CASAC) of EPA’s
Science Advisory Board.
B. History of Lead NAAQS Reviews
On October 5, 1978 EPA promulgated
primary and secondary NAAQS for Pb
under section 109 of the Act (43 FR
46246). Both primary and secondary
standards were set at a level of 1.5
micrograms per cubic meter (µg/m3),
measured as Pb in total suspended
particulate matter (Pb-TSP), not to be
exceeded by the maximum arithmetic
mean concentration averaged over a
calendar quarter. This standard was
based on the 1977 Air Quality Criteria
for Lead (USEPA, 1977).
4 In addition to the provisions of Section
109(d)(2)(B), concerning the role of CASAC in
providing advice and recommendations to the
Administrator on the criteria and standards, Section
109(d)(2)(C) provides that CASAC shall also, ‘‘(i)
advise the Administrator of areas in which
additional knowledge is required to appraise the
adequacy and basis of existing, new, or revised
national ambient air quality standards, (ii) describe
the research efforts necessary to provide the
required information, (iii) advise the Administrator
on the relative contribution to air pollution
concentrations of natural as well as anthropogenic
activity, and (iv) advise the Administrator of any
adverse public health, welfare, social economic, or
energy effects which may result from various
strategies for attainment and maintenance of such
national ambient air quality standards.’’
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A review of the Pb standards was
initiated in the mid-1980s. The
scientific assessment for that review is
described in the 1986 Air Quality
Criteria for Lead (USEPA, 1986a), the
associated Addendum (USEPA, 1986b)
and the 1990 Supplement (USEPA,
1990a). As part of the review, the
Agency designed and performed human
exposure and health risk analyses
(USEPA, 1989), the results of which
were presented in a 1990 Staff Paper
(USEPA, 1990b). Based on the scientific
assessment and the human exposure
and health risk analyses, the 1990 Staff
Paper presented options for the Pb
NAAQS level in the range of 0.5 to 1.5
µg/m3, and suggested the second highest
monthly average in three years for the
form and averaging time of the standard
(USEPA, 1990b). After consideration of
the documents developed during the
review and the significantly changed
circumstances since Pb was listed in
1976, as noted above, the Agency did
not propose any revisions to the 1978 Pb
NAAQS. In a parallel effort, the Agency
developed the broad, multi-program,
multimedia, integrated U.S. Strategy for
Reducing Lead Exposure (USEPA,
1991). As part of implementing this
strategy, the Agency focused efforts
primarily on regulatory and remedial
clean-up actions aimed at reducing Pb
exposures from a variety of nonair
sources judged to pose more extensive
public health risks to U.S. populations,
as well as on actions to reduce Pb
emissions to air.
C. Current Related Lead Control
Programs
States are primarily responsible for
ensuring attainment and maintenance of
ambient air quality standards once EPA
has established them. Under section 110
of the Act (42 U.S.C. 7410) and related
provisions, States are to submit, for EPA
approval, State implementation plans
(SIP’s) that provide for the attainment
and maintenance of such standards
through control programs directed to
sources of the pollutants involved. The
States, in conjunction with EPA, also
administer the prevention of significant
deterioration program (42 U.S.C. 7470–
7479) for these pollutants. In addition,
Federal programs provide for
nationwide reductions in emissions of
these and other air pollutants through
the Federal Motor Vehicle Control
Program under Title II of the Act (42
U.S.C. 7521–7574), which involves
controls for automobile, truck, bus,
motorcycle, nonroad engine, and aircraft
emissions; the new source performance
standards under section 111 of the Act
(42 U.S.C. 7411); and the national
emission standards for hazardous air
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pollutants under section 112 of the Act
(42 U.S.C. 7412).
As Pb is a multimedia pollutant, a
broad range of Federal programs beyond
those identified above that focus on air
pollution control provide for
nationwide reductions in environmental
releases and human exposures. The
Centers for Disease Control and
Prevention (CDC) programs provide for
the tracking of children’s blood Pb
levels nationally and provide guidance
on levels at which medical and
environmental case management
activities should be implemented (CDC,
2005a; ACCLPP, 2007).5 In 1991, the
Secretary of the Health and Human
Services (HHS) characterized Pb
poisoning as the ‘‘number one
environmental threat to the health of
children in the United States’’ (Alliance
to End Childhood Lead Poisoning.
1991). And, in 1997, President Clinton
created, by Executive Order 13045, the
President’s Task Force on
Environmental Health Risks and Safety
Risks to Children in response to
increased awareness that children face
disproportionate risks from
environmental health and safety hazards
(62 FR 19885).6 By Executive Orders
issued in October 2001 and April 2003,
President Bush extended the work for
the Task Force for an additional three
and a half years beyond its original
charter (66 FR 52013 and 68 FR 19931).
The Task Force set a Federal goal of
eliminating childhood Pb poisoning by
the year 2010 and reducing Pb
poisoning in children was the Task
Force’s top priority.
Federal abatement programs provide
for the reduction in human exposures
and environmental releases from inplace materials containing Pb (e.g., Pbbased paint, urban soil and dust and
contaminated waste sites). Federal
regulations on disposal of Pb-based
paint waste help facilitate the removal
of Pb-based paint from residences (See
‘‘Criteria for Classification of Solid
Waste Disposal Facilities and Practices
and Criteria for Municipal Solid Waste
Landfills: Disposal of Residential LeadBased Paint Waste; Final Rule’’ EPA–
HQ–RCRA–2001–0017). Further, in
1991, EPA lowered the maximum levels
of Pb permitted in public water systems
from 50 parts per billion (ppb) to 15 ppb
(56 FR 26460).
Federal programs to reduce exposure
to Pb in paint, dust and soil are
5 As described in Section III below the CDC stated
in 2005 that no ‘‘safe’’ threshold for blood Pb levels
in young children has been identified (CDC, 2005a).
6 Co-chaired by the Secretary of the HHS and the
Administrator of the EPA, the Task Force consisted
of representatives from 16 Federal departments and
agencies.
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specified under the comprehensive
federal strategy developed under the
Residential Lead-Based Paint Hazard
Reduction Act (Title X). Under Title X
and Title IV of the Toxic Substances
Control Act, EPA has established
regulations in the following four
categories: (1) Training and certification
requirements for persons engaged in
lead-based paint activities; accreditation
of training providers; work practice
standards for the safe, reliable, and
effective identification and elimination
of lead-based paint hazards; (2)
Ensuring that, for most housing
constructed before 1978, lead-based
paint information flows from sellers to
purchasers, from landlords to tenants,
and from renovators to owners and
occupants; (3) Establishing standards for
identifying dangerous levels of lead in
paint, dust and soil; and (4) Providing
information on lead hazards to the
public, including steps that people can
take to protect themselves and their
families from lead-based paint hazards.
Under Title X of TSCA, EPA
established dust lead standards for
residential housing and soil dust in
2001. This regulation supports the
implementation of other regulations
which deal with worker training and
certification, lead hazard disclosure in
real estate transactions, lead hazard
evaluation and control in federallyowned housing prior to sale and
housing receiving Federal assistance,
and U.S. Department of Housing and
Urban Development grants to local
jurisdictions to perform lead hazard
control. In addition, this regulation also
establishes, among other things, under
authority of TSCA section 402,
residential lead dust cleanup levels and
amendments to dust and soil sampling
requirements (66 FR 1206). The Title X
term ‘‘lead-based paint hazard’’
implemented through this regulation
identifies lead-based paint and all
residential lead-containing dusts and
soils regardless of the source of lead,
which, due to their condition and
location, would result in adverse human
health effects. One of the underlying
principles of Title X is to move the
focus of public and private decision
makers away from the mere presence of
lead-based paint, to the presence of
lead-based paint hazards, for which
more substantive action should be
undertaken to control exposures,
especially to young children. In
addition the success of the program will
rely on the voluntary participation of
states and tribes as well as counties and
cities to implement the programs and on
property owners to follow the standards
and EPA’s recommendations. If EPA
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were to set unreasonable standards (e.g.,
standards that would recommend
removal of all lead from paint, dust and
soil), States and Tribes may choose to
opt out of the Title X lead program and
property owners may choose to ignore
EPA’s advice believing it lacks
credibility and practical value.
Consequently, EPA needed to develop
standards that would not waste
resources by chasing risks of negligible
importance and that would be accepted
by States, Tribes, local governments and
property owners.
On January 10, 2006, EPA issued a
Notice of Proposed Rulemaking
covering renovations performed for
compensation in target housing. The
2006 Proposal contains requirements
designed to address lead hazards
created by renovation, repair, and
painting activities that disturb leadbased paint. The 2006 Proposal includes
requirements for training renovators,
other renovation workers, and dust
sampling technicians; for certifying
renovators, dust sampling technicians,
and renovation firms; for accrediting
providers of renovation and dust
sampling technician training; for
renovation work practices; and for
recordkeeping. The 2006 Proposal
proposes to make the rule effective in
two stages. Initially, the rule proposes to
apply to all renovations for
compensation performed in target
housing where a child with an increased
blood lead level resided and rental
target housing built before 1960. The
proposed rule also proposes application
to owner-occupied target housing built
before 1960, unless the person
performing the renovation obtained a
statement signed by the owner-occupant
that the renovation would occur in the
owner’s residence and that no child
under age 6 resided there. As proposed,
the rule would take effect one year later
in all rental target housing built between
1960 and 1978 and owner-occupied
target housing built between 1960 and
1978. EPA also proposes to allow
interested States, Territories, and Indian
Tribes the opportunity to apply for and
receive authorization to administer and
enforce all of the elements of the new
renovation provisions.
A significant number of commenters
observed that the proposal did not cover
buildings where children under age 6
spend a great deal of time, such as day
care centers and schools. Commenters
noted that the risk posed to children
from lead-based paint hazards in
schools and day-care centers is likely to
be equal to, if not greater than, the risk
posed from these hazards at home.
These commenters suggested that EPA
expand its proposal to include such
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places, and several suggested that EPA
use the existing definition of ‘‘childoccupied facility’’ in 40 CFR § 745.223
to define the expanded scope of
coverage. EPA felt that these comments
had merit, and, because adding childoccupied facilities was beyond the
scope of the 2006 Proposal, an
expansion of the 2006 Proposal was
necessary to give this issue full and fair
consideration. Accordingly, on June 5,
2007, EPA issued a Supplemental
Notice of Proposed Rulemaking to add
child-occupied facilities to the universe
of buildings covered by the 2006
Proposal. EPA is working expeditiously
to finalize this rulemaking and expects
to do so in the first calendar quarter of
2008.
Programs associated with the
Comprehensive Environmental
Response, Compensation, and Liability
Act (CERCLA or Superfund) and
Resource Conservation Recovery Act
(RCRA) also implement abatement
programs, reducing exposures to Pb and
other pollutants. For example, EPA
determines and implements protective
levels for Pb in soil at Superfund sites
and RCRA corrective action facilities.
Federal programs, including those
implementing RCRA, provide for
management of hazardous substances in
hazardous and municipal solid waste
(e.g., ‘‘Hazardous Waste Management
System; Identification and Listing of
Hazardous Waste: Inorganic Chemical
Manufacturing Wastes; Land Disposal
Restrictions for Newly Identified Wastes
and CERCLA Hazardous Substance
Designation and Reportable Quantities;
Final Rule’’, https://www.epa.gov/
epaoswer/hazwaste/state/revision/frs/
fr195.pdf and https://www.epa.gov/
epaoswer/hazwaste/ldr/basic.htm). For
example, Federal regulations concerning
batteries in municipal solid waste
facilitate the collection and recycling or
proper disposal of batteries containing
Pb (e.g., See ‘‘Implementation of the
Mercury-Containing and Rechargeable
Battery Management Act’’ https://
www.epa.gov/epaoswer/hazwaste/
recycle/battery.pdf and ‘‘Municipal
Solid Waste Generation, Recycling, and
Disposal in the United States: Facts and
Figures for 2005’’ https://www.epa.gov/
epaoswer/osw/conserve/resources/msw2005.pdf). Similarly, Federal programs
provide for the reduction in
environmental releases of hazardous
substances such as Pb in the
management of wastewater (https://
www.epa.gov/owm/).
A variety of federal nonregulatory
programs also provide for reduced
environmental release of Pb containing
materials through more general
encouragement of pollution prevention,
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promote reuse and recycling, reduce
priority and toxic chemicals in products
and waste, and conserve energy and
materials. These include the Resource
Conservation Challenge (https://
www.epa.gov/epaoswer/osw/conserve/
index.htm), the National Waste
Minimization Program (https://
www.epa.gov/epaoswer/hazwaste/
minimize/leadtire.htm), ‘‘Plug in to
eCycling’’ (a partnership between EPA
and consumer electronics manufacturers
and retailers; https://www.epa.gov/
epaoswer/hazwaste/recycle/electron/
crt.htm#crts), and activities to reduce
the practice of backyard trash burning
(https://www.epa.gov/msw/backyard/
pubs.htm).
Efforts such as those programs
described above have been successful in
that blood Pb levels in all segments of
the population have dropped
significantly from levels around 1990. In
particular, blood Pb levels for the
general population of children 1 to 5
years of age have dropped to a median
level of 1.6 µg/dL and a level of 3.9 µg/
dL for the 90th percentile child in the
2003–2004 NHANES as compared to
median and 90th percentile levels in
1988–1991 of 3.5 µg/dL and 9.4 µg/dL,
respectively (https://www.epa.gov/
envirohealth/children/body_burdens/
b1-table.htm). These levels (median and
90th percentile) for the general
population of young children 7 are at the
low end of the historic range of blood
Pb levels for general population of
children aged 1–5 years and are below
a level of 5 µg/dL—a level that has been
associated with adverse effects with a
higher degree of certainty in the
published literature (than levels such as
2 µg/dL) and is a level where cognitive
deficits were identified with statistical
significance (Lanphear et al., 2000). The
decline in blood Pb levels in the United
States has resulted from coordinated,
intensive efforts at the national, state
and local levels. The Agency has
continued to grapple with soil and dust
Pb levels from the historical use of Pb
in paint and gasoline and other sources.
In doing so, the agency has faced the
difficulty of determining the level at
which to set standards for residential
dust levels given the uncertainties at
what environmental levels and in which
specific medium may actually cause
particular blood Pb levels that are
7 It is noted that although the 95th percentile
value for the 2003–2004 NHANES is not currently
available, that value for 2001–2002 was 5.8 µg/dL.
Also, as discussed in Section III.A.1 (including
footnote 15), levels have been found to vary among
children of different socioeconomic status and other
demographic characteristics (CD, p. 4–21).
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associated with adverse effects (66 FR
1206).8
EPA’s research program, with other
Federal agencies defines, encourages
and conducts research needed to locate
and assess serious risks and to develop
methods and tools to characterize and
help reduce risks. For example, EPA’s
Integrated Exposure Uptake Biokinetic
Model for Lead in Children (IEUBK
model) for Pb in children and the Adult
Lead Methodology are widely used and
accepted as tools that provide guidance
in evaluating site specific data. More
recently, in recognition of the need for
a single model that predicts Pb
concentrations in tissues for children
and adults, EPA is developing the All
Ages Lead Model (AALM) to provide
researchers and risk assessors with a
pharmacokinetic model capable of
estimating blood, tissue, and bone
concentrations of Pb based on estimates
of exposure over the lifetime of the
individual. EPA research activities on
substances including Pb focus on better
characterizing aspects of health and
environmental effects, exposure and
control or management of
environmental releases (see https://
www.epa.gov/ord/
researchaccomplishments/).
D. Current Lead NAAQS Review
EPA initiated the current review of
the air quality criteria for Pb on
November 9, 2004 with a general call for
information (69 FR 64926). A project
work plan (USEPA, 2005a) for the
preparation of the Criteria Document
was released in January 2005 for CASAC
and public review. EPA held a series of
workshops in August 2005, with invited
recognized scientific experts to discuss
initial draft materials that dealt with
various lead-related issues being
addressed in the Pb air quality criteria
document. The first draft of the Criteria
Document (USEPA, 2005b) was released
for CASAC and public review in
December 2005 and discussed at a
CASAC meeting held on February 28–
March 1, 2006.
A second draft Criteria Document
(USEPA, 2006b) was released for
CASAC and public review in May 2006,
and discussed at the CASAC meeting on
June 28, 2006. A subsequent draft of
Chapter 7—Integrative Synthesis
(Chapter 8 in the final Criteria
Document), released on July 31, 2006,
was discussed at an August 15, 2006
CASAC teleconference. The final
Criteria Document was released on
September 30, 2006 (USEPA, 2006a;
8 See 2001 regulation to establish standards for
lead-based paint hazards in most pre-1978 housing
and child-occupied facilities (66 FR 1206).
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cited throughout this preamble as CD).
While the Criteria Document focuses on
new scientific information available
since the last review, it integrates that
information with scientific criteria from
previous reviews.
In February 2006, EPA released the
Plan for Review of the National Ambient
Air Quality Standards for Lead (USEPA
2006c) that described Agency plans and
a timeline for reviewing the air quality
criteria, developing human exposure
and risk assessments and an ecological
risk assessment, preparing a policy
assessment, and developing the
proposed and final rulemakings.
In May 2006, EPA released for CASAC
and public review a draft Analysis Plan
for Human Health and Ecological Risk
Assessment for the Review of the Lead
National Ambient Air Quality
Standards (USEPA, 2006d), which was
discussed at a June 29, 2006 CASAC
meeting (Henderson, 2006). The May
2006 assessment plan discussed two
assessment phases: a pilot phase and a
full-scale phase. The pilot phase of both
the human health and ecological risk
assessments was presented in the draft
Lead Human Exposure and Health Risk
Assessments and Ecological Risk
Assessment for Selected Areas (ICF,
2006; henceforth referred to as the first
draft Risk Assessment Report) which
was released for CASAC and public
review in December 2006. The first draft
Staff Paper, also released in December
2006, discussed the pilot assessments
and the most policy-relevant science
from the Criteria Document. These
documents were reviewed by CASAC
and the public at a public meeting on
February 6–7, 2007 (Henderson, 2007a).
Subsequent to that meeting, EPA
conducted full-scale human exposure
and health risk assessments, although
no further work was done on the
ecological assessment due to resource
limitations. A second draft Risk
Assessment Report (USEPA, 2007a),
containing full-scale human exposure
and health risk assessments, was
released in July 2007 for review by
CASAC at a meeting held on August 28–
29, 2007. Taking into consideration
CASAC comments (Henderson, 2007b)
and public comments on that document,
we conducted additional human
exposure and health risk assessments. A
final Risk Assessment Report (USEPA,
2007b) and final Staff Paper (USEPA,
2007c) were released on November 1,
2007.
The final Staff Paper presents OAQPS
staff’s evaluation of the policy
implications of the key studies and
scientific information contained in the
Criteria Document and presents and
interprets results from the quantitative
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risk/exposure analyses conducted for
this review. Further, the Staff Paper
presents OAQPS staff recommendations
on a range of policy options for the
Administrator to consider concerning
whether, and if so how, to review the
primary and secondary Pb NAAQS.
Such an evaluation is intended to help
‘‘bridge the gap’’ between the scientific
assessment contained in the Criteria
Document and the judgments required
of the EPA Administrator in
determining whether it is appropriate to
retain or revise the NAAQS for Pb. In
evaluating the adequacy of the current
standard and a range of policy
alternatives, the Staff Paper considered
the available scientific evidence and
quantitative risk-based analyses,
together with related limitations and
uncertainties, and focused on the
information that is most pertinent to
evaluating the basic elements of air
quality standards: Indicator,9 averaging
time, form,10 and level. These elements,
which together serve to define each
standard, must be considered
collectively in evaluating the health and
welfare protection afforded by the Pb
standards. The information,
conclusions, and OAQPS staff
recommendations presented in the Staff
Paper were informed by comments and
advice received from CASAC in its
reviews of the earlier draft Staff Paper
and drafts of related risk/exposure
assessment reports, as well as comments
on these earlier draft documents
submitted by public commenters.
The schedule for completion of this
review is governed by a judicial order
resolving a lawsuit filed in May 2004,
alleging that EPA had failed to complete
the current review within the period
provided by statute. Missouri Coalition
for the Environment, v. EPA (No.
4:04CV00660 ERW, Sept. 14, 2005). The
order that now governs this review,
entered by the court on September 14,
2005, provides that EPA finalize the
Staff Paper no later than November 1,
2007, which we have done. The order
also specifies that EPA sign, for
publication, notices of proposed and
final rulemaking concerning its review
of the Pb NAAQS no later than May 1,
2008 and September 1, 2008,
respectively. To ensure that the ordered
final rulemaking deadline will be met,
EPA has set an interim target date for a
proposed rulemaking of March 2008.
9 The ‘‘indicator’’ of a standard defines the
chemical species or mixture that is to be measured
in determining whether an area attains the
standard.
10 The ‘‘form’’ of a standard defines the air quality
statistic that is to be compared to the level of the
standard in determining whether an area attains the
standard.
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The EPA invites general, specific,
and/or technical comments on all issues
discussed in this ANPR, including
issues related to the Agency’s review of
the primary and secondary Pb NAAQS
(sections III and IV below) and
associated monitoring considerations
(section V below). EPA also invites
comments on all information, findings,
and recommendations presented in this
notice (section VI below).
A public meeting of the CASAC will
be held on December 12–13, 2007 for
the purpose of providing advice and
recommendations to the Administrator
based on its review of this ANPR and
the recently released final Staff Paper
and Risk Assessment Report.
Information about this meeting was
published in the Federal Register on
November 20, 2007 (72 FR 65335–
65336).
E. Implementation Considerations
Currently only two areas in the
United States are designated as nonattainment of the Pb NAAQS. If the Pb
NAAQS is significantly lowered as a
result of this review, it is likely (based
on a review of the current air quality
monitoring data) that many more areas
would be classified as non-attainment
(see section 2.3.2.5 of the Staff Paper for
more details). States with Pb nonattainment areas would be required to
develop ‘‘State Implementation Plans’’
that identify and implement specific air
pollution control measures that would
reduce the ambient Pb concentrations to
below the Pb NAAQS. If the Pb NAAQS
is revised to a lower level, States may
be able to attain the revised NAAQS by
implementing air pollution controls on
lead emitting industrial sources. These
controls include such measures as fabric
filter particulate controls and fugitive
dust controls. However, at some of the
lower Pb concentration levels that have
been identified for consideration in this
review, it may become necessary in
some areas to implement controls on
nonindustrial sources such as dust from
roadways, dust from construction, and/
or demolition sites.
As described in further detail in the
Staff Paper (see Section 2.2), Pb is
emitted from a wide variety of source
types. The top five categories of sources
of Pb emissions included in the EPA’s
2002 National Emissions Inventory
(NEI) include: Mobile sources; 11
industrial, commercial, institutional and
process boilers; utility boilers; iron and
11 The emissions estimates identified as mobile
sources in the current NEI are currently limited to
combustion of general aviation gas in piston-engine
aircraft. Lead emissions estimates for other mobile
source emissions of Pb (e.g., brake wear, tire wear,
and others) are not included in the current NEI.
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steel foundries; and primary Pb smelting
(see Staff Paper Section 2.2).
III. The Primary Standard
This section presents information
relevant to the review of the primary Pb
NAAQS, including information on the
health effects associated with Pb
exposures, results of the human
exposure and health risk assessment,
and considerations related to evaluating
the adequacy of the current standard
and alternative standards that might be
appropriate for the Administrator to
consider.
A. Health Effects Information
The following summary focuses on
health endpoints associated with the
range of exposures considered to be
most relevant to current exposure levels
and makes note of several key aspects of
the health evidence for Pb. First,
because exposure to atmospheric Pb
particles occurs not only via direct
inhalation of airborne particles, but also
via ingestion of deposited particles (e.g.,
associated with soil and dust), the
exposure being assessed is multimedia
and multi-pathway in nature, occurring
via both the inhalation and ingestion
routes. In fact, ingestion of indoor dust
can be recognized as a significant Pb
exposure pathway, particularly for
young children, for which dust ingested
via hand-to-mouth activity can be a
more important source of Pb exposure
than inhalation, although dust can be
resuspended through household
activities and pose an inhalation risk as
well (CD, p. 3–27 to 3–28).12 Some
studies have found that dietary intake of
Pb may be a predominant source of Pb
exposure among adults, greater than
consumption of water and beverages or
inhalation (CD, p. 3–43).13 Second, the
12 For example, the Criteria Document states the
following: ‘‘Given the large amount of time people
spend indoors, exposure to Pb in dusts and indoor
air can be significant. For children, dust ingested
via hand-to-mouth activity is often a more
important source of Pb exposure than inhalation.
Dust can be resuspended through household
activities, thereby posing an inhalation risk as well.
House dust Pb can derive both from Pb-based paint
and from other sources outside the home. The latter
include Pb-contaminated airborne particles from
currently operating industrial facilities or
resuspended soil particles contaminated by
deposition of airborne Pb from past emissions.’’
(CD, p. E–6)
13 Some recent exposure studies have evaluated
the relative importance of diet to other routes of Pb
exposure. In reports from the NHEXAS, Pb
concentrations measured in households throughout
the Midwest were significantly higher in solid food
compared to beverages and tap water (Clayton et al.,
1999; Thomas et al., 1999). However, beverages
appeared to be the dominant dietary pathway for Pb
according to the statistical analysis (Clayton et al.,
1999), possibly indicating greater bodily absorption
of Pb from liquid sources (Thomas et al., 1999).
Dietary intakes of Pb were greater than those
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exposure index or dose metric most
commonly used and associated with
health effects information is an internal
biomarker (i.e., blood Pb). Additionally,
the exposure duration of interest (i.e.,
that influencing internal dose pertinent
to health effects of interest) may span
months to potentially years, as does the
time scale of the environmental
processes influencing Pb deposition and
fate. Lastly, the nature of the evidence
for the health effects of greatest interest
for this review, neurological effects in
young children, are epidemiological
data substantiated by toxicological data
that provide biological plausibility and
insights on mechanisms of action (CD,
sections 5.3, 6.2 and 8.4.2).
In recognition of the multi-pathway
aspects of Pb, and the use of an internal
exposure metric in health risk
assessment, the next section describes
the internal disposition or distribution
of Pb, and the use of blood Pb as an
internal exposure or dose metric. This is
followed by a discussion of the nature
of Pb-induced health effects that
emphasizes those with the strongest
evidence. Potential impacts of Pb
exposures on public health, including
recognition of potentially susceptible or
vulnerable subpopulations, are then
discussed. Finally, key observations
about Pb-related health effects are
summarized.
1. Internal Disposition—Blood Lead as
Dose Metric
The health effects of Pb are remote
from the portals of entry to the body
(i.e., the respiratory system and
gastrointestinal tract). Consequently, the
internal disposition and distribution of
Pb is an integral aspect of the
relationship between exposure and
effect. This section briefly summarizes
the current state of knowledge of Pb
disposition pertaining to both inhalation
and ingestion routes of exposure as
described in the Criteria Document.
Inhaled Pb particles deposit in the
different regions of the respiratory tract
as a function of particle size (CD, pp. 4–
3 to 4–4). Lead associated with smaller
particles, which are predominantly
deposited in the pulmonary region,
may, depending on solubility, be
absorbed into the general circulation or
transported to the gastrointestinal tract
(CD, pp. 4–3). Lead associated with
larger particles, which are
predominantly deposited in the head
and conducting airways (e.g., nasal
calculated for intake from home tap water or
inhalation on a µg/day basis (Thomas et al., 1999).
The NHEXAS study in Arizona showed that, for
adults, ingestion was a more important Pb exposure
route than inhalation (O’Rourke et al., 1999). (CD,
p. 3–43)
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pharyngeal and tracheobronchial
regions of respiratory tract), may be
transported into the esophagus and
swallowed, thus making its way to the
gastrointestinal tract (CD, pp. 4–3 to 4–
4), where it may be absorbed into the
blood stream. Thus, Pb can reach the
gastrointestinal tract either directly
through the ingestion route or indirectly
following inhalation.
Once in the blood stream, where
approximately 99% of the Pb associates
with red blood cells, the Pb is quickly
distributed throughout the body (e.g.,
within days) with the bone serving as a
large, long-term storage compartment,
and soft tissues (e.g., kidney, liver,
brain, etc) serving as smaller
compartments, in which Pb may be
more mobile (CD, sections 4.3.1.4 and
8.3.1.). Additionally, the epidemiologic
evidence indicates that Pb freely crosses
the placenta resulting in continued fetal
exposure throughout pregnancy, and
that exposure increases during the later
half of pregnancy (CD, section 6.6.2).
During childhood development, bone
represents approximately 70% of a
child’s body burden of Pb, and this
accumulation continues through
adulthood, when more than 90% of the
total Pb body burden is stored in the
bone (CD, section 4.2.2). Accordingly,
levels of Pb in bone are indicative of a
person’s long-term, cumulative
exposure to Pb. In contrast, blood Pb
levels are usually indicative of recent
exposures. Depending on exposure
dynamics, however, blood Pb may—
through its interaction with bone—be
indicative of past exposure or of
cumulative body burden (CD, section
4.3.1.5).
Throughout life, Pb in the body is
exchanged between blood and bone, and
between blood and soft tissues (CD,
section 4.3.2), with variation in these
exchanges reflecting ‘‘duration and
intensity of the exposure, age and
various physiological variables’’ (CD, p.
4–1). Past exposures that contribute Pb
to the bone, consequently, may
influence current levels of Pb in blood.
Where past exposures were elevated in
comparison to recent exposures, this
influence may complicate
interpretations with regard to recent
exposure (CD, sections 4.3.1.4 to
4.3.1.6). That is, higher blood Pb
concentrations may be indicative of
higher cumulative exposures or of a
recent elevation in exposure (CD, pp. 4–
34 and 4–133).
In several recent studies investigating
the relationship between Pb exposure
and blood Pb in children (e.g., Lanphear
and Roghmann 1997; Lanphear et al.,
1998), blood Pb levels have been shown
to reflect Pb exposures, with particular
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influence associated with exposures to
Pb in surface dust. Further, as stated in
the Criteria Document ‘‘these and other
studies of populations near active
sources of air emissions (e.g., smelters,
etc.), substantiate the effect of airborne
Pb and resuspended soil Pb on interior
dust and blood Pb’’ (CD, p. 8–22).
Blood Pb levels are extensively used
as an index or biomarker of exposure by
national and international health
agencies, as well as in epidemiological
(CD, sections 4.3.1.3 and 8.3.2) and
toxicological studies of Pb health effects
and dose-response relationships (CD,
Chapter 5). The prevalence of the use of
blood Pb as an exposure index or
biomarker is related to both the ease of
blood sample collection (CD, p. 4–19;
Section 4.3.1) and by findings of
association with a variety of health
effects (CD, Section 8.3.2). For example,
the U.S. Centers for Disease Control and
Prevention (CDC), and its predecessor
agencies, have for many years used
blood Pb level as a metric for identifying
children at risk of adverse health effects
and for specifying particular public
health recommendations (CDC, 1991;
CDC, 2005a). In 1978, when the current
Pb NAAQS was established, the CDC
recognized a blood Pb level of 30 µg/dL
as a level warranting individual
intervention (CDC, 1991). In 1985, the
CDC recognized a level of 25 µg/dL for
individual child intervention, and in
1991, they recognized a level of 15 µg/
dL for individual intervention and a
level of 10 µg/dL for implementing
community-wide prevention activities
(CDC, 1991; CDC, 2005). In 2005, with
consideration of a review of the
evidence by their advisory committee,
CDC revised their statement on
Preventing Lead Poisoning in Young
Children, specifically recognizing the
evidence of adverse health effects in
children with blood Pb levels below 10
µg/dL and the data demonstrating that
no ‘‘safe’’ threshold for blood Pb had
been identified, and emphasizing the
importance of preventative measures
(CDC, 2005a, ACCLPP, 2007).14
Since 1976, the CDC has been
monitoring blood Pb levels nationally
through the National Health and
14 With the 2005 statement, CDC identified a
variety of reasons, reflecting both scientific and
practical considerations, for not lowering the 1991
level of concern, including a lack of effective
clinical or public health interventions to reliably
and consistently reduce blood Pb levels that are
already below 10 µg/dL, the lack of a demonstrated
threshold for adverse effects, and concerns for
deflecting resources from children with higher
blood Pb levels (CDC, 2005a). CDC’s Advisory
Committee on Childhood Lead Poisoning
Prevention recently provided recommendations
regarding interpreting and managing blood Pb
levels below 10 µg/dL in children and reducing
childhood exposures to Pb (ACCLPP, 2007).
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Nutrition Examination Survey
(NHANES). This survey has
documented the dramatic decline in
mean blood Pb levels in the U.S.
population that has occurred since the
1970s and that coincides with
regulations regarding leaded fuels,
leaded paint, and Pb-containing
plumbing materials that have reduced
Pb exposure among the general
population (CD, Sections 4.3.1.3 and
8.3.3; Schwemberger et al., 2005). The
Criteria Document summarizes related
information as follows (CD, p. E–6).
In the United States, decreases in mobile
sources of Pb, resulting from the phasedown
of Pb additives created a 98% decline in
emissions from 1970 to 2003. NHANES data
show a consequent parallel decline in bloodPb levels in children aged 1 to 5 years from
a geometric mean of ~15 µg/dL in 1976–1980
to 1–2 µg/dL in the 2000–2004 period.
While levels in the U.S. general
population, including geometric mean
levels in children aged 1–5, have
declined significantly, mean levels have
been found to vary among children of
different socioeconomic status (SES)
and other demographic characteristics
(CD, p. 4–21).15
Bone measurements, as a result of the
generally slower Pb turnover in bone,
are recognized as providing a better
measure of cumulative Pb exposure (CD,
Section 8.3.2). The bone pool of Pb in
children, however, is thought to be
much more labile than that in adults
due to the more rapid turnover of bone
mineral as a result of growth (CD, p. 4–
27). As a result, changes in blood Pb
concentration in children more closely
parallel changes in total body burden
(CD, pp. 4–20 and 4–27). This is in
contrast to adults, whose bone has
accumulated decades of Pb exposures
(with past exposures often greater than
current ones), and for whom the bone
may be a significant source long after
exposure has ended (CD, Section
4.3.2.5).
15 For example, while the 2001–2004 median
blood level for children aged 1–5 of all races and
ethnic groups is 1.6 µg/dL, the median for the
subset living below the poverty level is 2.3 µg/dL
and 90th percentile values for these two groups are
4.0 µg/dL and 5.4 µg/dL, respectively. Similarly, the
2001–2004 median blood level for black, nonhispanic children aged 1–5 is 2.5 µg/dL, while the
median level for the subset of that group living
below the poverty level is 2.9 µg/dL and the median
level for the subset living in a household with
income more than 200% of the poverty level is 1.9
µg/dL. Associated 90th percentile values for 2001–
2004 are 6.4 µg/dL (for black, non-hispanic children
aged 1–5), 7.7 µg/dL (for the subset of that group
living below the poverty level) and 4.1 µg/dL (for
the subset living in a household with income more
than 200% of the poverty level). (https://
www.epa.gov/envirohealth/children/body_burdens/
b1-table.htm—then click on ‘‘Download a universal
spreadsheet file of the Body Burdens data tables’’).
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Accordingly, blood Pb level in
children is the index of exposure or
exposure metric in the risk assessment
discussed below in section III.B. The
use of concentration-response functions
that rely on blood Pb (e.g., rather than
ambient Pb concentration) as the
exposure metric reduces uncertainty in
the causality aspects of Pb risk
estimates. The relationship between
specific sources and pathways of
exposure and blood Pb level is needed,
however, in order to identify the
specific risk contributions associated
with those sources and pathways of
greatest interest to this assessment (i.e.,
those related to Pb emitted into the air).
For example, the blood Pb-response
relationships developed in
epidemiological studies of Pb exposed
populations do not distinguish among
different sources or pathways of Pb
exposure (e.g., inhalation, ingestion of
indoor dust, ingestion of dust
containing leaded paint). In the
exposure assessment for this review,
models that estimate blood Pb levels
associated with Pb exposure (e.g., CD,
Section 4.4) are used to inform estimates
of contributions to blood Pb arising from
ambient air related Pb as compared to
contributions from other sources.
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2. Nature of Effects
Lead has been demonstrated to exert
‘‘a broad array of deleterious effects on
multiple organ systems via widely
diverse mechanisms of action’’ (CD, p.
8–24 and Section 8.4.1). This array of
health effects includes heme
biosynthesis and related functions;
neurological development and function;
reproduction and physical
development; kidney function;
cardiovascular function; and immune
function. The weight of evidence varies
across this array of effects and is
comprehensively described in the
Criteria Document. There is also some
evidence of Pb carcinogenicity,
primarily from animal studies, together
with limited human evidence of
suggestive associations (CD, Sections
5.6.2, 6.7, and 8.4.10).16
This review is focused on those
effects most pertinent to ambient
exposures, which given the reductions
in ambient Pb levels over the past 30
years, are generally those associated
with blood Pb levels in children and
adults in the range of 10 µg/dL and
16 Lead has been classified as a probable human
carcinogen by the International Agency for Research
on Cancer, based mainly on sufficient animal
evidence, and as reasonably anticipated to be a
human carcinogen by the U.S. National Toxicology
Program (CD, Section 6.7.2). U.S. EPA considers Pb
a probable carcinogen (https://www.epa.gov/iris/
subst/0277.htm; CD, p. 6–195).
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lower. Tables 8–5 and 8–6 in the
Criteria Document highlight the key
such effects observed in children and
adults, respectively (CD, pp. 8–60 to 8–
62). The effects include neurological,
hematological and immune effects for
children, and hematological,
cardiovascular and renal effects for
adults. As evident from the discussions
in Chapters 5, 6 and 8 of the Criteria
Document, ‘‘neurotoxic effects in
children and cardiovascular effects in
adults are among those best
substantiated as occurring at blood Pb
concentrations as low as 5 to 10 µg/dL
(or possibly lower); and these categories
are currently clearly of greatest public
health concern’’ (CD, p. 8–60). The
toxicological and epidemiological
information available since the time of
the last review ‘‘includes assessment of
new evidence substantiating risks of
deleterious effects on certain health
endpoints being induced by distinctly
lower than previously demonstrated Pb
exposures indexed by blood Pb levels
extending well below 10 µg/dL in
children and/or adults’’ (CD, p. 8–25).
Some health effects associated with
blood Pb levels extend below 5 µg/dL,
and some studies have observed these
effects at the lowest blood levels
considered. Threshold levels for these
effects cannot be discerned from the
currently available studies. For
example, the Criteria Document also
states the following (CD, p. 6–269).
Recent studies of Pb neurotoxicity in
children consistently indicate that blood Pb
levels <10 µg/dL are associated with
neurocognitive deficits. The data are also
suggestive that these effects may be seen at
blood Pb levels ranging down to 5 µg/dL, or
perhaps somewhat lower, but the evidence is
less definitive.17
Since effects on children’s developing
nervous system are considered to be the
sentinel effects in this review, and are
the focus of the quantitative risk
assessment conducted for this review
(discussed below in section III.B), these
effects are discussed briefly below.
Other neurological effects associated
with Pb exposures indexed by blood Pb
levels near or below 10 µg/dL include
behavioral effects, such as delinquent
behavior (CD, Sections 6.2.6 and
8.4.2.2), sensory effects, such as those
related to hearing and vision (CD,
Sections 6.2.7, 7.4.2.3 and 8.4.2.3), and
deficits in neuromotor function (CD, p.
8–36). The differing evidence and
17 The Criteria Document further states
‘‘Collectively, the prospective cohort and crosssectional studies offer evidence that exposure to Pb
affects the intellectual attainment of preschool and
school age children at blood Pb levels <10 µg/dL
(most clearly in the 5 to 10 µg/dL range, but, less
definitively, possibly lower).’’ (p. 6–269)
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associated strength of the evidence for
these different effects is described in
detail in the Criteria Document.
The nervous system has long been
recognized as a target of Pb toxicity,
with the developing nervous system
affected at lower exposures than the
mature system (CD, Sections 5.3, 6.2.1,
6.2.2, and 8.4). While blood Pb levels in
U.S. children ages one to five years have
decreased notably since the late 1970s,
newer studies have investigated and
reported associations of effects on the
neurodevelopment of children with
these more recent blood Pb levels (CD,
Chapter 6). Functional manifestations of
Pb neurotoxicity during childhood
include sensory, motor, cognitive and
behavioral impacts. Numerous
epidemiological studies have reported
neurocognitive, neurobehavioral,
sensory, and motor function effects in
children at blood Pb levels below 10 µg/
dL (CD, Section 6.2). As discussed in
the Criteria Document, ‘‘extensive
experimental laboratory animal
evidence has been generated that (a)
substantiates well the plausibility of the
epidemiologic findings observed in
human children and adults and (b)
expands our understanding of likely
mechanisms underlying the neurotoxic
effects’’ (CD, p. 8–25; Section 5.3).
Cognitive effects associated with Pb
exposures that have been observed in
epidemiological studies have included
decrements in intelligence test results,
such as the widely used IQ score, and
in academic achievement as assessed by
various standardized tests as well as by
class ranking and graduation rates (CD,
Section 6.2.16 and pp. 8–29 to 8–30). As
noted in the Criteria Document with
regard to the latter, ‘‘Associations
between Pb exposure and academic
achievement observed in the abovenoted studies were significant even after
adjusting for IQ, suggesting that Pbsensitive neuropsychological processing
and learning factors not reflected by
global intelligence indices might
contribute to reduced performance on
academic tasks’’ (CD, pp. 8–29 to 8–30).
Other cognitive effects observed in
studies of children have included effects
on attention, executive functions,
language, memory, learning and
visuospatial processing (CD, Sections
5.3.5, 6.2.5 and 8.4.2.1), with attention
and executive function effects
associated with Pb exposures indexed
by blood Pb levels below 10 µg/dL (CD,
Section 6.2.5 and pp. 8–30 to 8–31). The
evidence for the role of Pb in this suite
of effects includes experimental animal
findings (discussed in CD, Section
8.4.2.1; p. 8–31), which provide strong
biological plausibility of Pb effects on
learning ability, memory and attention
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(CD, Section 5.3.5), as well as associated
mechanistic findings. With regard to
persistence of effects the Criteria
Document states the following (CD, p.
8–67):
Persistence or apparent ‘‘irreversibility’’ of
effects can result from two different
scenarios: (1) Organic damage has occurred
without adequate repair or compensatory
offsets, or (2) exposure somehow persists. As
Pb exposure can also derive from endogenous
sources (e.g., bone), a performance deficit
that remains detectable after external
exposure has ended, rather than indicating
irreversibility, could reflect ongoing toxicity
due to Pb remaining at the critical target
organ or Pb deposited at the organ postexposure as the result of redistribution of Pb
among body pools.
The persistence of effect appears to depend
on the duration of exposure as well as other
factors that may affect an individual’s ability
to recover from an insult. The likelihood of
reversibility also seems to be related, at least
for the adverse effects observed in certain
organ systems, to both the age-at-exposure
and the age-at-assessment.
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The evidence with regard to persistence
of Pb-induced deficits observed in
animal and epidemiological studies is
described in discussion of those studies
in the Criteria Document (CD, Sections
5.3.5, 6.2.11, and 8.5.2). It is
additionally important to note that there
may be long-term consequences of such
deficits over a lifetime. Poor academic
skills and achievement can have
‘‘enduring and important effects on
objective parameters of success in real
life,’’ as well as increased risk of
antisocial and delinquent behavior (CD,
Section 6.2.16).
As discussed in the Criteria
Document, while there is no direct
animal test parallel to human IQ tests,
‘‘in animals a wide variety of tests that
assess attention, learning, and memory
suggest that Pb exposure {of animals}
results in a global deficit in functioning,
just as it is indicated by decrements in
IQ scores in children’’ (CD, p. 8–27).
The animal and epidemiological
evidence for this endpoint are
consistent and complementary (CD, p.
8–44). As stated in the Criteria
Document (p. 8–44):
Findings from numerous experimental
studies of rats and of nonhuman primates, as
discussed in Chapter 5, parallel the observed
human neurocognitive deficits and the
processes responsible for them. Learning and
other higher order cognitive processes show
the greatest similarities in Pb-induced
deficits between humans and experimental
animals. Deficits in cognition are due to the
combined and overlapping effects of Pbinduced perseveration, inability to inhibit
responding, inability to adapt to changing
behavioral requirements, aversion to delays,
and distractibility. Higher level
neurocognitive functions are affected in both
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animals and humans at very low exposure
levels (<10 µg/dL), more so than simple
cognitive functions.
Epidemiologic studies of Pb and child
development have demonstrated inverse
associations between blood Pb
concentrations and children’s IQ and
other outcomes at successively lower Pb
exposure levels over the past 30 years
(CD, p. 6–64). This is supported by
multiple studies performed over the
past 15 years (see CD, Section 6.2.13);
‘‘the most compelling evidence for
effects at blood Pb levels <10 µg/dL
comes from an international pooled
analysis of seven prospective cohort
studies (n = 1,333) by Lanphear et al.
(2005)’’ (CD, p. 6–67 and sections 6.2.13
and 6.2.3.1.11). This pooled analysis
estimated a decline of 6.2 points in full
scale IQ (with a 95% confidence
interval bounded by 3.8 and 8.6)
occurring between approximately 1 and
10 µg/dL blood Pb level, measured
concurrent with the IQ test (CD, p. 6–
76). As discussed below in section III.B,
this analysis (Lanphear et al., 2005) was
relied upon in the quantitative risk
assessment.
3. Lead-Related Impacts on Public
Health
In addition to the advances in our
knowledge and understanding of Pb
health effects at lower exposures (e.g.,
using blood Pb as the index), there has
been some change with regard to the
U.S. population Pb burden since the
time of the last Pb NAAQS review. For
example, the geometric mean blood Pb
level for U.S. children aged 1–5, as
estimated by the U.S. Centers for
Disease Control, declined from 2.7 µg/
dL (95% CI: 2.5–3.0) in the 1991–1994
survey period to 1.7 µg/dL (95% CI:
1.55–1.87) in the 2001–2002 survey
period (CD, Section 4.3.1.3).18 Blood Pb
levels have also declined in the U.S.
adult population over this time period
(CD, Section 4.3.1.3).19 As noted in the
Criteria Document, ‘‘blood-Pb levels
have been declining at differential rates
for various general subpopulations, as a
function of income, race, and certain
18 These levels are in contrast to the geometric
mean blood Pb level of 14.9 µg/dL reported for U.S.
children (aged 6 months to 5 years) in 1976–1980
(CD, Section 4.3.1.3). Median and 90th percentile
values have also declined from 15 µg/dL and 25 µg/
dL, respectively, in 1976–1980, to 1.6 µg/dL and 3.9
µg/dL, respectively in 2003–04 (https://
www.epa.gov/envirohealth/children/body_burdens/
b1-table.htm).
19 For example, NHANES data for older adults (60
years of age and older) indicate a decline in overall
population geometric mean blood Pb level from 3.4
µg/dL in 1991–1994 to 2.2 µg/dL in 1999–2002; the
trend for adults between 20 and 60 years of age is
similar to that for children 1 to 5 years of age
(https://www.cdc.gov/mmwr/preview/mmwrhtml/
mm5420a5.htm).
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other demographic indicators such as
age of housing’’ (CD, p. 8–21).
a. At-Risk Subpopulations
Potentially at-risk subpopulations
include those with increased
susceptibility (i.e., physiological factors
contributing to a greater response for the
same exposure) and those with
increased exposure (including that
resulting from behavior leading to
increased contact with contaminated
media) (USEPA 1986a, p. 1–154). A
behavioral factor of great impact on Pb
exposure is the incidence of hand-tomouth activity that is prevalent in very
young children (CD, Section 4.4.3).
Physiological factors include both
conditions contributing to a subgroup’s
increased risk of effects at a given blood
Pb level, and those that contribute to
blood Pb levels higher than those
otherwise associated with a given Pb
exposure (CD, Section 8.5.3). We also
considered evidence pertaining to
vulnerability to pollution-related effects
which additionally encompasses
situations of elevated exposure, such as
residing in old housing with Pbcontaining paint or near sources of
ambient Pb, as well as socioeconomic
factors, such as reduced access to health
care or low socioeconomic status (SES)
(USEPA, 2003, 2005c) that can
contribute to increased risk of adverse
health effects from Pb.
Three particular physiological factors
contributing to increased risk of Pb
effects at a given blood Pb level are
recognized in the Criteria Document
(e.g., CD, Section 8.5.3): Age, health
status, and genetic composition. With
regard to age, the susceptibility of young
children to the neurodevelopmental
effects of Pb is well recognized (e.g., CD,
Sections 5.3, 6.2, 8.4, 8.5, 8.6.2),
although the specific ages of
vulnerability have not been established
(CD, pp. 6–60 to 6–64). Early childhood
may also be a time of increased
susceptibility for Pb immunotoxicity
(CD, Sections 5.9.10, 6.8.3 and 8.4.6).
Further early life exposures have been
associated with increased risk of
cardiovascular effects in humans later in
life (CD, p. 8–74). Early life exposures
have also been associated with
increased risk, in animals, of
neurodegenerative effects later in life
(CD, p. 8–74).20 Health status is another
20 Specifically, among young adults who lived as
children in an area heavily polluted by a smelter
and whose current Pb exposure was low, higher
bone Pb levels were associated with higher systolic
and diastolic blood pressure (CD, p. 8–74). In adult
rats, greater early exposures to Pb are associated
with increased levels of amyloid protein precursor,
a marker of risk for neurodegenerative disease (CD,
p. 8–74).
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physiological factor in that
subpopulations with pre-existing health
conditions may be more susceptible (as
compared to the general population) for
particular Pb-associated effects, with
this being most clear for renal and
cardiovascular outcomes. For example,
African Americans as a group, have a
higher frequency of hypertension than
the general population or other ethnic
groups (NCHS, 2005), and as a result
may face a greater risk of adverse health
impact from Pb-associated
cardiovascular effects. A third
physiological factor relates to genetic
polymorphisms. That is, subpopulations
defined by particular genetic
polymorphisms (e.g., presence of the daminolevulinic acid dehydratase-2
[ALAD–2] allele) have also been
recognized as sensitive to Pb toxicity,
which may be due to increased
susceptibility to the same internal dose
and/or to increased internal dose
associated with same exposure (CD, p.
8–71, Sections 6.3.5, 6.4.7.3 and 6.3.6).
While early childhood is recognized
as a time of increased susceptibility, a
difficulty in identifying a discrete
period of susceptibility from
epidemiological studies has been that
the period of peak exposure, reflected in
peak blood Pb levels, is around 18–27
months when hand-to-mouth activity is
at its maximal (CD, p. 6–60). The earlier
Pb literature described the first 3 years
of life as a critical window of
vulnerability to the neurodevelopmental
impacts of Pb (CD, p. 6–60). Recent
epidemiologic studies, however, have
indicated a potential for susceptibility
of children to concurrent Pb exposure
extending to school age (CD, pp. 6–60 to
6–64). The evidence indicates both the
sensitivity of the first 3 years of life, and
a sustained sensitivity throughout the
lifespan as the human central nervous
system continues to mature and be
vulnerable to neurotoxicants (CD,
Section 8.4.2.7). The animal evidence
helps inform an understanding of
specific periods of development with
increased vulnerability to specific types
of effect (CD, Section 5.3), and indicates
the potential importance of exposures of
duration on the order of months.
Evidence of a differing sensitivity of the
immune system to Pb across and within
different periods of life stages indicates
the potential importance of exposures of
duration as short as weeks to months.
For example, the animal studies suggest
that the gestation period is the most
sensitive life stage followed by early
neonatal stage, and that within these life
stages, critical windows of vulnerability
are likely to exist (CD, Section 5.9 and
p. 5–245).
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In summary, there are a variety of
ways in which Pb exposed populations
might be characterized and stratified for
consideration of public health impacts.
Age or lifestage was used to distinguish
potential groups on which to focus the
quantitative risk assessment because of
its influence on exposure and
susceptibility. Young children were
selected as the priority population for
the risk assessment in consideration of
the health effects evidence regarding
endpoints of greatest public health
concern. The Criteria Document
recognizes, however, other population
subgroups as described above may also
be at risk of Pb-related health effects of
public health concern.
b. Potential Public Health Impacts
As discussed in the Criteria
Document, there are potential public
health implications of low-level Pb
exposure, indexed by blood Pb levels,
associated with several health endpoints
identified in the Criteria Document (CD,
Section 8.6).21 These include potential
impacts on population IQ, which is the
focus of the quantitative risk assessment
conducted for this review, as well as
heart disease and chronic kidney
disease, which are not included in the
quantitative risk assessment (CD,
Sections 8.6, 8.6.2, 8.6.3 and 8.6.4). It is
noted that there is greater uncertainty
associated with effects at the lower
levels of blood Pb, and that there are
differing weights of evidence across the
effects observed.22 With regard to
potential implications of Pb effects on
IQ, the Criteria Document recognizes the
‘‘critical’’ distinction between
population and individual risk, noting
that a ‘‘point estimate indicating a
modest mean change on a health index
at the individual level can have
substantial implications at the
population level’’ (CD, p. 8–77).23 A
downward shift in the mean IQ value is
associated with both substantial
decreases in percentages achieving very
high scores and substantial increases in
the percentage of individuals achieving
21 The differing evidence and associated strength
of the evidence for these different effects is
described in detail in the Criteria Document.
22 As is described in Section III.B.2.a, CASAC, in
their comments on the analysis plan for the risk
assessment described in this notice, placed higher
priority on modeling the child IQ metric than the
adult endpoints (e.g., cardiovascular effects).
23 Similarly, ‘‘although an increase of a few
mmHg in blood pressure might not be of concern
for an individual’s well-being, the same increase in
the population mean might be associated with
substantial increases in the percentages of
individuals with values that are sufficiently
extreme that they exceed the criteria used to
diagnose hypertension’’ (CD, p. 8–77).
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very low scores (CD, p. 8–81).24 For an
individual functioning in the low IQ
range due to the influence of
developmental risk factors other than
Pb, a Pb-associated IQ decline of several
points might be sufficient to drop that
individual into the range associated
with increased risk of educational,
vocational, and social handicap (CD, p.
8–77).
The magnitude of a public health
impact is dependent upon the size of
population affected and type or severity
of the effect. As summarized above,
there are several population groups that
may be susceptible or vulnerable to
effects associated with exposure to Pb,
including young children, particularly
those in families of low SES (CD, p. E–
15), as well as individuals with
hypertension, diabetes, and chronic
renal insufficiency (CD, p. 8–72).
Although comprehensive estimates of
the size of these groups residing in
proximity to policy-relevant sources of
ambient Pb have not been developed,
total estimates of these population
subpopulations within the U.S. are
substantial (as noted in Table 3–3 of the
Staff Paper).25
With regard to estimates of the size of
potentially vulnerable subpopulations
living in areas of increased exposure
related to ambient Pb, the information is
still more limited. The limited
information available on air and surface
soil concentrations of Pb indicates
elevated concentrations near stationary
sources as compared with areas remote
from such sources (CD, Sections 3.2.2
and 3.8). Air quality analyses (presented
in Chapter 2 of the Staff Paper) indicate
dramatically higher Pb concentrations at
monitors near sources as compared with
those more remote. As described in
Section 2.3.2.1 of the Staff Paper,
however, since the 1980s the number of
Pb monitors has been significantly
reduced by states (with EPA guidance
that monitorings well below the current
NAAQS could be shut down) and a lack
of monitors near some large sources may
lead to underestimates of the extent of
occurrences of relatively higher Pb
concentrations. The significant
limitations of our monitoring and
emissions information constrain our
efforts to characterize the size of at-risk
populations in areas influenced by
24 For example, for a population mean IQ of 100
(and standard deviation of 15), 2.3% of the
population would score above 130, but a shift of the
population to a mean of 95 results in only 0.99%
of the population scoring above 130 (CD, pp. 8–81
to 8–82).
25 For example, approximately 4.8 million
children live in poverty, while the estimates of
numbers of adults with hypertension, diabetes or
chronic kidney disease are on the order of 20 to 50
million (see Table 3–3 of Staff Paper).
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policy-relevant sources of ambient Pb.
For example, the limited size and
spatial coverage of the current Pb
monitoring network constrains our
ability to characterize current levels of
airborne Pb in the U.S. Further, the
available information on emissions and
locations of sources indicates that the
network is inconsistent in its coverage
of the largest sources identified in the
2002 National Emissions Inventory
(NEI), with monitors within a mile of
only 2 of 26 facilities in the 2002 NEI
with emissions greater than 5 tons per
year (tpy). Additionally, there are
various uncertainties and limitations
associated with source information in
the NEI.
In recognition of the significant
limitations associated with the currently
available information on Pb emissions
and airborne concentrations in the U.S.
and the associated exposure of
potentially at-risk populations, Chapter
2 of the Staff Paper summarizes the
information in several different ways.
For example, analyses of the current
monitoring network indicated the
numbers of monitoring sites that would
exceed alternate standard levels, taking
into consideration different statistical
forms. These analyses are also
summarized with regard to population
size in counties home to those
monitoring sites (see Appendix 5.A of
the Staff Paper). Information for the
monitors and from the NEI indicates a
range of source sizes in proximity to
monitors at which various levels of Pb
are reported. Together this information
suggests that there is variety in the
magnitude of Pb emissions from sources
that could influence air Pb
concentrations. Identifying specific
emissions levels of sources expected to
result in air Pb concentrations of
interest, however, would be informed by
a comprehensive analysis using detailed
source characterization information that
was not feasible within the time and
data constraints of this review. Instead,
we have developed a summary of the
emissions and demographic information
for Pb sources that includes estimates of
the numbers of people residing in
counties in which the aggregate Pb
emissions from NEI sources is greater
than or equal to 0.1 tpy or in counties
in which the aggregate Pb emissions is
greater than or equal to 0.1 tpy per 1000
square miles (see Tables 3–4 and 3–5,
respectively, in the Staff Paper).
Additionally, the potential for
historically deposited Pb near roadways
to contribute to increased risks of Pb
exposure and associated risk to
populations residing nearby is suggested
in the Criteria Document. Although
estimates of the number of individuals,
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including children, living within close
proximity to roadways specifically
recognized for this potential have not
been developed, these numbers may be
substantial. 26
4. Key Observations
The following key observations are
based on the available health effects
evidence and the evaluation and
interpretation of that evidence in the
Criteria Document.
• Lead exposures occur both by
inhalation and by ingestion (CD,
Chapter 3). As stated in the Criteria
Document, ‘‘given the large amount of
time people spend indoors, exposure to
Pb in dusts and indoor air can be
significant’’ (CD, p. 3–27).
• Children, in general and especially
low SES children, are at increased risk
for Pb exposure and Pb-induced adverse
health effects. This is due to several
factors, including enhanced exposure to
Pb via ingestion of soil Pb and/or dust
Pb due to normal childhood hand-tomouth activity (CD, p. E–15, Chapter 3
and Section 6.2.1).
• Once inhaled or ingested, Pb is
distributed by the blood, with long-term
storage accumulation in the bone. Bone
Pb levels provide a strong measure of
cumulative exposure which has been
associated with many of the effects
summarized below, although difficulty
of sample collection has precluded
widespread use in epidemiological
studies to date (CD, Chapter 4).
• Blood levels of Pb are well accepted
as an index of exposure (or exposure
metric) for which associations with the
key effects (see below) have been
observed. In general, associations with
blood Pb are most robust for those
effects for which past exposure history
poses less of a complicating factor, i.e.,
for effects during childhood (CD,
Section 4.3).
• Both epidemiological and
toxicologic studies have shown that
environmentally relevant levels of Pb
affect many different organ systems (CD,
p. E–8). Many associations of health
effects with Pb exposure have been
found at levels of blood Pb that are
currently relevant for the U.S.
population, with children having blood
26 For
example, the 2005 American Housing
Survey, conducted by the U.S. Census Bureau
indicates that some 14 million (or approximately
13% of) housing units are ‘‘within 300 feet of a 4or-more-lane roadway, railroad or airport’’ (U.S.
Census Bureau, 2006). Additionally, estimates
developed for Colorado, Georgia and New York
indicate that approximately 15–30% of the
populations in those states reside within 75 meters
of a major roadway (i.e., a ‘‘Limited Access
Highway’’, ‘‘Highway’’, ‘‘Major Road’’ or ‘‘Ramp’’,
as defined by the U.S. Census Feature Class Codes)
(ICF, 2005).
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Pb levels of 5–10 µg/dL, or, perhaps
somewhat lower, being at notable risk
for neurological effects (see subsequent
bullet). Supportive evidence from
toxicological studies provides biological
plausibility for the observed effects.
(CD, Chapters 5, 6 and 8)
• Pb exposure is associated with a
variety of neurological effects in
children, notably intellectual attainment
and school performance. Both
qualitative and quantitative evidence,
with further support from animal
research, indicates a robust and
consistent effect of Pb exposure on
neurocognitive ability at mean
concurrent blood Pb levels in the range
of 5 to 10 µg/dL. A recent analysis of a
nationally representative U.S. sample
suggested Pb effects on intellectual
attainment of young children at
population mean concurrent blood Pb
levels ranging down to as low as 2 µg/
dL. (CD, Sections 5.3, 6.2, 8.4.2 and
6.10)
• Deficits in cognitive skills may have
long-term consequences over a lifetime.
Poor academic skills and achievement
can have enduring and important effects
on objective parameters of success in
real life as well as increased risk of
antisocial and delinquent behavior. (CD,
Sections 6.1 and 8.4.2)
• For the quantitative risk assessment
for neurocognitive ability in young
children (described in Chapter 4 of the
Staff Paper), the Staff Paper chose to use
nonlinear concentration-response
models that reflect the epidemiological
evidence of a higher slope of the blood
Pb concentration-response relationship
at lower blood Pb levels, particularly
below 10 µg/dL (CD, Sections 6.2.13 and
8.6).
• At mean blood Pb levels, in
children, on the order of 10 µg/dL, and
somewhat lower, associations have been
found with effects to the immune
system, including altered macrophage
activation, increased IgE levels and
associated increased risk for
autoimmunity and asthma (CD, Sections
5.9, 6.8, and 8.4.6).
• In adults, with regard to
cardiovascular outcomes, the Criteria
Document included the following
summary (CD, p. E–10).
Epidemiological studies have consistently
demonstrated associations between Pb
exposure and enhanced risk of deleterious
cardiovascular outcomes, including
increased blood pressure and incidence of
hypertension. 27 A meta-analysis of
27 The Criteria Document states that ‘‘While
several studies have demonstrated a positive
correlation between blood pressure and blood Pb
concentration, others have failed to show such
association when controlling for confounding
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numerous studies estimates that a doubling
of blood-Pb level (e.g., from 5 to 10 µg/dL)
is associated with ∼1.0 mm Hg increase in
systolic blood pressure and ∼0.6 mm Hg
increase in diastolic pressure. Studies have
also found that cumulative past Pb exposure
(e.g., bone Pb) may be as important, if not
more, than present Pb exposure in assessing
cardiovascular effects. The evidence for an
association of Pb with cardiovascular
morbidity and mortality is limited but
supportive.
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Studies of nationally representative U.S.
samples observed associations between
blood Pb levels and increased systolic
blood pressure at population mean
blood lead levels less than 5 µg/dL,
particularly among African Americans
(CD, Section 6.5.2). With regard to
gender differences, the Criteria
Document states the following (CD, p.
6–154).
Although females often show lower
Pb coefficients than males, and Blacks
higher Pb coefficients than Whites,
where these differences have been
formally tested, they are usually not
statistically significant. The tendencies
may well arise in the differential Pb
exposure in these strata, lower in
women than in men, higher in Blacks
than in Whites. The same sex and race
differential is found with blood
pressure.
Animal evidence provides confirmation
of Pb effects on cardiovascular
functions. (CD, Sections 5.5, 6.5, 8.4.3
and 8.6.3)
• Renal effects, evidenced by reduced
renal filtration, have also been
associated with Pb exposures indexed
by bone Pb levels and also with mean
blood Pb levels in the range of 5 to 10
µg/dL in the general adult population,
with the potential adverse impact of
such effects being enhanced for
susceptible subpopulations including
those with diabetes, hypertension, and
chronic renal insufficiency (CD,
factors such as tobacco smoking, exercise, body
weight, alcohol consumption, and socioeconomic
status. Thus, the studies that have employed blood
Pb level as an index of exposure have shown a
relatively weak association with blood pressure. In
contrast, the majority of the more recent studies
employing bone Pb level have found a strong
association between long-term Pb exposure and
arterial pressure (Chapter 6). Since the residence
time of Pb in the blood is relatively short but very
long in the bone, the latter observations have
provided rather compelling evidence for a positive
relationship between Pb exposure and a subsequent
rise in arterial pressure’’ (CD, pp. 5–102 to 5–103).
Further, in consideration of the meta-analysis also
described here, the Criteria Document stated that
‘‘The meta-analysis provides strong evidence for an
association between increased blood Pb and
increased blood pressure over a wide range of
populations’’ (CD, p. 6–130) and ‘‘the meta-analyses
results suggest that studies not detecting an effect
may be due to small sample sizes or other factors
affecting precision of estimation of the exposure
effect relationship’’ (CD, p. 6–133).
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Sections 6.4, 8.4.5, and 8.6.4). The full
significance of this effect is unclear,
given that other evidence of more
marked signs of renal dysfunction have
not been detected at blood Pb levels
below 30–40 µg/dL in large studies of
occupationally-exposed Pb workers (CD,
pp. 6–270 and 8–50). 28
• Other Pb associated effects in adults
occurring at or just above 10 µg/dL
include hematological (e.g., impact on
heme synthesis pathway) and
neurological effects, with animal
evidence providing support of Pb effects
on these systems and evidence
regarding mechanism of action. (CD,
Sections 5.2, 5.3, 6.3 and 6.9.2)
B. Human Exposure and Health Risk
Assessments
This section presents a brief summary
of the human exposure and health risk
assessments conducted by EPA for this
review. The complete full-scale
assessment, which includes specific
analyses conducted to address CASAC
comments and advice on an earlier draft
assessment, is presented in the final
Risk Assessment Report (USEPA,
2007b).
The focus of this Pb NAAQS risk
assessment is on Pb derived from those
sources emitting Pb to ambient air. The
design and implementation of this
assessment needed to address
significant limitations and complexity
that go far beyond the situation for
similar assessments typically performed
for other criteria pollutants. Not only
was the risk assessment constrained by
the timeframe allowed for this review in
the context of breadth of information to
address, it was also constrained by
significant limitations in data and
modeling tools for the assessment.
Furthermore, the multimedia and
persistent nature of Pb, and the role of
multiple exposure pathways, add
significant complexity to the assessment
as compared to other assessments that
focus only on the inhalation pathway.
28 In the general population, both cumulative and
circulating Pb has been found to be associated with
longitudinal decline in renal functions. In the large
NHANES III study, alterations in urinary creatinine
excretion rate (one indicator of possible renal
dysfunction) was observed in hypertensives at a
mean blood Pb of only 4.2 µg/dL. These results
provide suggestive evidence that the kidney may
well be a target organ for effects from Pb in adults
at current U.S. environmental exposure levels. The
magnitude of the effect of Pb on renal function
ranged from 0.2 to ¥1.8 mL/min change in
creatinine clearance per 1.0 µg/dL increase in blood
Pb in general population studies. However, the full
significance of this effect is unclear, given that other
evidence of more marked signs of renal dysfunction
have not been detected at blood Pb levels below 30–
40 µg/dL among thousands of occupationallyexposed Pb workers that have been studied. (CD, p.
6–270)
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Due to the limited data, models, and
time available, the risk assessment
could not fully incorporate all of the
important complexities associated with
Pb. Consequently, in characterizing risk
associated with the ambient airrelated 29 (policy-relevant) sources and
exposures, simplifying assumptions
were made in several areas. For
example, people are also exposed to Pb
that originates from nonair sources,
including leaded paint or drinking
water distribution systems. For this
assessment, the Pb from these nonair
sources is collectively referred to as
‘‘policy-relevant background.’’ 30 31
Although deposition of airborne Pb is a
major source of Pb in food (CD, p. 3–54)
and may also contribute to Pb in
drinking water, the contribution from
air pathways to these nonair exposure
pathways could not be explicitly
modeled, and these contributions are
treated as though they were part of the
policy-relevant background. 32 This
means that some benefits associated
with emissions reductions are excluded
to the extent that reduced air emissions
will eventually mean less Pb in water
and food.
An overview of the human health risk
assessment completed in the last review
of the Pb NAAQS in 1990 (USEPA,
1990a) is presented first below, followed
29 Ambient air related sources are those emitting
Pb into the ambient air (including resuspension of
previously emitted Pb, that may include Pb paint
from older buildings which has weathered and
impacted outdoor soil with subsequent
resuspension), and ambient air related exposures
include inhalation of ambient air Pb as well as
ingestion of Pb deposited out of the air (e.g., onto
outdoor soil/dust or indoor dust).
30 This categorization of policy-relevant sources
and background exposures is not intended to
convey any particular policy decision at this stage
regarding the Pb standard. Rather, it is simply
intended to define the focus of this analysis.
31 In the context of NAAQS for other criteria
pollutants which are not multimedia in nature,
such as ozone, the term policy-relevant background
is used to distinguish anthropogenic air emissions
from naturally occurring non-anthropogenic
emissions to separate pollution levels that can be
controlled by U.S. regulations from levels that are
generally uncontrollable by the United States
(USEPA, 2007d). In the case of Pb, however, due
to the multimedia, multipathway nature of human
exposures to Pb, policy-relevant background is
defined more broadly to include not only the ‘‘quite
low’’ levels of naturally occurring Pb emissions into
the air from non-anthropogenic sources such as
volcanoes, sea salt, and windborne soil particles
from areas free of anthropogenic activity, but also
Pb from nonair sources, generally including leaded
paint or drinking water distribution systems, which
are collectively referred to in the risk assessment
described here as ‘‘policy-relevant background’’
(USEPA, 2007b, p. 2–28, p. 1–3).
32 Furthermore, although Pb from indoor paint is
considered a component of policy-relevant
background, for this analysis, it may be reflected
somewhat in estimates developed for policyrelevant sources due to modeling constraints (see
USEPA, 2007b).
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by a summary of key aspects of the
approach used in this assessment,
including key limitations and
uncertainties. The key assessment
results are then summarized.
1. Overview of Risk Assessment From
Last Review
The risk assessment conducted in
support of the last review used a case
study approach to compare air quality
scenarios in terms of their impact on the
percentage of modeled populations that
exceeded specific blood Pb levels
chosen with consideration of the health
effects evidence at that time (USEPA,
1990b; USEPA, 1989). The case studies
in that analysis, however, focused
exclusively on Pb smelters including
two secondary and one primary smelter
and did not consider exposures in a
more general urban context.
Additionally, the analysis focused on
children (birth through 7 years of age)
and middle-aged men. The assessment
evaluated impacts of alternate NAAQS
on numbers of children and men with
blood Pb levels above levels of concern
based on health effects evidence at that
time. The primary difference between
the risk assessment approach used in
the current analysis and the assessment
completed in 1990 involves the risk
metric employed. Rather than
estimating the percentage of study
populations with exposures above blood
Pb levels of interest as was done in the
last review (i.e., 10, 12 and 15 µg/dL),
the current analysis estimates changes
in health risk, specifically IQ loss,
associated with Pb exposure for child
populations at each of the case study
locations with that IQ loss further
differentiated between background Pb
exposure and policy-relevant exposures.
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2. Design Aspects of Exposure and Risk
Assessments
This section provides an overview of
key elements of the assessment design,
inputs, and methods, and includes
identification of key uncertainties and
limitations.
a. CASAC Advice
The CASAC conducted a consultation
on the draft analysis plan for the risk
assessment (USEPA, 2006c) in June,
2006 (Henderson, 2006). Some key
comments provided by CASAC
members on the plan included: (1)
Placing a higher priority on modeling
the child IQ metric than the adult
endpoints (e.g., cardiovascular effects),
(2) recognizing the importance of indoor
dust loading by Pb contained in outdoor
air as a factor in Pb-related exposure
and risk for sources considered in this
analysis, and (3) concurring with use of
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the IEUBK biokinetic blood Pb model.
Taking these comments into account, a
pilot phase assessment was conducted
to test the risk assessment methodology
being developed for the subsequent fullscale assessment. The pilot phase
assessment is described in the first draft
Staff Paper and accompanying technical
report (ICF 2006), which was discussed
by the CASAC Pb panel on February 6–
7 (Henderson, 2007a).
Results from the pilot assessment,
together with comments received from
CASAC and the public, informed the
design of the full-scale analysis. The
full-scale analysis included a
substitution of a more generalized urban
case study for the location-specific nearroadway case study evaluated in the
pilot. In addition, a number of changes
were made in the exposure and risk
assessment approaches, including the
development of a new indoor dust Pb
model focused specifically on urban
residential locations and specification of
additional IQ loss concentrationresponse (C–R) functions to provide
greater coverage for potential impacts at
lower exposure levels.
The draft full-scale assessment was
presented in the July 2007 draft risk
assessment report (USEPA, 2007a) that
was released for public comment and
provided to CASAC for review. In their
review of the July draft risk assessment
report, the CASAC Pb Panel made
several recommendations for additional
exposure and health risk analyses
(Henderson, 2007b). These included a
recommendation that the general urban
case study be augmented by the
inclusion of risk analyses in specific
urban areas of the U.S. In this regard,
they specifically stated the following
(Henderson, 2007b, p. 3).
* * * the CASAC strongly believes that it
is important that EPA staff make estimates of
exposure that will have national implications
for, and relevance to, urban areas; and that,
significantly, the case studies of both primary
lead (Pb) smelter sites as well as secondary
smelter sites, while relevant to a few atypical
locations, do not meet the needs of
supporting a Lead NAAQS. The Agency
should also undertake case studies of several
urban areas with varying lead exposure
concentrations, based on the prototypic
urban risk assessment that OAQPS produced
in the 2nd Draft Lead Human Exposure and
Health Risk Assessments. In order to estimate
the magnitude of risk, the Agency should
estimate exposures and convert these
exposures to estimates of blood levels and IQ
loss for children living in specific urban
areas.
Hence, EPA included additional case
studies in the risk assessment. Further,
CASAC recommended using a
concentration-response function with a
change in slope near 7.5 µg/dL.
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Accordingly, EPA included such an
additional concentration-response
function in the risk assessment. Results
from the initial full-scale analyses, along
with comments from CASAC, such as
those described here, and the public
resulted in a final version of the fullscale assessments which is summarized
in this notice and presented in greater
detail in the Risk Assessment Report
and associated appendices (USEPA,
2007b). While these additional analyses
were developed in response to CASAC
recommendations, there has not been
review of the completed analyses by
CASAC.
b. Health Endpoint, Risk Metric and
Concentration-Response Functions
The health endpoint on which the
quantitative health risk assessment
focuses is developmental neurotoxicity
in children, with IQ decrement as the
risk metric. Among the wide variety of
health endpoints associated with Pb
exposures, there is general consensus
that the developing nervous system in
young children is the most sensitive and
that neurobehavioral effects (specifically
neurocognitive deficits), including IQ
decrements, appear to occur at lower
blood levels than previously believed
(i.e., at levels <10 µg/dL). For example,
the overall weight of the available
evidence, described in the Criteria
Document, provides clear substantiation
of neurocognitive decrements being
associated in young children with blood
Pb levels in the range of 5 to 10 µg/dL,
and some analyses indicate Pb effects on
intellectual attainment of young
children ranging from 2 to 8 µg/dL (CD,
Sections 6.2, 8.4.2, and 8.4.2.6). That is,
while blood Pb levels in U.S. children
ages one to five years have decreased
notably since the late 1970s, newer
studies have investigated and reported
associations of effects on the
neurodevelopment of children with
these more recent blood Pb levels (CD,
Chapter 6).
The evidence for neurotoxic effects in
children is a robust combination of
epidemiological and toxicological
evidence (CD, Sections 5.3, 6.2, and
8.5). The epidemiological evidence is
supported by animal studies that
substantiate the biological plausibility
of the associations, and provides an
understanding of mechanisms of action
for the effects (CD, Section 8.4.2). The
selection of children’s IQ for the
quantitative risk assessment reflects
consideration of the evidence presented
in the Criteria Document as well as
advice received from CASAC
(Henderson, 2006, 2007a).
The epidemiological studies that have
investigated blood Pb effects on IQ (see
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CD, Section 6.2.3) have considered a
variety of specific blood Pb metrics,
including: (1) Blood concentration
‘‘concurrent’’ with the response
assessment (e.g., at the time of IQ
testing), (2) average blood concentration
over the ‘‘lifetime’’ of the child at the
time of response assessment (e.g.,
average of measurements taken over
child’s first 6 or 7 years), (3) peak blood
concentration during a particular age
range, and (4) early childhood blood
concentration (e.g., the mean of
measurements between 6 and 24 months
age). All four specific blood Pb metrics
have been correlated with IQ (see CD, p.
6–62; Lanphear et al., 2005). In the
international pooled analysis by
Lanphear and others (2005), however,
the concurrent and lifetime averaged
measurements were considered
‘‘stronger predictors of lead-associated
intellectual deficits than was maximal
measured (peak) or early childhood
blood lead concentrations,’’ with the
concurrent blood Pb level exhibiting the
strongest relationship (CD, p. 6–29). It is
not clear in this case, or for similar
findings in other studies, whether the
cognitive deficits observed were due to
Pb exposure that occurred during early
childhood or were a function of
concurrent exposure. Nevertheless,
concurrent blood Pb levels likely
reflected both ongoing exposure and
preexisting body burden (CD, p. 6–32).
Given the evidence described in detail
in the Criteria Document (Chapters 6
and 8), and in consideration of CASAC
recommendations (Henderson, 2006,
2007a, 2007b), the risk assessment for
this review relies on the functions
presented by Lanphear and others
(2005) that relate absolute IQ as a
function of concurrent blood Pb or of
the log of concurrent blood Pb, and
lifetime average blood Pb, respectively.
As discussed in the Criteria Document
(CD, p. 8–63 to 8–64), the slope of the
concentration-response relationship
described by these functions is greater at
the lower blood Pb levels (e.g., less than
10 µg/dL). As discussed in the Criteria
Document, threshold blood Pb levels for
these effects cannot be discerned from
the currently available epidemiological
studies, and the evidence in the animal
Pb neurotoxicity literature does not
define a threshold for any of the toxic
mechanisms of Pb (CD, Sections 5.3.7
and 6.2).
In applying relationships observed
with the pooled analysis (Lanphear et
al., 2005) to the risk assessment, which
includes blood Pb levels below the
range represented by the pooled
analysis, several alternative blood Pb
concentration-response models were
considered in recognition of a reduced
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confidence in our ability to characterize
the quantitative blood Pb concentrationresponse relationship at the lowest
blood Pb levels represented in the
recent epidemiological studies. The
functions considered and employed in
the initial risk analyses for this review
include the following.
• Log-linear function with lowexposure linearization, for both
concurrent and lifetime average blood
metrics, applies the nonlinear
relationship down to the blood Pb
concentration representing the lower
bound of blood Pb levels for that blood
metric in the pooled analysis and
applies the slope of the tangent at that
point to blood Pb concentrations
estimated in the risk assessment to fall
below that level.
• Log-linear function with cutpoint,
for both concurrent and lifetime average
blood metrics, also applies the
nonlinear relationship at blood Pb
concentrations above the lower bound
of blood Pb concentrations in the pooled
analysis dataset for that blood metric,
but then applies zero risk to all lower
blood Pb concentrations estimated in
the risk assessment.
In the additional risk analyses
performed subsequent to the August
2007 CASAC public meeting, the two
functions listed above and the following
two functions were employed (see
Section 5.3.1 of the Risk Assessment
Report for details on the forms of these
functions as applied in this risk
assessment).
• Population stratified dual linear
function for concurrent blood Pb,
derived from the pooled dataset
stratified at peak blood Pb of 10 µg/dL
and
• Population stratified dual linear
function for concurrent blood Pb,
derived from the pooled dataset
stratified at 7.5 µg/dL peak blood Pb.
In interpreting risk estimates derived
using the various functions,
consideration should be given to the
uncertainties with regard to the
precision of the coefficients used for
each analysis. The coefficients for the
log-linear model from Lanphear et al.
(2005) had undergone a careful
development process, including
sensitivity analyses, using all available
data from 1,333 children. The shape of
the exposure-response relationship was
first assessed through tests of linearity,
then by evaluating the restricted cubic
spline model. After determining that the
log-linear model provided a good fit to
the data, covariates to adjust for
potential confounding were included in
the log-linear model with careful
consideration of the stability of the
parameter estimates. After the multiple
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regression models were developed,
regression diagnostics were employed to
ascertain whether the Pb coefficients
were affected by collinearity or
influential observations. To further
investigate the stability of the model, a
random-effects model (with sites
random) was applied to evaluate the
results and also the effect of omitting
one of the seven cohorts on the Pb
coefficient. In the various sensitivity
analyses performed, the coefficient from
the log-linear model was found to be
robust and stable. The log-linear model,
however, is not biologically plausible at
very low blood Pb concentrations as
they approach zero; therefore, in the
first two functions the log-linear model
is applied down to a cutpoint (of 1 µg/
dL for the concurrent blood Pb metric),
selected based on the low end of the
blood Pb levels in the pooled dataset,
followed by a linearization or an
assumption of zero risk at levels below
that point.
In contrast, the coefficients from the
two analyses using the population
stratified dual linear function with
stratification at 7.5 µg/dL and 10 µg/dL,
peak blood Pb, have not undergone such
careful development. These analyses
were primarily done to compare the
lead-associated decrement at lower
blood Pb concentrations and higher
blood Pb concentrations. For these
analyses, the study population was
stratified at the specified peak blood Pb
level and separate linear models were
fitted to the concurrent blood Pb data
for the children in the two study
population subgroups. The fit of the
model or sensitivity analyses were not
conducted (or reported) on these
coefficients. While these analyses are
quite suitable for the purpose of
investigating whether the slope at lower
concentration levels are greater
compared to higher concentration
levels, use of such coefficients in a risk
analysis to assess public health impact
may be inappropriate. Further, only 103
children had maximal blood Pb levels
less than 7.5 µg/dL and 244 children
had maximal blood Pb levels less than
10 µg/dL. While these children may
better represent current blood Pb levels,
not fitting a single model using all
available data may lead to bias. Slob et
al. (2005) noted that the usual argument
for not considering data from the high
dose range is that different biological
mechanisms may play a role at higher
doses compared to lower doses.
However, this does not mean a single
curve across the entire exposure range
cannot describe the relationship. The
fitted curve merely assumes that the
underlying dose-response follows a
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smooth curve over the whole dose
range. If biological mechanisms change
when going from lower to higher doses,
this change will result in a gradually
changing slope of the dose-response.
The major strength of the Lanphear et al.
(2005) study was the large sample size
and the pooled analysis of data from
seven different cohorts. In the case of
the study population subgroup with
peak blood Pb below 7.5 µg/dL, less
than 10% of the available data is used
in the analysis, with more than half of
the data coming from one cohort
(Rochester) and the six other cohorts
contributing zero to 13 children to the
analysis. Such an analysis dissipates the
strength of the Lanphear et al. study.
In consideration of the preceding
discussion, greater confidence is placed
in the log-linear model form compared
to the dual-linear stratified models for
purposes of the risk assessment
described in this notice. Further, in
considering risk estimates derived from
the four core functions (log-linear
function with low-exposure
linearization, log-linear function with
cutpoint, dual linear function, stratified
at 7.5 µg/dL peak blood Pb, and dual
linear function, stratified at 10 µg/dL
peak blood Pb), greatest confidence is
assigned to risk estimates derived using
the log-linear function with lowexposure linearization since this
function (a) is a nonlinear function that
describes greater response per unit
blood Pb at lower blood Pb levels
consistent with multiple studies
identified in the discussion above, (b) is
based on fitting a function to the entire
pooled dataset (and hence uses all of the
data in describing response across the
range of exposures), (c) is supported by
sensitivity analyses showing the model
coefficients to be robust, and (d)
provides an approach for predicting IQ
loss at the lowest exposures simulated
in the assessment (consistent with the
lack of evidence for a threshold). Note,
however, that risk estimates generated
using the other three concentrationresponse functions are also presented to
provide perspective on the impact of
uncertainty in this key modeling step.
c. Case Study Approach
For the risk assessment described in
this notice, a case study approach was
employed as described in Sections 2.2
(and subsections) and 5.1.3 of the Risk
Assessment Report (USEPA, 2007b).
The four types of case studies included
in the assessment are the following:
• Location-specific urban case
studies: Three urban case studies focus
on specific urban areas (Cleveland,
Chicago and Los Angeles) to provide
perspectives on the magnitude of
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ambient air Pb-related risk in specific
urban locations. Ambient air Pb
concentrations are characterized using
source-oriented and other Pb-TSP
monitors in these cities. As stated
above, these case studies were
developed in response to CASAC
recommendations and there has not
been review of the completed analyses
for these case studies by CASAC
• General urban case study: The
general urban case study is a
nonlocation-specific analysis that uses
several simplifying assumptions
regarding ambient air Pb levels and
demographics to produce a simplified
representation of urban areas.
• Primary Pb smelter case study: 33
This case study estimates risk for
children living in an area currently not
in attainment with the current NAAQS,
that is impacted by Pb emissions from
a primary Pb smelter. As such, this case
study characterizes risk for a specific
highly exposed population and also
provides insights on risk to child
populations living in areas near large
sources of Pb emissions.
• Secondary Pb smelter case study: 34
This case study was included in the
initial analyses for the full-scale
assessment as an example of areas
influenced by smaller point sources of
Pb emissions. As discussed in Section
III.B.2.g below, however, a variety of
significant limitations in the approaches
employed for this case and associated
large uncertainties in these results are
recognized that preclude considering
this case study to be illustrative of the
larger set of areas influenced by
similarly sized Pb sources. Risk
estimates for this case study (presented
in detail in the Risk Assessment Report
(USEPA, 2007b)) are lower than those
for the other case studies.
quarterly averaging time.35 The current
NAAQS scenario for the urban case
studies assumes ambient air Pb
concentrations higher than actual
current conditions. While it is extremely
unlikely that Pb concentrations in urban
areas would rise to meet the current
NAAQS and there are limitations and
uncertainties associated with the
approach used (as described in Section
III.B.2.g below), this scenario was
included to provide some perspective
on risks associated with just meeting the
current NAAQS relative to current
conditions. When evaluating these
results it is important to keep the
limitations and uncertainties in mind.
Current conditions for the three
location-specific urban case studies in
terms of maximum quarterly average air
Pb concentrations are 0.09, 0.14 and
0.36 µg/m3 for the study areas in Los
Angeles, Chicago and Cleveland,
respectively. In terms of maximum
monthly average the values are 0.17 µg/
m3, 0.31 µg/m3 and 0.56 µg/m3 for the
study areas in Los Angeles, Chicago and
Cleveland, respectively. Two current
conditions scenarios were considered
for the general urban case study: One
based on the mean value for ambient air
Pb levels in large urban areas (0.14 µg/
m3 as a maximum quarterly average)
and a high-end ambient air Pb level in
large urban areas (0.87 µg/m3 as a
maximum quarterly average).
Details of the assessment scenarios,
including a description of the derivation
of Pb concentrations for air and other
media are presented in Sections 2.3 (and
subsections) and Section 5.1.1 of the
Risk Assessment Report (USEPA,
2007b).
d. Air Quality Scenarios
Air quality scenarios assessed include
(a) a current conditions scenario for the
location-specific urban case studies, the
general urban case study and the
secondary Pb smelter case study, (b) a
current NAAQS scenario for the
location-specific urban case studies, the
general urban case study and the
primary Pb smelter case study, and (c)
a range of alternative NAAQS scenarios
for all case studies. The alternative
NAAQS scenarios include levels of 0.5,
0.2, 0.05, and 0.02 µg/m3, with a
monthly averaging time, as well as a
level of 0.2 µg/m3 scenario using a
To inform policy aspects of the Pb
NAAQS review, the assessment
estimates for blood Pb and IQ loss were
divided into two components: The
fraction associated with policy-relevant
pathways, which include inhalation,
outdoor soil/dust ingestion and indoor
dust ingestion, and the fraction
associated with background (e.g., diet
and drinking water). The policy-relevant
pathways are further divided into two
categories, ‘‘recent air’’ and ‘‘past air’’.
Conceptually, the recent air category
includes those pathways involving Pb
that is or has recently been in the
outdoor ambient air, including
inhalation and ingestion of indoor dust
Pb derived from recent ambient air (i.e.,
33 See Section III.B.2.a for a summary of CASAC’s
comment with regard to the primary and secondary
Pb smelter case studies.
34 See Section III.B.2.a for a summary of CASAC’s
comment with regard to the primary and secondary
Pb smelter case studies.
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e. Categorization of Policy-Relevant
Exposure Pathways
35 For further discussion of the air quality
scenarios and averaging times included in the risk
assessment, see section 2.3.1 of the Risk Assessment
Report (USEPA, 2007b)
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air Pb that has penetrated into the
residence recently and loaded indoor
dust). Past air includes exposure
contributions from ingestion of outdoor
soil/dust that is contacted on surfaces
outdoors, and ingestion of indoor dust
Pb that is derived from past air sources
(i.e., impacts from Pb that was in the
ambient air in the past and has not been
recently resuspended into ambient air).
In this assessment, as discussed further
below, that portion of indoor dust Pb
not associated with recent air, is
classified as ‘‘other’’ and, due to
technical limitations includes not only
past air impacts, but also contributions
from indoor Pb paint. In the risk
assessment, estimates of contribution to
blood Pb and IQ loss were developed for
the following pathways or pathway
combinations:
• Inhalation of ambient air Pb (i.e.,
‘‘recent air’’ Pb): This is derived using
the blood Pb estimate resulting from Pb
exposure limited to the inhalation
pathway (and will include exposures to
Pb in ambient air from all sources
contributing to the ambient air
concentration estimate).
• Ingestion of ‘‘recent air’’ indoor
dust Pb: This is derived using the blood
Pb estimate resulting from Pb exposure
limited to ingestion of the Pb in indoor
dust that is predicted to be associated
with ambient air concentrations (i.e., via
the air concentration coefficient in the
regression-based dust models or via the
mechanistic component of the hybrid
blood Pb model (see Section 3.1.4 of the
Risk Assessment Report). For the
primary Pb smelter case study, estimates
for this pathway are not separated from
estimates for the pathway described in
the subsequent bullet due to uncertainty
regarding this categorization with the
model used for this case study (Section
3.1.4.2 of the Risk Assessment Report).
• Ingestion of ‘‘other’’ indoor dust Pb:
This is derived using the blood Pb
estimate resulting from Pb exposure
limited to ingestion of the Pb in indoor
dust that is not predicted to be
associated with ambient air
concentrations (i.e., that predicted by
the intercept in the dust models plus
that predicted by the outdoor soil
concentration coefficient, for models
that include an intercept (Section 3.1.4
of the Risk Assessment Report)). This is
interpreted to represent indoor paint,
outdoor soil/dust, and additional
sources of Pb to indoor dust including
historical air (see Risk Assessment
Report, Section 2.4.3). As the intercept
in regression dust models will be
inclusive of error associated with the
model coefficients, this category also
includes some representation of dust Pb
associated with current ambient air
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concentrations (described in previous
bullet). For the primary Pb smelter case
study, estimates for this pathway are not
separated from estimates for the
pathway described above due to
uncertainty regarding this categorization
with the model used for this case study
(Risk Assessment Report, Section
3.1.4.2). This pathway is included in the
‘‘past air’’ category.
• Ingestion of outdoor soil/dust Pb:
This is derived using the blood Pb
estimate resulting from Pb exposure
limited to ingestion of outdoor soil/dust
Pb. This pathway is included in the
‘‘past air’’ category (and could include
contamination from historic Pb
emissions from automobiles and Pb
paint).
• Ingestion of drinking water Pb: This
is derived using the blood Pb estimate
resulting from Pb exposure limited to
ingestion of drinking water Pb. This
pathway is included in the policyrelevant background category.
• Ingestion of dietary Pb: This is
derived using the blood Pb estimate
resulting from Pb exposure limited to
ingestion of dietary Pb. This pathway is
included in the policy-relevant
background category.
In simulating reductions in exposure
associated with reducing ambient air Pb
levels through alternative NAAQS (and
increases in exposure if the current
NAAQS was reached in certain case
studies), modeling for the assessment
has only affected the exposure pathways
categorized as recent air (inhalation and
ingestion of that portion of indoor dust
associated with outdoor ambient air).
The assessment has not simulated
decreases in past air-related exposure
pathways (e.g., reductions in outdoor
soil Pb levels following reduction in
ambient air Pb levels and a subsequent
decrease in exposure through incidental
soil ingestion and the contribution of
outdoor soil to indoor dust). This aspect
of the analysis will tend to
underestimate the reductions in risk
associated with alternative NAAQS.
However, this does not mean that
overall risk has been underestimated.
The net effect of all sources of
uncertainty or bias in the analysis,
which may also tend to under- or
overestimate risk, could not be
quantified.
Additionally, there is uncertainty
related to parsing out exposure and risk
between background and policyrelevant exposure pathways (and
subsequent parsing of recent air and
past air) resulting from a number of
technical limitations. Key among these
is that, while conceptually, indoor Pb
paint contributions to indoor dust Pb
would be considered background and
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included in modeling background
exposures, due to technical limitations
related to indoor dust Pb modeling,
ultimately, Pb paint was included as
part of ‘‘other’’ indoor dust Pb (i.e., as
part of past air exposure). The inclusion
of indoor lead Pb as a component of
‘‘other’’ indoor air (and consequently as
a component of ‘‘past air’’ exposure)
represents a source of potential high
bias in our prediction of total exposure
and risk associated with past air because
conceptually, exposure to indoor paint
Pb is considered part of background
exposure.
In summary, because of limitations in
the assessment design, data and
modeling tools, the risk attributable to
policy-relevant exposure pathways is
bounded on the low end by the risk
estimated for the ‘‘recent air’’ category
and on the upper end by the risk
estimated for the ‘‘recent air’’ plus ‘‘past
air’’ categories.
f. Analytical Steps
The risk assessment includes four
analytical steps, briefly described below
and presented in detail in Sections
2.4.4, 3.1, 3.2, 4.1, and 5.1 of the Risk
Assessment Report (USEPA, 2007b).
• Characterization of Pb in ambient
air: The characterization of outdoor
ambient air Pb levels uses different
approaches depending on the case study
(as explained in more detail below): (a)
Source-oriented and non-source
oriented monitors are assumed to
represent different exposure zones in
the city-specific case studies, (b) a single
exposure level is assumed, based on
monitoring data for various cities, for
the general urban case study, and (c)
ambient levels are estimated using air
dispersion modeling based on Pb
emissions from a particular facility in
the point source case studies.
• Characterization of outdoor soil/
dust and indoor dust Pb concentrations:
Outdoor soil Pb levels are estimated
using empirical data and/or fate and
transport modeling. Indoor dust Pb
levels are predicted using a combination
of (a) regression-based models that
relate indoor dust to ambient air Pb and/
or outdoor soil Pb, and (b) mechanistic
models.36
• Characterization of blood Pb levels:
Blood Pb levels for each exposure zone
are derived from central-tendency blood
Pb concentrations estimated using the
36 Additional detail on the methods used in
characterizing Pb concentrations in outdoor soil
and indoor dust are presented in Sections 3.1.3 and
3.1.4 of the Risk Assessment, respectively. Data,
methods and assumptions here used in
characterizing Pb concentrations in these exposure
media may differ from those in other analyses that
serve different purposes.
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Integrated Exposure and Uptake
Biokinetic (IEUBK) model, and
concurrent or lifetime average blood Pb
is estimated from these outputs as
described in Section 3.2.1.1 of the Risk
Assessment Report (USEPA, 2007b). For
the point source and location-specific
urban case studies, a probabilistic
exposure model is used to generate
population distributions of blood Pb
concentrations based on: (a) The central
tendency blood Pb levels for each
exposure zone, (b) demographic data for
the distribution of children (less than 7
years of age) across exposure zones in a
study area, and (c) a geometric standard
deviation (GSD) intended to
characterize interindividual variability
in blood Pb (e.g., reflecting differences
in behavior and biokinetics related to
Pb). For the general urban case study, as
demographic data for a specific location
are not considered, the GSD is applied
directly to the central tendency blood
Pb level to estimate a population
distribution of blood Pb levels.
Additional detail on the methods used
to model population blood Pb levels is
presented in Sections 3.2.2 and 5.2.2.3
of the Risk Assessment Report (USEPA,
2007b).
• Risk characterization (estimating IQ
loss): Concurrent or lifetime average
blood Pb estimates for each simulated
child in each case study population are
converted into total Pb-related IQ loss
estimates using the concentrationresponse functions described above.
Key limitations and uncertainties
associated with the application of these
specific analytical steps are summarized
in Section III.B.2.g below.
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g. Generating Multiple Sets of Risk
Results
In the initial analyses for the full-scale
assessment (USEPA, 2007a), EPA
implemented multiple modeling
approaches for each case study scenario
in an effort to characterize the potential
impact on exposure and risk estimates
of uncertainty associated with the
limitations in the tools, data and
methods available for this risk
assessment and with key analytical
steps in the modeling approach. These
multiple modeling approaches are
described in Section 2.4.6.2 of the final
Risk Assessment Report (USEPA,
2007b). In consideration of comments
provided by CASAC (Henderson, 2007b)
on these analyses regarding which
modeling approach they felt had greater
scientific support, a pared down set of
modeling combinations was identified
as the core approach for the subsequent
analyses. This core modeling approach
includes the following key elements:
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• Ambient air Pb estimates (based on
monitors or modeling and proportional
rollbacks, as described below),
• Background exposure from food
and water (as described above),
• The hybrid indoor dust model
specifically developed for urban
residential applications (which predicts
Pb in indoor dust as a function of
ambient air Pb and nonair contribution),
• The IEUBK blood Pb model (which
predicts blood Pb in young children
exposed to Pb from multiple exposure
pathways),
• The concurrent blood Pb metric,
• A GSD for concurrent blood Pb of
2.1 to characterize interindividual
variability in blood Pb levels for a given
ambient level, and
• four different functions relating
concurrent blood Pb to IQ loss,
including two log-linear models (one
with a cutpoint and one with lowexposure linearization) and two duallinear models with stratification, one
stratified at 7.5 µg/dL peak blood Pb and
the other at 10 µg/dL peak blood Pb.
For each case study, the core
modeling approach employs a single set
of modeling elements to estimate
exposure and the four different
concentration-response functions
referenced above to derive four sets of
risk results from the single set of
exposure estimates. The spread of
estimates resulting from application of
all four functions captures much of the
uncertainty associated model choice in
this analytical step. Among these four
functions, greater confidence is
associated with estimates derived using
the log-linear with low-exposure
linearization concentration-response
function as discussed above.
In addition to employing multiple
concentration-response functions, the
assessment includes various sensitivity
analyses to characterize the potential
impact of uncertainty in other key
analysis steps on exposure and risk
estimates. The sensitivity analyses and
uncertainty characterization completed
for the risk analysis are described in
Sections 3.5, 4.3, 5.2.5 and 5.3.3 of the
Risk Assessment Report (USEPA,
2007b).
h. Key Limitations and Uncertainties
As recognized above, EPA has made
simplifying assumptions in several areas
of this assessment due to the limited
data, models, and time available. These
assumptions and related limitations and
uncertainties are described in the Risk
Assessment Report (USEPA, 2007b).
Key assumptions, limitations and
uncertainties are briefly identified
below. EPA considers these aspects of
the assessment to be important to the
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interpretation of the exposure and risk
estimates. In the presentation below,
limitations (and associated uncertainty)
are listed, beginning with those
regarding design of the assessment or
case studies, followed by those
regarding estimation of Pb
concentrations in ambient air indoor
dust, outdoor soil/dust, and blood, and
lastly regarding estimation of Pb-related
IQ Loss.
• Temporal aspects: Exposure for the
simulated child population begins at
birth (including a prenatal maternal
contribution) and continues for 7 years,
with Pb concentrations in all exposure
media remaining constant throughout
the period, and children residing in the
same exposure zone throughout the
period. In characterizing exposure
media concentrations, annual averages
are derived and held constant through
the seven year period. Exposure factors
and physiological parameters vary with
age of the cohort through the seven year
exposure period, several exposure
factors and physiological parameters are
varied on an annual basis within the
blood Pb modeling step. These aspects
are a simplification of population
exposures that contributes some
uncertainty to our exposure and risk
estimates.
• General urban case study: This case
study differs from the others in several
ways. It is by definition a general case
study and not based on a specific
location. There is a single exposure zone
for the case study within which all
media concentrations of Pb are assumed
to be spatially uniform; that is, no
spatial variation within the area is
simulated. Additionally, the case study
does not rely on any specific
demographic values. Within the single
exposure zone a theoretical population
of unspecified size is assumed to be
uniformly distributed. Thus this case
study is a simplified representation of
urban areas intended to inform our
assessment of the impact of changes in
ambient Pb concentrations on risk, but
which carries with it attendant
uncertainties in our interpretation of the
associated exposure and risk estimates.
For example, the risk estimates for this
case study, while generally
representative of an urban residential
population exposed to the specified
ambient air Pb levels, cannot be readily
related to a specific urban population.
Specific urban populations are spatially
distributed in a nonuniform pattern and
experience ambient air Pb levels that
vary through time and space.
Consequently, interpretations of the
associated blood Pb and risk estimates
with regard to their relevance to specific
urban residential exposures carry
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substantial uncertainty and presumably
an upward bias in risk, particularly for
large areas, across which air
concentrations may vary substantially.
• Point source case studies:
Dispersion modeling was used to
characterize ambient air Pb levels in the
point source case studies. This approach
simulates spatial gradients related to
dispersion and deposition of Pb from
emitting sources. The details of this
modeling is presented in the Risk
Assessment Report (USEPA, 2007b). In
the case of the point sources modeled,
sources were limited to those associated
with the smelter operations, and did not
include other sources such as
resuspension of roadside Pb not related
to facility operations, and other
stationary sources of Pb within or near
the study area. This means that, with
distance from the facility, there is likely
underestimation of ambient air-related
Pb exposure because with increased
distance from the facility there would be
increasing influence of other sources
relative to that of the facility. This
limitation is likely to have more
significant impact on risk estimates
associated with the full study than on
those for the subareas (which are the
portions of the study area with 1.5 km
from the smelter facilities), and to
perhaps have a more significant impact
on risk estimates associated with the
smaller secondary Pb smelter (see
below). As noted above, in their review
of the July draft risk assessment report,
the CASAC Pb Panel made several
recommendations for additional
exposure and health risk analyses
(Henderson, 2007b), including a
recommendation that the general urban
case study be augmented by the
inclusion of risk analyses in specific
urban areas of the U.S. In this regard,
they specifically stated the following
(Henderson, 2007b, p. 3):
The CASAC strongly believes that it is
important that EPA staff make estimates of
exposure that will have national implications
for, and relevance to, urban areas; and that,
significantly, the case studies of both primary
lead (Pb) smelter sites as well as secondary
smelter sites, while relevant to a few atypical
locations, do not meet the needs of
supporting a Lead NAAQS. The Agency
should also undertake case studies of several
urban areas with varying lead exposure
concentrations, based on the prototypic
urban risk assessment that OAQPS produced
in the 2nd Draft Lead Human Exposure and
Health Risk Assessments.
• Secondary Pb smelter case study:
Air Pb concentration estimates derived
from the air dispersion modeling
completed for the secondary Pb smelter
case study are subject to appreciably
greater uncertainty than that for those
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for the primary Pb smelter case study
due to a number of factors, including:
(a) A more limited and less detailed
accounting of emissions and emissions
sources associated with the facility
(particularly fugitive emissions), (b) a
lack of prior air quality modeling
analyses and performance analyses, and
(c) a substantially smaller number of PbTSP monitors in the area that could be
used to evaluate and provide confidence
in model performance.37 Further, as
mentioned in the previous bullet, no air
sources of Pb other than those
associated with the facility were
accounted for in the modeling. Given
the relatively smaller magnitude of
emissions from the secondary Pb
smelter, the underestimating potential
of this limitation with regard to air
concentrations with distance from the
facility has a greater relative impact on
risk estimates for this case study than
for the primary Pb smelter case study.
The aggregate uncertainty of all of these
factors results in low confidence in
estimates for this case study. It is
observed that exposure and risk
estimates are lower than those for the
other case studies. Although this case
study was initially intended to be used
as an example of areas near stationary
sources of intermediate size (smaller
than the primary Pb smelter),
experience with this analysis indicates
that substantially more data and
multiple case studies differing in several
aspects would be needed to broadly
characterize risks for such a category of
Pb exposure scenarios.
• Location-specific urban case
studies: The Pb-TSP monitoring
network is currently quite limited. The
number of monitors available to
represent air concentrations in these
case studies ranged from six for
Cleveland to 11 for Chicago.
Accordingly, our estimates of the
magnitude of and spatial variation of air
Pb concentrations are subject to
uncertainty associated with the limited
data. In applying the available data to
each of these case studies, exposure
zones, one corresponding to each
monitor, were created and U.S. Census
block groups (and the children within
those demographic units) were
distributed among the exposure zones.
The details of the approach used are
described in Section 5.1.3 of the Risk
Assessment Report (USEPA, 2007b).
Although this approach provides a
spatial gradient across the study area
due to differences in monitor values for
37 The information supporting the air dispersion
modeling for the primary Pb smelter case study
provides substantially greater confidence in
estimates for that case study.
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each exposure zone, this approach
assumes a constant concentration
within each exposure zone (i.e., no
spatial gradient within a zone).
Additionally, the nearest neighbor
approach to assign block groups to
exposure zones assumes that a monitor
adequately represents all locations that
are closer to that monitor than to any of
the others in the study area. In reality,
across block groups there are more
variable spatial gradients in a study area
than those reflected in the approach
used here. This introduces significant
uncertainty into the characterization of
risk for the urban case studies. As
recognized in Section, III.B.2.a, the
analyses for these case studies were
developed in response to CASAC
recommendations on the July 2007 draft
Risk Assessment (Henderson, 2007b)
and there has not been review of the
completed analyses by CASAC.
• Current NAAQS air quality
scenarios: For the location-specific
urban case studies, proportional roll-up
procedures were used to adjust ambient
air Pb concentrations up to just meet the
current NAAQS (see Sections 2.3.1 and
5.2.2.1 of the Risk Assessment Report,
USEPA, 2007b, for detailed discussion).
EPA recognizes that it is extremely
unlikely that Pb concentrations in urban
areas would rise to meet the current
NAAQS and that there is substantial
uncertainty with our simulation of such
conditions. In these case studies a
proportional roll-up was simulated,
such that it is assumed that the current
spatial distribution of air concentrations
(as characterized by the current data) is
maintained and increased Pb emissions
contribute to increased Pb
concentrations, the highest of which just
meets the current standard. There are
many other types of changes within a
study area that could result in a similar
outcome such as increases in emissions
from just one specific industrial
operation that could lead to air
concentrations in a part of the study
area that just meet the current NAAQS,
while the remainder of the study area
remained largely unchanged (at current
conditions). For the primary Pb smelter
case study, where current conditions
exceed the current NAAQS, attainment
of the current NAAQS was simulated
using air quality modeling, emissions
and source parameters used in
developing the 2007 proposed revision
to the State Implementation Plan for the
area (see Section 3.1.1.2 of the Risk
Assessment Report (USEPA, 2007b)).
• Alternative NAAQS air quality
scenarios: In all case studies,
proportional roll-down procedures were
used to adjust ambient air Pb
concentrations downward to attain
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alternative NAAQS (see Sections 2.3.1
and 5.2.2.1 of the Risk Assessment
Report, USEPA, 2007b). There is
significant uncertainty in simulating
conditions associated with the
implementation of emissions reduction
actions to meet a lower standard. There
are a variety of changes other than that
represented by a proportional roll-down
that could result in air concentrations
that just meet lower alternative
standards. For example, control
measures might be targeted only at the
specific area exceeding the standard,
resulting in a reduction of air Pb
concentrations to the alternate standard
while concentrations in the rest of the
study area remain unchanged (at current
conditions). Consequently, there is
significant uncertainty associated with
estimates for the alternate NAAQS
scenarios.
• Estimates of outdoor soil/dust Pb
concentrations: Outdoor soil Pb
concentration for both the urban case
studies and the primary Pb smelter case
study are based on empirical data (see
Section 3.1.3 of the Risk Assessment).
To the extent that the underlying
sampling data included areas containing
older structures, the impact of Pb paint
weathered from older structures on soil
Pb levels will be reflected in these
empirical estimates. In the case of the
urban case studies, a mean value from
a sample of houses built between 1940
and 1998 was used to represent soil Pb
levels (see Section 3.1.3.1 of the Risk
Assessment). Outdoor soil/dust Pb
concentrations in all air quality
scenarios have been set equal to the
values for the current conditions
scenarios. An impact of changes in air
Pb concentrations on soil
concentrations, and the associated
impact on dust concentrations, blood Pb
and risk estimates were not simulated.
In areas where air concentrations have
been greater in the past, however,
implementation of a reduced NAAQS
might be expected to yield reduced soil
Pb levels over the long term. As
described in Section 2.3.3 of the Risk
Assessment Report (USEPA, 2007b),
however, there is potentially significant
uncertainty associated with this
specification, particularly with regard to
implications for areas in which a Pb
source may locate where one of
comparable size had not been
previously. Additionally, it is possible
that control measures implemented to
meet alternative NAAQS may result in
changes to soil Pb concentrations; these
are not reflected in the assessment.
• Estimates of indoor dust Pb
concentrations for the urban case
studies (application of the hybrid
model): The hybrid mechanistic-
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empirical model for estimating indoor
dust Pb for the urban case studies (see
Section 3.1.4.1 of the Risk Assessment
Report, USEPA, 2007b) has several
sources of uncertainty that could
significantly impact its estimates. These
include: (a) Failure to consider houseto-house variability in factors related to
infiltration of outdoor ambient air Pb
indoors and subsequent buildup on
indoor surfaces, (b) limitations in data
available on the rates and efficiency of
indoor dust cleaning and removal, (c)
limitations in the method for converting
model estimates of dust Pb loading to
dust Pb concentration needed for blood
Pb modeling, and (d) the approach
employed to partition estimates of dust
Pb concentration into ‘‘recent air’’ and
‘‘other’’ components (see Section 5.3.3.4
of the Risk Assessment Report, USEPA,
2007b). These last two sources of
uncertainty reduce our confidence in
estimates of apportionment of dust Pb
between ‘‘recent air’’ and ‘‘other’’. In
recognition of this limitation, in
evaluating exposure and risk reduction
trends related to reducing ambient air
Pb levels, focus has been placed on
changes in total blood Pb rather than on
estimates of ‘‘recent air’’ blood Pb.
• Estimates of indoor dust Pb
concentrations for the primary Pb
smelter case study (application of the
site-specific regression model): There is
uncertainty associated with the sitespecific regression model applied in the
remediation zone (see Section 3.1.4.2 of
the Risk Assessment Report), and
relatively greater uncertainty associated
with its application to air quality
scenarios that simulate notably lower air
Pb levels. Limitations in the dataset
from which the model was derived
limited its form to that of a simple
regression that predicts dust Pb
concentration as a function of air Pb
concentration plus a constant
(intercept). However there may be
variables in addition to air that
influence dust Pb concentrations and
their absence in the regression
contributes uncertainty to the resulting
estimates. To the extent that these
unaccounted-for variables are spatially
related to the smelter facility Pb sources,
our estimates could be biased, not with
regard to the absolute dust Pb
concentration, but with regard to
differences in dust Pb concentration
estimate between different air quality
scenarios. Those differences may be
overestimated because of potential
overestimation of the air coefficient and
underestimation of the intercept in the
regression model. Examples of such
unaccounted-for variables are roadside
dust Pb and historical contributions to
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current levels of indoor dust Pb (e.g., Pb
that entered a house in the past and
continues to contribute to current dust
Pb levels).
• Characterizing interindividual
variability using a GSD: There is
uncertainty associated with the GSD
specified for each case study (see
Sections 3.2.3 and 5.2.2.3 of the Risk
Assessment Report). Two factors are
described here as contributors to that
uncertainty. Interindividual variability
in blood Pb levels for any study
population (as described by the GSD)
will reflect, to a certain extent, spatial
variation in media concentrations,
including outdoor ambient air Pb levels
and indoor dust Pb levels. For each case
study, there is significant uncertainty in
the specification of spatial variability in
ambient air Pb levels and associated
indoor dust Pb levels, as noted above. In
addition, there are a limited number of
datasets for different types of residential
child populations from which a GSD
can be derived (e.g., NHANES
datasets 38 for more heterogeneous
populations and individual study
datasets for likely more homogeneous
populations near specific industrial Pb
sources). This uncertainty associated
with the GSDs introduces significant
uncertainty in exposure and risk
estimates for the 95th population
percentile.
• Exposure pathway apportionment
for higher percentile blood Pb level and
IQ loss estimates: Apportionment of
blood Pb levels for higher population
percentiles is assumed to be the same as
that estimated using the central
tendency estimate of blood Pb in an
exposure zone. This introduces
significant uncertainty into projections
of pathway apportionment for higher
population percentiles of blood Pb and
IQ loss. In reality, pathway
apportionment may differ in higher
exposure percentiles. For example,
paint and/or drinking water exposures
may increase in importance, with airrelated contributions decreasing as an
overall percentage of blood Pb levels
and associated risk. Because of this
uncertainty related to pathway
apportionment, as mentioned earlier,
greater confidence is placed in estimates
of total Pb exposure and risk in
evaluating the impact of the current
NAAQS and alternative NAAQS relative
to current conditions.
• Relating blood Pb levels to IQ loss:
Specification of the quantitative
relationship between blood Pb level and
38 For example, the GSD for the urban case
studies, in the risk assessment described in this
notice, was derived using NHANES data for the
years 1999–2000.
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IQ loss is subject to significant
uncertainty at lower blood Pb levels
(e.g., below 5 µg/dL concurrent blood
Pb). As discussed earlier, there are
limitations in the datasets and
concentration-response analyses
available for characterizing the
concentration-response relationship at
these lower blood Pb levels. For
example, the pooled international
dataset analyzed by Lanphear and
others (2005) includes relatively few
children with blood Pb levels below 5
µg/dL and no children with levels below
1 µg/dL. In recognition of the
uncertainty in specifying a quantitative
concentration-response relationship at
such levels, our core modeling approach
involves the application of four different
functions to generate a range of risk
estimates (see Section 4.2.6 and Section
5.3.1 of the Risk Assessment Report,
USEPA, 2007b). The difference in
absolute IQ loss estimates for the four
concentration-response functions for a
given case study/air quality scenario
combination is typically close to a factor
of 3. Estimates of differences in IQ loss
between air quality scenarios (in terms
of percent), however, are more similar
across the four functions, although the
function producing higher overall risk
estimates (the dual linear function,
stratified at 7.5 µg/dL, peak blood Pb)
also produces larger absolute reductions
in IQ loss compared with the other three
functions.
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3. Summary of Results
This section presents blood Pb and IQ
loss estimates generated in the exposure
and risk assessments. Blood Pb
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estimates are presented first, followed
by IQ loss estimates.
a. Blood Pb Estimates
This section presents blood Pb
estimates for the median (Table 1) and
95th (Table 2) population percentiles.39
Each table presents estimates of blood
Pb levels resulting from total Pb
exposure across all pathways (policy
relevant and background), as well as
39 Blood Pb level estimates for current conditions
for these cases studies differ from the national
values associated with NHANES. For example,
median blood Pb levels presented in Table 1 for the
current conditions scenario for the urban case
studies are somewhat larger than the national
median from the NHANES data for 2003–2004.
Specifically, values for the three location-specific
urban case studies range from 1.7 to 1.8 µg/dL with
the general urban case study having a value of 1.9
µg/dL (current-conditions mean) (see Table 1),
while the median value from NHANES (2003–2004)
is 1.6 µg/dL (https://www.epa.gov/envirohealth/
children/body_burdens/b1-table.htm). NHANES
values for the 95th percentile were not available for
2003–2004, precluding a comparison of modeled
estimates presented in Table 2 against NHANES
data. We note, however, that the 95th percentile
value in 2001–2002 was 5.8 µg/dL (see footnote 7).
However, NHANES values for the 90th percentile
(for 2003–2004) were identified and these values
can be compared against 90th percentile estimates
generated for the urban case studies (see Risk
Assessment Report, Appendix O, Section O.3.2 for
the location-specific urban case study and
Appendix N, Section N.2.1.2 for the general urban
case study). The 90th percentile blood Pb levels for
the current conditions scenario, for the three
location-specific urban case studies range from 4.5
to 4.6 µg/dL, while the estimate for the general
urban case study is 5.0 µg/dL. These 90th percentile
values for the case study populations are larger than
the 90th percentile value of 3.9 µg/dL reported by
NHANES for all children in 2003–2004. It is noted
that ambient air levels reflected in the urban case
studies are likely to differ from those underlying the
NHANES data.
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estimates of the percent contribution
from ‘‘recent air’’ and ‘‘recent plus past
air’’ exposure categories. As noted in
Sections 4.2.4 of the Staff Paper and
Section 3.4 of the Risk Assessment
Report, given the various limitations of
our modeling tools, the contribution to
blood Pb levels from air-related
exposure pathways and current levels of
Pb emitted to the air (including via
resuspension) are likely to fall between
contributions attributed to ‘‘recent air’’
and those attributed to ‘‘recent plus past
air’’. Key uncertainties regarding
partitioning dust Pb into ‘‘recent air’’
and ‘‘other’’ categories are summarized
above (and in Section 4.2.7 of the Staff
Paper). The ‘‘recent air’’ component of
indoor dust Pb is the projected level
associated with outdoor ambient air Pb
levels, with outdoor ambient air
potentially including resuspended,
previously deposited Pb which may
reflect the resuspension of historic
levels of Pb from gasoline and from
exterior house and building Pb paint. In
presenting the 95th population
percentile estimates, it is recognized
that 5 percent of the child study
population at each case study are
estimated to have blood Pb levels above
these estimates. Due to technical
limitations, however, we believe that it
is not possible at this point to
reasonably predict the distribution of
blood Pb levels for that top 5 percent.
Observations regarding the blood Pb
results presented in Tables 1 and 2 are
presented in Section 4.3 of the Staff
Paper.
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40 As noted in footnote 39, median blood Pb
levels generated for the three location-specific
urban case studies and the general urban case study
for the current conditions scenario are somewhat
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larger than the median value from NHANES for
2003–2004.
41 As recognized in section III.B.2.d above, to
simulate air concentrations associated with the
current NAAQS, a proportional roll-up of
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concentrations from those for current conditions
was performed for the location-specific urban case
studies. This was not necessary for the primary Pb
smelter case study in which air concentrations
currently exceed the current standard.
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noted in footnote 39, 90th percentile blood
Pb levels generated for the three location specific
urban case studies and the general urban case study
for the current conditions scenario are larger than
the 90th percentile value from NHANES for 2003–
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42 As
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2004. Note, 95th percentile values were not
available for the NHANES 2003–2004 dataset,
preventing a direct comparison to modeled
estimates presented in Table 2. However, in 2001–
2002, the 95th percentile value was 5.8 µg/dL (see
footnote 7).
43 As recognized in section III.B.2.d above, to
simulate air concentrations associated with the
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current NAAQS, a proportional roll-up of
concentrations from those for current conditions
was performed for the location-specific urban case
studies. This was not necessary for the primary Pb
smelter case study in which air concentrations
currently exceed the current standard.
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b. IQ Loss Estimates
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This section presents IQ loss
estimates in Tables 3 through 6. These
IQ loss estimates need to be understood
in the context of the broader and more
comprehensive and detailed
presentation provided Risk Assessment
Report (USEPA, 2007b). The tables
presented here include three types of
risk estimates:
• Estimates of IQ loss for all air
quality scenarios (based on total Pb
exposure): Tables 3 and 4 present IQ
loss estimates for total Pb exposure for
each of the air quality scenarios
simulated for each case study. Table 3
presents estimates for the population
median and Table 4 presents results for
the 95th population percentile. These
results included both median and 95th
population percentile estimates. To
reflect the variation in estimates derived
from the four different concentrationresponse functions included in the
analysis, three categories of estimates
are considered including (a) IQ loss
estimates generated using the low
concentration-response function (the
model that generated the lowest IQ loss
estimates), (b) estimates generated using
the log-linear with low-exposure
linearization (LLL) model, and (c) IQ
loss estimates generated using the high
concentration-response function (the
model that generated the highest IQ loss
estimates). For reasons described above,
estimates generated using the LLL
model have been given emphasis in the
summary below.
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• Estimates of IQ loss under the
current NAAQS air quality scenario
(with pathway apportionment): Tables 5
and 6 present IQ loss estimates for total
Pb exposure based on simulation of just
meeting the current NAAQS for the case
studies to which the core modeling
approach was applied. Specifically,
Table 5 presents estimates of the total
Pb-related IQ loss for the population
median and Table 6 presents estimates
for the 95th population percentile. Both
of these tables present total IQ loss
estimates for (a) total Pb exposure
(including both policy-relevant
pathways and background sources) and
(b) policy-relevant exposures alone
(bounded by estimates for ‘‘recent air’’
and for ‘‘recent plus past air’’).
• IQ loss incidence estimates for the
three location-specific urban case
studies: Estimates of the number of
children for each location-specific urban
case study projected to have total Pbrelated IQ loss greater than one point are
summarized in Table 7, and similar
estimates for IQ loss greater than 7
points are summarized in Table 8. Also
presented are the changes in incidence
of the current NAAQS and alternative
NAAQS scenarios compared to current
conditions, with emphasis placed on
estimates generated using the LLL
concentration-response function.
Estimates are presented for each of the
four concentration-response functions
used in the core analysis. The complete
set of incidence results is presented in
Risk Assessment Report Appendix O,
Section O.3.4.
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The IQ loss results presented in
Tables 3 through 8 need to be
understood in the context of the broader
and more comprehensive and detailed
presentation provided in the Risk
Assessment Report. Observations
regarding the IQ loss results presented
in Tables 3 through 8 are presented in
Section 4.4 of the Staff Paper.
It is important to point out that the
range of absolute IQ loss estimates
generated using the four models for a
given case study and air quality scenario
is typically around a factor of three.
However, the relative (proportional)
change in IQ loss across air quality
scenarios (i.e., the pattern of IQ loss
reduction across air quality scenarios for
the same case study) is fairly consistent
across all four models. This suggests
uncertainty in estimates of absolute IQ
loss for a median or 95th percentile
child with exposures related to a given
ambient air Pb level. Accordingly, we
have greater confidence in predicting
incremental changes in IQ loss across
air quality scenarios and this is reflected
in the observations presented in Section
4.4 of the Staff Paper. As with the blood
Pb estimates, 5 percent of the child
study population at each case study
location is estimated to have IQ loss
above the 95th percentile estimates
presented here, however, due to
technical limitations of our modeling
tools, it is not feasible at this point to
reasonably predict the distribution of IQ
loss levels for that top 5 percent.
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44 As
recognized in section III.B.2.d above, to
simulate air concentrations associated with the
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current NAAQS, a proportional roll-up of
concentrations from those for current conditions
was performed for the location-specific urban case
studies. This was not necessary for the primary Pb
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currently exceed the current standard.
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45 As recognized in section III.B.2.d above, to
simulate air concentrations associated with the
current NAAQS, a proportional roll-up of
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concentrations from those for current conditions
was performed for the location-specific urban case
studies. This was not necessary for the primary Pb
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currently exceed the current standard.
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46 As recognized in section III.B.2.d above, to
simulate air concentrations associated with the
current NAAQS, a proportional roll-up of
concentrations from those for current conditions
was performed for the location-specific urban case
studies. This was not necessary for the primary Pb
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smelter case study in which air concentrations
currently exceed the current standard.
47 As recognized in section III.B.2.d above, to
simulate air concentrations associated with the
current NAAQS, a proportional roll-up of
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concentrations from those for current conditions
was performed for the location-specific urban case
studies. This was not necessary for the primary Pb
smelter case study in which air concentrations
currently exceed the current standard.
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48 As recognized in section III.B.2.d above, to
simulate air concentrations associated with the
current NAAQS, a proportional roll-up of
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concentrations from those for current conditions
was performed for the location-specific urban case
studies. This was not necessary for the primary Pb
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currently exceed the current standard.
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49 As recognized in section III.B.2.d above, to
simulate air concentrations associated with the
current NAAQS, a proportional roll-up of
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concentrations from those for current conditions
was performed for the location-specific urban case
studies. This was not necessary for the primary Pb
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currently exceed the current standard.
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C. Considerations in Review of the
Standard
This section presents an integrative
synthesis of information in the Criteria
Document together with EPA analyses
and evaluations. EPA notes that the
final decision on retaining or revising
the current primary Pb standard is a
public health policy judgment to be
made by the Administrator. The
Administrator’s final decision will draw
upon scientific information and
analyses about health effects,
population exposure and risks, as well
as judgments about the appropriate
response to the range of uncertainties
that are inherent in the scientific
evidence and analyses. These judgments
will be informed by a recognition that
the available health effects evidence
generally reflects a continuum
consisting of ambient levels at which
scientists generally agree that health
effects are likely to occur, through lower
levels at which the likelihood and
magnitude of the response become
increasingly uncertain.
This approach is consistent with the
requirements of the NAAQS provisions
of the Act and with how EPA and the
courts have historically interpreted the
Act. These provisions require the
Administrator to establish primary
standards that, in the Administrator’s
judgment, are requisite to protect public
health with an adequate margin of
safety. In so doing, the Administrator
seeks to establish standards that are
neither more nor less stringent than
necessary for this purpose. The Act does
not require that primary standards be set
at a zero-risk level but rather at a level
that avoids unacceptable risks to public
health, including the health of sensitive
groups.
The following discussion starts with
background information on the current
standard (section III.C.1), including both
the basis for derivation of the current
standard and considerations and
conclusions from the 1990 Staff Paper
(USEPA, 1990b). This is followed by a
summary of the general approach for
this current review (section III.C.2).
Considerations with regard to the
adequacy of the current standard are
discussed in section III.C.3, with
evidence and exposure-risk-based
considerations in subsections III.C.3.a
and b, respectively, followed by a
summary of CASAC advice and
recommendations (section III.C.3.c) and,
lastly, solicitation of comment on the
broad range of policy options (section
III.C.3.d). Considerations with regard to
elements of alternative standards—
indicator, averaging time and form, and
level—are discussed in sections
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III.C.4.a., III.C.4.b, and III.C.4.c,
respectively. The discussion with regard
to level includes subsections on
evidence and exposure-risk-based
considerations (sections III.C.4.a and b),
followed by a summary of CASAC
advice and recommendations (section
III.C.4.c) and, lastly, solicitation of
comment on the broad range of policy
options (section III.C.4.d).
1. Background on the Current Standard
a. Basis for Setting the Current Standard
The current primary standard is set at
a level of 1.5 µg/m3, measured as PbTSP, not to be exceeded by the
maximum arithmetic mean
concentration averaged over a calendar
quarter. The standard was set in 1978 to
provide protection to the public,
especially children as the particularly
sensitive population subgroup, against
Pb-induced adverse health effects (43
FR 46246). The basis for selecting each
of the elements of the standard is
described below.
i. Level
EPA’s objective in selecting the level
of the current standard was ‘‘to estimate
the concentration of Pb in the air to
which all groups within the general
population can be exposed for
protracted periods without an
unacceptable risk to health’’ (43 FR
46252). Consistent with section 109 of
the Clean Air Act, the Agency selected
a level for the current standard that was
below the concentration that was at that
time identified as a threshold for
adverse health effects (i.e., 40 µg/dl
blood Pb), so as to provide an adequate
margin of safety. As stated in the notice
of final rulemaking, ‘‘This estimate was
based on EPA’s judgment in four key
areas:
(1) Determining the ‘‘sensitive
population’’ as that group within the
general population which has the lowest
threshold for adverse effects or greatest
potential for exposure. EPA concludes
that young children, aged 1 to 5, are the
sensitive population.
(2) Determining the safe level of total
lead exposure for the sensitive
population, indicated by the
concentration of lead in the blood. EPA
concludes that the maximum safe level
of blood lead for an individual child is
30 µg Pb/dl and that population blood
lead, measured as the geometric mean,
must be 15 µg Pb/dl in order to place
99.5 percent of children in the United
States below 30 µg Pb/dl.
(3) Attributing the contribution to
blood lead from nonair pollution
sources. EPA concludes that 12 µg Pb/
dl of population blood lead for children
should be attributed to nonair exposure.
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(4) Determining the air lead level
which is consistent with maintaining
the mean population blood lead level at
15 µg Pb/dl [the maximum safe level].
Taking into account exposure from
other sources (12 µg Pb/dl), EPA has
designed the standard to limit air
contribution after achieving the
standard to 3 µg Pb/dl. On the basis of
an estimated relationship of air lead to
blood lead of 1 to 2, EPA concludes that
the ambient air standard should be 1.5
µg Pb/m3.’’ (43 FR 46252)
EPA’s judgments in these key areas, as
well as margin of safety considerations,
are discussed below.
The assessment of the science that
was presented in the 1977 Criteria
Document (USEPA, 1977), indicated
young children, aged 1 to 5, as the
population group at particular risk from
Pb exposure. Children were recognized
to have a greater physiological
sensitivity than adults to the effects of
Pb and a greater exposure. In identifying
young children as the sensitive
population, EPA also recognized the
occurrence of subgroups with enhanced
risk due to genetic factors, dietary
deficiencies or residence in urban areas.
Yet information was not available to
estimate a threshold for adverse effects
for these subgroups separate from that of
all young children. Additionally, EPA
recognized both a concern regarding
potential risk to pregnant women and
fetuses, and a lack of information to
establish that these subgroups are more
at risk than young children.
Accordingly, young children, aged 1 to
5, were identified as the group which
has the lowest threshold for adverse
effects of greatest potential for exposure
(i.e., the sensitive population) (43 FR
46252).
In identifying the maximum safe
exposure, EPA relied upon the
measurement of Pb in blood (43 FR
46252–46253). The physiological effect
of Pb that had been identified as
occurring at the lowest blood Pb level
was inhibition of an enzyme integral to
the pathway by which heme (the oxygen
carrying protein of human blood) is
synthesized, i.e., delta-aminolevulinic
acid dehydratase (d-ALAD). The 1977
Criteria Document reported a threshold
for inhibition of this enzyme in children
at 10 µg Pb/dL. The 1977 Criteria
Document also reported a threshold of
15–20 µg/dL for elevation of
protoporphyrin (EP), which is an
indication of some disruption of the
heme synthesis pathway. EPA
concluded that this effect on the heme
synthesis pathway (indicated by EP)
was potentially adverse. EPA further
described a range of blood levels
associated with a progression in
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detrimental impact on the heme
synthesis pathway. At the low end of
the range (15–20 µg/dL), the initial
detection of EP associated with blood Pb
was not concluded to be associated with
a significant risk to health. The upper
end of the range (40 µg/dL), the
threshold associated with clear evidence
of heme synthesis impairment and other
effects contributing to clinical
symptoms of anemia, was regarded as
clearly adverse to health. EPA also
recognized the existence of thresholds
for additional adverse effects (e.g.,
nervous system deficits) occurring for
some children at just slightly higher
blood Pb levels (e.g., 50 µg/dL).
Additionally, EPA stated that the
maximum safe blood level should not be
higher than the blood Pb level
recognized by the CDC as ‘‘elevated’’
(and indicative of the need for
intervention). In 1978, that level was 30
µg/dL. 50
Having identified the maximum safe
blood level in individual children, EPA
next made a public health policy
judgment regarding the target mean
blood level for the U.S. population of
young children (43 FR 46252–46253).
With this judgment, EPA identified a
target of 99.5 percent of this population
to be brought below the maximum safe
blood Pb level. This judgment was
based on consideration of the size of the
sensitive subpopulation, and the
recognition that there are special highrisk groups of children within the
general population. The population
statistics available at the time (the 1970
U.S. Census) indicated a total of 20
million children younger than 5 years of
age, with 15 million residing in urban
areas and 5 million in center cities
where Pb exposure was thought likely to
be ‘‘high’’. Concern about these highrisk groups influenced EPA’s
determination of 99.5 percent, deterring
EPA from selecting a population
percentage lower than 99.5 (43 FR
46253). EPA then used standard
statistical techniques to calculate the
population mean blood Pb level that
50 The CDC subsequently revised their advisory
level for children’s blood Pb to 25 µg/dL in 1985,
and to 10 µg/dL 1991. In 2005, with consideration
of a review of the evidence by their advisory
committee, CDC revised their statement on
Preventing Lead Poisoning in Young Children,
specifically recognizing the evidence of adverse
health effects in children with blood Pb levels
below 10 µg/dL and the data demonstrating that no
‘‘safe’’ threshold for blood Pb in children had been
identified, and emphasizing the importance of
preventative measures (CDC, 2005a). Recently,
CDC’s Advisory Committee on Childhood Lead
Poisoning Prevention noted the 2005 CDC
statements and reported on a review of the clinical
interpretation and management of blood Pb levels
below 10 µg/dL (ACCLPP, 2007). More details on
this level are provided in Section III.A.1.
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would place 99.5 percent of the
population below the maximum safe
level. Based on the then available data,
EPA concluded that blood Pb levels in
the population of U.S. children were
normally distributed with a GSD of 1.3.
Based on standard statistical techniques,
EPA determined that a thus described
population in which 99.5 percent of the
population has blood Pb levels below 30
µg/dL would have a geometric mean
blood level of 15 µg/dL. EPA described
15 µg/dL as ‘‘the maximum safe blood
lead level (geometric mean) for a
population of young children’’ (43 FR
46247).
When setting the current NAAQS,
EPA recognized that the air standard
needed to take into account the
contribution to blood Pb levels from Pb
sources unrelated to air pollution.
Consequently, the calculation of the
current NAAQS included the
subtraction of Pb contributed to blood
Pb from nonair sources from the
estimate of a safe mean population
blood Pb level. Without this subtraction,
EPA recognized that the combined
exposure to Pb from air and nonair
sources would result in a blood Pb
concentration exceeding the safe level
(43 FR 46253). In developing an
estimate of this nonair contribution,
EPA recognized the lack of detailed or
widespread information about the
relative contribution of various sources
to children’s blood Pb levels, such that
an estimate could only be made by
inference from other empirical or
theoretical studies, often involving
adults. Additionally, EPA recognized
the expectation that the contribution to
blood Pb levels from nonair sources
would vary widely, was probably not in
constant proportion to air Pb
contribution, and in some cases may
alone exceed the target mean population
blood Pb level (43 FR 46253–46254).
The amount of blood Pb attributed to
nonair sources was selected based
primarily on findings in studies of blood
Pb levels in areas where air Pb levels
were low relative to other locations in
U.S. The air Pb levels in these areas
ranged from 0.1 to 0.7 µg/m3. The
average of the reported blood Pb levels
for children of various ages in these
areas was on the order of 12 µg/dL.
Thus, 12 µg/dL was identified as the
nonair contribution, and subtracted
from the population mean target level of
15 µg/dL to yield a value of 3 µg/dL as
the limit on the air contribution to blood
Pb.
In determining the air Pb level
consistent with an air contribution of 3
µg Pb/dL, EPA reviewed studies
assessed in the 1977 Criteria Document
that reported changes in blood Pb with
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different air Pb levels. These studies
included a study of children exposed to
Pb from a primary Pb smelter,
controlled exposures of adult men to Pb
in fine particulate matter, and a
personal exposure study involving
several male cohorts exposed to Pb in a
large urban area in the early 1970s (43
FR 46254). Using all three studies, EPA
calculated an average slope or ratio over
the entire range of data. That value was
1.95 (rounded to 2 µg/dL blood Pb
concentration to 1 µg/m3 air Pb
concentration), and is recognized to fall
within the range of values reported in
the 1977 Criteria Document. On the
basis of this 2-to-1 relationship, EPA
concluded that the ambient air standard
should be 1.5 µg Pb/m3 (43 FR 46254).
In consideration of the appropriate
margin of safety during the development
of the current NAAQS, EPA identified
the following factors: (1) The 1977
Criteria Document reported multiple
biological effects of Pb in practically all
cell types, tissues and organ systems, of
which the significance for health had
not yet been fully studied; (2) no
beneficial effects of Pb at then current
environmental levels were recognized;
(3) data were incomplete as to the extent
to which children are indirectly
exposed to air Pb that has moved to
other environmental media, such as
water, soil and dirt, and food; (4) Pb is
chemically persistent and with
continued uncontrolled emissions
would continue to accumulate in
human tissue and the environment; and
(5) the possibility that exposure
associated with blood Pb levels
previously considered safe might
influence neurological development and
learning abilities of the young child (43
FR 46255). Recognizing that estimating
an appropriate margin of safety for the
air Pb standard was complicated by the
multiple sources and media involved in
Pb exposure, EPA chose to use margin
of safety considerations principally in
establishing a maximum safe blood Pb
level for individual children (30 µg Pb/
dL) and in determining the percentage
of children to be placed below this
maximum level (about 99.5 percent).
Additionally, in establishing other
factors used in calculating the standard,
EPA used margin of safety
considerations in the sense of making
careful judgment based on available
data, but these judgments were not
considered to be at the precautionary
extreme of the range of data available at
the time (43 FR 46251).
EPA further recognized that, because
of the variability between individuals in
a population experiencing a given level
of Pb exposure, it was considered
impossible to provide the same margin
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of safety for all members in the sensitive
population or to define the margin of
safety in the standard as a simple
percentage. EPA believed that the
factors it used in designing the
standards provided an adequate margin
of safety for a large proportion of the
sensitive population. The Agency did
not believe that the margin was
excessively large or on the other hand
that the air standard could protect
everyone from elevated blood Pb levels
(43 FR 46251).
ii. Averaging Time, Form, and Indicator
The averaging time for the current
standard is a calendar quarter. In the
decision for this aspect of the standard,
the Agency also considered a monthly
averaging period, but concluded that ‘‘a
requirement for the averaging of air
quality data over calendar quarter will
improve the validity of air quality data
gathered without a significant reduction
in the protectiveness of the standards.’’
As described in the notice for this
decision (43 FR 46250), this conclusion
was based on several points, including
the following:
• An analysis of ambient
measurements available at the time
indicated that the distribution of air Pb
levels was such that there was little
possibility that there could be sustained
periods greatly above the average value
in situations where the quarterly
standard was achieved.
• A recognition that the monitoring
network may not actually represent the
exposure situation for young children,
such that it seemed likely that elevated
air Pb levels when occurring would be
close to Pb air pollution sources where
young children would typically not
encounter them for the full 24-hour
period reported by the monitor.
• Medical evidence available at the
time indicated that blood Pb levels reequilibrate slowly to changes in air
exposure, a finding that would serve to
dampen the impact of short-term period
of exposure to elevated air Pb.
• Direct exposure to air is only one of
several routes of total exposure, thus
lessening the impact of a change in air
Pb on blood Pb levels.
The statistical form of the current
standard is as a not-to-be-exceeded or
maximum value. EPA set the standard
as a ceiling value with the conclusion
that this air level would be safe for
indefinite exposure for young children
(43 FR 46250).
The indicator is total airborne Pb
collected by a high volume sampler (43
FR 46258). EPA’s selection of Pb-TSP as
the indicator for the standard was based
on explicit recognition both of the
significance of ingestion as an exposure
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pathway for Pb that had deposited from
the air and of the potential for Pb
deposited from the air to become resuspended in respirable size particles in
the air and available for human
inhalation exposure. As stated in the
final rule, ‘‘a significant component of
exposure can be ingestion of materials
contaminated by deposition of lead from
the air,’’ and that, ‘‘in addition to the
indirect route of ingestion and
absorption from the gastrointestinal
tract, non-respirable Pb in the
environment may, at some point become
respirable through weathering or
mechanical action’’ (43 FR 46251).
b. Policy Options Considered in the Last
Review
During the 1980s, EPA initiated a
review of the air quality criteria and
NAAQS for Pb. CASAC and the public
were fully involved in this review,
which led to the publication of a criteria
document with associated addendum
and a supplement (USEPA, 1986a,
1986b, 1990a), an exposure analysis
methods document (USEPA, 1989) and
a staff paper (USEPA, 1990b).
Total emissions to air were estimated
to have dropped by 94 percent between
1978 and 1987, with the vast majority of
it attributed to the reduction of Pb in
gasoline. Accordingly, the focus of the
last review was on areas near stationary
sources of Pb emissions. Although such
sources were not considered to have
made a significant contribution (as
compared to Pb in gasoline) to the
overall Pb pollution across large, urban
or regional areas, Pb emissions from
such sources were considered to have
the potential for a significant impact on
a local scale. Air Pb concentrations, and
especially soil and dust Pb
concentrations had been associated with
elevated levels of Pb absorption in
children and adults in numerous Pb
point source community studies.
Exceedances of the current NAAQS
were found at that time only in the
vicinity of nonferrous smelters or other
point sources of Pb.
In summarizing and interpreting the
health evidence presented in the 1986
Criteria Document and associated
documents, the 1990 Staff Paper
described the collective impact on
children of the effects at blood Pb levels
above 15 µg/dL as representing a clear
pattern of adverse effects worthy of
avoiding. This is in contrast to EPA’s
identification of 30 µg/dL as a safe blood
Pb level for individual children when
the NAAQS was set in 1978. The Staff
Paper further stated that at blood Pb
levels of 10–15 µg/dL, there was a
convergence of evidence of Pb-induced
interference with a diverse set of
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physiological functions and processes,
particularly evident in several
independent studies showing impaired
neurobehavioral function and
development. Further, the available data
did not indicate a clear threshold in this
blood Pb range. Rather, it suggested a
continuum of health risks down to the
lowest levels measured.51
For the purposes of comparing the
relative protectiveness of alternative Pb
NAAQS, the staff conducted analyses to
estimate the percentages of children
with blood Pb levels above 10 µg/dL and
above 15 µg/dL for several air quality
scenarios developed for a small set of
stationary source exposure case studies.
The results of the analyses of child
populations living near two Pb smelters
indicated that substantial reductions in
Pb exposure could be achieved through
just meeting the current Pb NAAQS.
According to the best estimate analyses,
over 99.5% of children living in areas
significantly affected by the smelters
would have blood Pb levels below 15
µg/dL if the current standard was
achieved. Progressive changes in this
number were estimated for the
alternative monthly Pb NAAQS levels
evaluated in those analyses, which
ranged from 1.5 µg/m3 to 0.5 µg/m3.
In light of the health effects evidence
available at the time, the 1990 Staff
Paper presented air quality, exposure,
and risk analyses, and other policy
considerations, as well as the following
staff conclusions with regard to the
primary Pb NAAQS (USEPA, 1990b, pp.
xii to xiv):
(1) ‘‘The range of standards * * *
should be from 0.5 to 1.5 µg/m3.’’
(2) ‘‘A monthly averaging period
would better capture short-term
increases in lead exposure and would
more fully protect children’s health than
the current quarterly average.’’
(3) ‘‘The most appropriate form of the
standard appears to be the second
highest monthly averages {sic} in a 3year span. This form would be nearly as
stringent as a form that does not permit
any exceedances and allows for
discounting of one ‘‘bad’’ month in 3
years which may be caused, for
example, by unusual meteorology.’’
(4) ‘‘With a revision to a monthly
averaging time more frequent sampling
is needed, except in areas, like
roadways remote from lead point
sources, where the standard is not
expected to be violated. In those
situations, the current 1-in-6 day
sampling schedule would sufficiently
reflect air quality and trends.’’
51 In 1991, the CDC reduced their advisory level
for children’s blood Pb from 25 µg/dL to 10 µg/dL.
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(5) ‘‘Because exposure to atmospheric
lead particles occurs not only via direct
inhalation, but via ingestion of
deposited particles as well, especially
among young children, the hi-volume
sampler provides a reasonable indicator
for determining compliance with a
monthly standard and should be
retained as the instrument to monitor
compliance with the lead NAAQS until
more refined instruments can be
developed.’’
Based on its review of a draft Staff
Paper, which contained the above
recommendations, the CASAC strongly
recommended to the Administrator that
EPA should actively pursue a public
health goal of minimizing the Pb
content of blood to the extent possible,
and that the Pb NAAQS is an important
component of a multimedia strategy for
achieving that goal (CASAC, 1990, p. 4).
In noting the range of levels
recommended by staff, CASAC
recommended consideration of a revised
standard that incorporates a ‘‘wide
margin of safety, because of the risk
posed by Pb exposures, particularly to
the very young whose developing
nervous system may be compromised by
even low level exposures’’ (id., p. 3).
More specifically, CASAC judged that a
standard within the range of 1.0 to 1.5
µg/m3 would have ‘‘relatively little, if
any, margin of safety;’’ that greater
consideration should be given to a
standard set below 1.0 µg/m3; and, to
provide perspective in setting the
standard, it would be appropriate to
consider the distribution of blood Pb
levels associated with meeting a
monthly standard of 0.25 µg/m3, a level
below the range considered by staff (id.).
After consideration of the documents
developed during the review, EPA chose
not to propose revision of the NAAQS
for Pb. During the same time period, the
Agency published and embarked on the
implementation of a broad, multiprogram, multi-media, integrated
national strategy to reduce Pb exposures
(USEPA, 1991). As part of implementing
this integrated Pb strategy, the Agency
focused efforts primarily on regulatory
and remedial clean-up actions aimed at
reducing Pb exposures from a variety of
non-air sources judged to pose more
extensive public health risks to U.S.
populations, as well as on actions to
reduce Pb emissions to air, particularly
near stationary sources. This focus
reflected in part the dramatic reduction
of Pb in gasoline that occurred since the
standard was set in 1978, which
resulted in orders-of-magnitude
reductions in airborne emissions of Pb,
and a significant shift in the types of
sources with the greatest Pb emissions.
EPA established standards for Pb-based
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paint hazards and Pb dust cleanup
levels in most pre-1978 housing and
child-occupied facilities. Additionally,
EPA has developed standards for the
management of Pb in solid and
hazardous waste, oversees the cleanup
of Pb contamination at Superfund sites,
and has issued regulations to reduce Pb
in drinking water (https://www.epa.gov/
lead/regulation.htm). Beyond these
specific regulatory actions, the Agency’s
Lead Awareness Program has continued
to work to protect human health and the
environment against the dangers of Pb
by conducting research and designing
educational outreach activities and
materials (https://www.epa.gov/lead/).
Actions to reduce Pb emissions to air
during the 1990s included enforcement
of the NAAQS, as well as the
promulgation of regulations under
Section 112 of the Clean Air Act,
including national emissions standards
for hazardous air pollutants at primary
and secondary Pb smelters, as well as
other Pb sources.
2. Approach for Current Review
To evaluate whether it is appropriate
to consider retaining the current
primary Pb standard, or whether
consideration of revisions is
appropriate, EPA is considering an
approach in this review like that used
in the Staff Paper. As discussed below,
this approach builds upon the general
approach used in the initial setting of
the standard, as well as that used in the
last review, and reflects the broader
body of evidence and information now
available.
This approach is based on an
integration of information on health
effects associated with exposure to
ambient Pb; expert judgment on the
adversity of such effects on individuals;
and policy judgments as to when the
standard is requisite to protect public
health with an adequate margin of
safety, which are informed by air quality
and related analyses, quantitative
exposure and risk assessments when
possible, and qualitative assessment of
impacts that could not be quantified.
In conducting this assessment, EPA is
aware of the dramatic reductions in air
Pb emissions in the U.S. in recent
decades.52 In addition to the dramatic
reduction of Pb in gasoline, an
additional circumstance that has
changed since the standard was set is
the enactment of the Clean Air Act
Amendments of 1990, which amended
Clean Air Act Section 112 to list Pb
compounds as hazardous air pollutants
52 Detailed information on air Pb emissions, and
temporal trends in emissions since 1980 is provided
in Section 2.2 of the Staff Paper.
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(HAP) and to require technology-based
and risk-based standards, as
appropriate, for major stationary sources
of HAP.53 EPA is also aware that these
significantly changed circumstances
have raised the question in this review
of whether it is still appropriate to
maintain a NAAQS for Pb or to retain
Pb on the list of criteria pollutants. As
a result, this evaluation will consider
the status of Pb as a criteria pollutant
and assesses whether revocation of the
standard is an appropriate option for the
Administrator to consider.
As discussed below, in conducting
this evaluation, EPA will take into
account both evidence-based and
quantitative exposure- and risk-based
considerations. To the extent that the
available information suggests that
revision of the current standard may be
appropriate to consider, EPA will also
evaluate the currently available
information to determine the extent to
which it supports consideration of a
revised standard. In this evaluation,
EPA will consider the specific elements
of the standard to identify options (in
terms of an indicator, averaging time,
level, and form) for consideration in
making public health policy judgments,
based on the currently available
information, as to the degree of
protection that is requisite to protect
public health with an adequate margin
of safety.
To help inform the Agency’s
consideration of the quantitative
exposure and risk assessments,
summarized above in section III.B, EPA
solicits comment on the appropriate
weight to be placed on the results from
these assessments in evaluating the
adequacy of the current primary
standard and in considering alternative
standards. Specifically, we solicit
comment on a number of aspects of the
design of the assessments and
interpretation of the assessment results,
including in particular: (1) The
appropriateness of rolling up ambient
Pb concentrations to simulate just
meeting the current standard for areas in
which current concentrations are well
below the level of the current
standard; 54 (2) the use of a proportional
53 The use of Pb paint in new houses has declined
substantially over the 20th century. For example ‘‘an
estimated 68% of U.S. homes built before 1940 have
Pb hazards, as do 43% of those built during 1940–
1959 and 8% of those built during 1960–1977’’
(ACCLPP, 2007). We are uncertain of the
implications of these reductions for ambient air.
54 We have not in the past used such an approach
in developing risk assessments for other NAAQS
reviews since other risk assessments (i.e., for ozone
and PM) included a number of areas that did not
meet the current NAAQS such that rolling up
ambient pollutant concentrations was not needed to
characterize risks associated with just meeting the
current standard.
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method to roll-up and roll-down Pb
concentrations to simulate just meeting
the current and alternative standards; 55
(3) the categorization and
apportionment of policy-relevant
exposure pathways and policy-relevant
background, particularly with regard to
exposures related to historically
deposited Pb from leaded gasoline and
from Pb paint; and (4) the weight to be
given to risk estimates derived using
various concentration-response
functions. More broadly, we also solicit
comment on the approach of
considering exposures and risks
resulting from the ingestion of
historically emitted Pb that may now be
present in indoor dust and outdoor soil
(e.g., that associated with past use of Pb
in gasoline or Pb paint) impacted by
ambient air Pb as being policy-relevant
for the purpose of setting a NAAQS.
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3. Adequacy of the Current Standard
In considering the adequacy of the
current standard, EPA will first consider
whether it is appropriate to maintain a
NAAQS for Pb or to retain Pb on the list
of criteria pollutants. As noted above,
this question has arisen in this review
as a result of the dramatic alteration in
the basic patterns of air Pb emissions in
the U.S. since the standard was set, that
primarily reflects the dramatic
reduction of Pb in gasoline, which
resulted in orders-of-magnitude
reductions in airborne emissions of Pb
and a significant shift in the types of
sources with the greatest Pb emissions.
In addition, Section 112 of the Clean Air
Act was amended in 1990 to include Pb
compounds on the list of HAP and to
require EPA to establish technologybased emission standards for those
listed major source categories emitting
Pb compounds, and to establish riskbased standards, as appropriate, for
those categories of sources.
EPA notes that CASAC specifically
examined several scientific issues and
related public health (and public
welfare) policy issues that the CASAC
Lead Review Panel 56 judged to be
essential in determining whether
delisting Pb or revoking the Pb NAAQS
would be appropriate options for the
Administrator to consider. In its letter to
the Administrator of March 27, 2007,
based on its review of the first draft Staff
Paper (Henderson, 2007a; Attachment A
of the Staff Paper), CASAC’s
55 There
are other methods that might be used.
Lead Panel includes the statutorily
defined seven-member CASAC and additional
subject-matter experts needed to provide an
appropriate breadth of expertise for this review of
the Pb NAAQS.
56 This
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examination of these issues was framed
by the following series of questions:
(1) Does new scientific information
accumulated since EPA’s promulgation
of the current primary Lead NAAQS of
1.5 µg/m3 in 1978 suggest that science
previously overstated the toxicity of
lead?
(2) Have past regulatory and other
controls on lead decreased PbB [blood
lead] concentrations in human
populations so far below levels of
concern as to suggest there is now an
adequate margin of safety inherent in
those PbB levels?
(3) Have the activities that produced
emissions and atmospheric
redistribution of lead in the past
changed to such an extent that society
can have confidence that emissions will
remain low even in the absence of
NAAQS controls?
(4) Are airborne concentrations and
amounts of lead sufficiently low
throughout the United States that future
regulation of lead exposures can be
effectively accomplished by regulation
of lead-based products and allowable
amounts of lead in soil and/or water?
(5) If lead were de-listed as a criteria
air pollutant, would it be appropriately
regulated under the Agency’s Hazardous
Air Pollutants (HAP) program?
For the reasons presented in its March
2007 letter, the CASAC Lead Review
Panel judged that the answer to each of
these questions was ‘‘no,’’ leading the
Panel to conclude that ‘‘the existing
state of science is consistent with
continuing to list ambient lead as a
criteria pollutant for which fullyprotection NAAQS are required’’ (id, p.
5). Further, in a subsequent letter to the
Administrator of September 27, 2007,
based on its review of the second draft
Risk Assessment Report (Henderson,
2007b; Attachment B of the Staff Paper),
CASAC strongly reiterated its
opposition to any considered delisting
of Pb, and expressed its unanimous
support for maintaining fully-protective
NAAQS (id., p. 2). The EPA seeks
comment and supporting information
on the issue of whether it would be
appropriate for EPA to determine that
emissions of Pb no longer contribute to
air pollution that may reasonably be
anticipated to endanger public heath.
EPA also solicits comment and
supporting information on the extent to
which reductions in the ambient air Pb
standard would benefit public health.
In considering the adequacy of the
current standard, EPA will consider the
available evidence and quantitative
exposure- and risk-based information,
summarized below.
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a. Evidence-Based Considerations
In considering the broad array of
health effects evidence assessed in the
Criteria Document with respect to the
adequacy of the current standard, EPA
will focus on those health endpoints
associated with the Pb exposure and
blood levels most pertinent to ambient
exposures. Additionally, we will give
particular weight to evidence available
today that differs from that available at
the time the standard was set with
regard to its support of the current
standard.
First, with regard to the sensitive
population, the susceptibility of young
children to the effects of Pb is well
recognized, in addition to more recent
recognition of effects of chronic
exposure to low level Pb with advancing
age (CD, Sections 5.3.7 and pp. 8–73 to
8–75). The prenatal period and early
childhood are periods of increased
susceptibility to Pb exposures, with
evidence of adverse effects on the
developing nervous system that
generally appear to persist into later
childhood and adolescence (CD, Section
6.2).57 Thus, while the sensitivity of the
elderly and other particular subgroups
is recognized, as at the time the
standard was set, young children
continue to be recognized as the key
sensitive population for Pb exposures.
With regard to the exposure levels at
which adverse health effects occur, the
current evidence demonstrates the
occurrence of adverse health effects at
appreciably lower blood Pb levels than
those demonstrated by the evidence at
the time the standard was set. This
change in the evidence since the time
the standard was set is reflected in
changes made by the CDC in their
advisory level for Pb in children’s
blood, and changes they have made in
their characterization of that level.
Although CDC recognized a level of 30
µg/dL blood Pb as warranting individual
intervention in 1978 when the Pb
NAAQS was set, in 2005 they
recognized the evidence of adverse
health effects in children with blood Pb
levels below 10 µg/dL and the data
demonstrating that no ‘‘safe’’ threshold
for blood Pb had been identified (CDC,
1991; CDC, 2005).
The Criteria Document describes
current evidence regarding the
occurrence of a variety of adverse health
57 For example, the following statement is made
in the Criteria Document ‘‘Negative Pb impacts on
neurocognitive ability and other neurobehavioral
outcomes are robust in most recent studies even
after adjustment for numerous potentially
confounding factors (including quality of care
giving, parental intelligence, and socioeconomic
status). These effects generally appear to persist into
adolescence and young adulthood.’’ (CD, p.E–9)
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effects, including those on the
developing nervous system, associated
with blood Pb levels extending well
below 10 µg/dL to 5 µg/dL and possibly
lower (CD, Sections 8.4 and 8.5).58 With
regard to the evidence of effects on the
developing nervous system at these low
levels, EPA notes, in particular, the
international pooled analysis by
Lanphear and others (2005), studies of
individual cohorts such as the
Rochester, Boston, and Mexico City
cohorts (Canfield et al., 2003a; Canfield
et al., 2003b; Bellinger and Needleman,
2003; Tellez-Rojo et al., 2006), the study
of African-American inner-city children
from Detroit (Chiodo et al., 2004), and
the cross-sectional analysis of a
nationally representative sample from
the NHANES III (conducted from 1988–
1994), in which the mean blood Pb level
was 1.9 µg/dL (Lanphear et al., 2000).
Further, current evidence does not
indicate a threshold for the more
sensitive health endpoints such as
adverse effects on the developing
nervous system (CD, pp. 5–71 to 5–74
and Section 6.2.13).
As when the standard was set in 1978,
EPA recognizes that there remain today
contributions to blood Pb levels from
nonair sources. Estimating contributions
from nonair sources are complicated by
the persistent nature of Pb. For example,
Pb that is a soil or dust contaminant
today may have been airborne yesterday
or many years ago. The studies currently
available and reviewed in the Criteria
Document that evaluate the multiple
pathways of Pb exposure do not usually
distinguish between outdoor soil/dust
Pb resulting from historical emissions
and outdoor soil/dust Pb resulting from
recent emissions. Further, while indoor
dust Pb has been identified as being a
predominant contributor to children’s
blood Pb, available studies do not
distinguish the different pathways (airrelated and other) contributing to indoor
dust Pb. As recognized in Section III.A.
58 For context, it is noted that the 2001–2004
median blood level for children aged 1–5 of all
races and ethnic groups is 1.6 µg/dL, the median
for the subset living below the poverty level is 2.3
µg/dL and 90th percentile values for these two
groups are 4.0 µg/dL and 5.4 µg/dL, respectively.
Similarly, the 2001–2004 median blood level for
black, non-hispanic children aged 1–5 is 2.5 µg/dL,
while the median level for the subset of that group
living below the poverty level is 2.9 µg/dL and the
median level for the subset living in a household
with income more than 200% of the poverty level
is 1.9 µg/dL. Associated 90th percentile values for
2001–2004 are 6.4 µg/dL (for black, non-hispanic
children aged 1–5), 7.7 µg/dL (for the subset of that
group living below the poverty level) and 4.1 µg/
dL (for the subset living in a household with
income more than 200% of the poverty level).
(https://www.epa.gov/envirohealth/children/
body_burdens/b1-table.htm—then click on
‘‘Download a universal spreadsheet file of the Body
Burdens data tables’’).
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above (including footnote 13), some
studies have found that dietary intake of
Pb may be a predominant source of Pb
exposure among adults, greater than
consumption of water and beverages or
inhalation (CD, p. 3–43). The exposure
assessment for children performed for
this review has employed available data
and methods to develop estimates
intended to inform a characterization of
these pathways.
Consistent with reductions in air Pb
concentrations 59 which contribute to
blood Pb, nonair contributions have also
been reduced. For example, the use of
Pb paint in new houses has declined
substantially over the 20th century,
such that ‘‘an estimated 68% of U.S.
homes built before 1940 have Pb
hazards, as do 43% of those built during
1940–1959 and 8% of those built during
1960–1977’’ (ACCLPP, 2007).
Additionally, Pb contributions to diet
have been reported to have declined
significantly since 1978, perhaps as
much as 70% or more between then and
1990 (WHO, 1995) and the 2006 Criteria
Document identifies a drop in dietary
Pb intake by 2 to 5 year olds of 96%
between the early 1980s and mid 1990s.
The 1977 Criteria Document included a
dietary Pb intake estimate for the
general population of 100 to 350 µg Pb/
day (USEPA 1977, p. 1–2) and the 2006
Criteria Document cites recent studies
indicating a dietary intake ranging from
2 to 10 µg Pb/day (CD, Section 3.4 and
p. 8–14). Reductions in elevated blood
Pb levels in urban areas indicate that
other nonair contributions to blood Pb
(e.g., drinking water distribution
systems, and Pb-based paint) have also
been reduced since the late 1970s. In
their March 2007 letter to the
Administrator, the CASAC Pb Panel
recommended that 1.0–1.4 µg/dL or
lower be considered as an estimate of
the nonair component of blood Pb.
As in 1978, the evidence
demonstrates that Pb in ambient air
contributes to Pb in blood, with the
pertinent exposure routes including
both inhalation and ingestion (CD,
Sections 3.1.3.2, 4.2 and 4.4; Hilts et al.,
2003). In 1978, the evidence indicated a
quantitative relationship between
ambient air Pb and blood Pb—i.e., the
ratio describing the increase in blood Pb
per unit of air Pb—that ranged from 1:1
to 1:2 (USEPA, 1977). In setting the
standard, the Agency relied on a ratio of
1:2, i.e., 2 µg/dL blood Pb per 1 µg/m3
air Pb (43 FR 46252). The evidence now
and in the past on this relationship is
limited by the circumstances in which
59 Air Pb concentrations nationally are estimated
to have declined more than 90% since the early
1980s.
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the data are collected. Specific
measurements of Pb in blood that
derived from Pb that had been in the air
are not available. Rather, estimates are
available for the relationship between
Pb concentrations in air and Pb levels in
blood, developed from populations in
differing Pb exposure circumstances,
which inform this issue. Many of the
currently available reviews of estimates
for air-to-blood ratios, which include air
contributions from both inhalation and
ingestion exposure pathways, indicate
that such ratios generally fall between
1:3 to 1:5, with some higher 60 (USEPA
1986a, pp. 11–99 to 11–100 and 11–106;
Brunekreef, 1984). Findings of a recent
study of changes in children’s blood Pb
levels associated with reduced Pb
emissions and associated air
concentrations near a Pb smelter in
Canada indicates a ratio on the order of
1:7 (CD, pp. 3–23 to 3–24; Hilts et al.,
2003). In their advice to the Agency,
CASAC identified values of 1:5 as used
by the World Health Organization
(2000) and 1:10 as supported by an
empirical analysis of changes in air Pb
and changes in blood Pb between 1976
and the time when the phase-out of Pb
from gasoline was completed
(Henderson, 2007a).61 While there is
uncertainty in the absolute value of the
air-to-blood relationship, the current
evidence indicates a notably greater
ratio, with regard to increase in blood
Pb, than the 1978 1:2 relationship e.g.,
on the order of 1:3 to 1:5 with some
higher estimates (see footnote 60) and
some lower estimates (down to 1:1).
EPA’s consideration of this issue in
1986 indicated that ratios which
consider both inhalation and ingestion
pathways are ‘‘necessarily higher than
those estimates for inhaled air lead
alone’’ (USEPA, 1986a, p. 11–106). We
solicit comment on data or studies that
may help inform our understanding of
this important parameter.
Based on this information, the Staff
Paper concluded that young children
remain the sensitive population of
primary focus in this review, there is
now no recognized safe level of Pb in
60 For example, adjusted ratios from Brunekreef
(1984, Table 1) ranged up to 1:8.5 and unadjusted
ratios extended above 1:10.
61 The CASAC Panel stated ‘‘The Schwartz and
Picher analysis showed that in 1978, the midpoint
of the National Health and Nutrition Examination
Survey (NHANES) II, gasoline lead was responsible
for 9.1 µg/dL of blood lead in children. Their
estimate is based on their coefficient of 2.14 µg/dL
per 100 metric tons (MT) per day of gasoline use,
and usage of 426 MT/day in 1976. Between 1976
and when the phase-out of lead from gasoline was
completed, air lead concentrations in U.S. cities fell
a little less than 1 µg/m3 (24). These two facts imply
a ratio of 9–10 µg/dL per µg/m3 reduction in air
lead, taking all pathways into account.’’
(Henderson, 2007a, page D–2 to D–3).
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children’s blood, and studies appear to
show adverse effects at mean concurrent
blood Pb levels as low as 2 ug/dL (CD,
pp. 6–31 to 6–32; Lanphear et al., 2000).
Further, while the nonair contribution
to blood Pb has declined, perhaps to a
range of 1.0–1.4 µg/dL, the air-to-blood
ratio appears to be higher at today’s
lower blood Pb levels than the estimates
at the time the standard was set, with
current estimates on the order of 1:3 to
1:5 and perhaps up to 1:10. Using the
framework employed in setting the
standard in 1978, the more recently
available evidence and more recently
available estimates may suggest a level
for the standard that is lower by an
order of magnitude or more.
b. Exposure- and Risk-Based
Considerations
In addition to the evidence-based
considerations, EPA will also consider
exposures and health risks estimated to
occur upon meeting the current Pb
standard to help inform judgments
about the extent to which exposure and
risk estimates may be judged to be
important from a public health
perspective, taking into account key
uncertainties associated with the
estimated exposures and risks.
As discussed above, young children
are the sensitive population of primary
focus in this review. The exposure and
risk assessment estimates Pb exposure
for children (less than 7 years of age),
and associated risk of neurocognitive
effects in terms of IQ decrements. In
addition to the risks (IQ decrement) that
were quantitatively estimated, EPA
recognizes that there may be long-term
adverse consequences of such deficits
over a lifetime, that there is evidence of
other health effects occurring at similar
or higher exposures for young children,
and that other health evidence
demonstrates associations between Pb
exposure and adverse health effects in
adults. As noted in section III.B above,
the risk assessment results focus
predominantly on risk estimates derived
using the log-linear with low-exposure
linearization (LLL) concentrationresponse function, with the range
associated with the other three
functions also being noted.
As noted in the Criteria Document, a
modest change in the mean for a health
index at the individual level can have
substantial implications at the
population level (CD, p. 8–77, Sections
8.6.1 and 8.6.2; Bellinger, 2004;
Needleman et al., 1982; Weiss, 1988;
Weiss, 1990)). For example, for an
individual functioning in the low range
of IQ due to the influence of risk factors
other than Pb, a Pb-associated IQ
decline of a few points might be
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sufficient to drop that individual into
the range associated with increased risk
of educational, vocational, and social
handicap (CD, p. 8–77). Further, given
a somewhat uniform manifestation of
Pb-related decrements across the range
of IQ scores in a population, a
downward shift in the mean IQ value is
not associated only with a substantial
increase in the percentage of individuals
achieving very low scores, but also with
substantial decreases in percentages
achieving very high scores (CD, p. 8–
81). The CASAC Pb Panel has advised
on this point that ‘‘a population loss of
1–2 IQ points is highly significant from
a public health perspective’’
(Henderson, 2007a, p. 6).
In this section, risk estimates for the
median and for an upper percentile, the
95th are discussed. In setting the
standard in 1978, EPA accorded risk
management significance to the 99.5th
percentile by selecting a mean blood Pb
level intended to bring 99.5 percent of
the population to or below the then
described maximum safe blood Pb level.
Similarly, in their advice to EPA in this
review, CASAC stated that ‘‘the primary
lead standard should be set so as to
protect 99.5% of the population’’
(Henderson, 2007a, p. 6). In considering
estimates from the quantitative
assessment that will inform conclusions
consistent with this objective, however,
EPA and CASAC also recognize
uncertainties in the risk estimates at the
edges of the distribution and
consequently the 95th percentile is
reported as the estimate of the high end
of the risk distribution (Henderson,
2007b, p. 3). In so doing, however, EPA
notes that there are individuals in the
population expected to have higher risk,
the consideration of which is important
given the risk management objectives
for the current standard when set in
1978 with regard to the 99.5th
percentile.
In addition to estimating IQ loss
associated with the combined exposure
to Pb from all exposure pathways, EPA
estimated IQ loss for two policy-relevant
categories of exposure pathways. These
are ‘‘recent air’’, which conceptually is
intended to include contributions to
blood Pb associated with Pb that has
recently been in the air, and ‘‘past air’’,
intended to include contributions to
blood Pb associated with Pb that was in
the air in the past but not in the air
recently. In the exposure modeling
conducted for the risk assessment, the
exposure pathways assigned to the
recent air category were inhalation of
ambient air Pb and ingestion of the
component of indoor dust Pb that is
predicted to be associated with ambient
air concentrations. The exposure
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pathways assigned to the past air
category were ingestion of outdoor soil/
dust Pb and ingestion of the component
of indoor dust Pb not assigned to recent
air. There are various limitations
associated with our modeling tools that
affected the estimates for these two
categories. As a result, blood Pb levels
and associated risks of greatest interest
in this review—those associated with
exposure pathways involving ambient
air Pb and current levels of Pb emitted
to the air (including via resuspension)—
are likely to fall between estimates for
recent air and those for the sum of
recent plus past air.62 Accordingly, this
notice presents these two sets of
estimates as providing a range of
interest, with regard to policy-relevant
Pb, for this review.
In considering the adequacy of the
current standard, it is important to note
that the standard is currently met
throughout the country with very few
exceptions. The national composite
average maximum quarterly mean based
on 198 active monitoring sites during
2003–2005 is 0.17 µg/m3, an order of
magnitude below the current standard,
indicating that most of the monitored
areas of the country are well below the
standard. Review of the current
monitoring network in light of current
information on Pb sources and
emissions, however, indicated that
monitors are not located near many of
the larger sources. Therefore, the
assessment may be underestimating Pb
concentrations.
Using the current monitoring data,
EPA estimated exposure and risk
associated with current conditions in a
general urban case study and in three
location-specific urban case studies in
areas where air concentrations fall
significantly below the current
standard.63 Two current conditions
scenarios were assessed for the general
urban case study, one based on the 95th
percentile of levels in large urban areas
(0.87 µg/m3, maximum quarterly mean)
and one based on mean levels in such
62 Comparisons of blood Pb levels estimated for
individual case study populations (from all
exposure sources in current conditions scenarios) to
national population values from NHANES are noted
in footnote 39 in Section III.B.3.a.
63 Comparisons of median and 90th percentile
blood Pb levels estimated for individual case study
populations (from all exposure sources in current
conditions scenarios) to national population values
from NHANES are noted in footnote 39 in Section
III.B.3.a. That comparison suggests that modeled
estimates generated for the location-specific urban
case studies for both population percentiles are
somewhat larger than values cited in NHANES (for
2003–2004). However, as mentioned earlier, factors
related to Pb exposure, including ambient air levels,
are likely to differ for the urban case study
populations compared with the national population
underlying NHANES.
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areas (0.14 µg/m3, maximum quarterly.
Levels in the three location-specific case
studies ranged from 0.09 to 0.35 µg/m3,
in terms of maximum quarterly average.
For the general urban case study, which
is a simplified representation of urban
areas, median estimates of total Pbrelated IQ loss range from 1.5 to 6.3
points (across all four concentrationresponse functions), with estimates
based on the LLL function of 4.5 and 4.7
points, for the mean and high-end
current conditions scenarios,
respectively. Associated estimates for
exposure pathway contributions to total
IQ loss (LLL estimate) at the population
median in these two scenarios indicate
that IQ loss associated with policyrelevant Pb falls somewhere between 1.3
and 3.6 points. At the 95th percentile
for total IQ loss (LLL estimate), IQ loss
associated with policy-relevant Pb is
estimated to fall somewhere between 2.2
and 6.0 points (Risk Assessment Report,
Table 5–9).
For the three location-specific areas,
median estimates of total Pb-related IQ
loss for current conditions range from
1.4 to 5.2 points (across all four
concentration-response functions), with
estimates based on the LLL function all
being 4.2 points.64 Median IQ loss
associated with policy-relevant Pb (LLL
function) is estimated to fall between
0.6 to 2.9 points IQ loss. The 95th
percentile estimates for total Pb-related
IQ loss across the three location-specific
urban case studies range from 4.1 to
11.4 points (across all four
concentration-response functions), with
estimates based on the LLL function
ranging from 7.5 to 7.6 points. At the
95th percentile for the three locationspecific urban case studies, IQ loss
associated with policy-relevant Pb (LLL
function) is estimated to fall between
1.2 to 5.2 points IQ loss (Risk
Assessment Report, Tables 5–9 and 5–
10).
In order to consider exposure and risk
associated with the current standard,
EPA developed estimates for a case
study based on air quality projected to
just meet the standard in a location of
the country where air concentrations do
not meet the current standard (the
primary Pb smelter case study). In so
64 Although the maximum quarterly average
concentration for the highest monitor in each study
area differs among the three areas by a factor of 4
(0.09 to 0.36 µg/m3), the population weighted air Pb
concentrations for these three study areas are more
similar and differ by approximately a factor of 2,
with the study area with highest maximum
quarterly average concentration having a lower
population-weighted air concentration that is more
similar to the other two areas. This similarity in
population weighted concentrations explains the
finding of similar total IQ loss across the three
study areas.
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doing, we consider it extremely unlikely
that air concentrations in urban areas
across the U.S. that are currently well
below the current standard would
increase to just meet the standard.
However, we recognize the potential for
air Pb concentrations in some areas
currently well below the standard to
increase to just meet the standard by
way of, for example, expansion of
existing sources (e.g., facilities operating
as secondary smelters may exercise
previously used capabilities as primary
smelters) or by the congregation of
multiple Pb sources in adjacent
locations. We have simulated this
scenario (increased Pb concentrations to
just meet the current standard) in a
general urban case study and three
location-specific urban case studies. In
this scenario, we note substantial
uncertainty in simulating how the
profile of Pb concentrations might
change in the hypothetical case where
concentrations increase to just meet the
current standard.
Turning first to the estimates of total
blood Pb for the current NAAQS
scenario simulated for the locationspecific urban case studies, we note the
extent to which exposures associated
with increased air Pb concentrations
that simulate just meeting the current
standard are estimated to increase blood
Pb levels in young children. The
magnitude of this for the median total
blood Pb ranges from 0.3 µg/dL (an
increase of 20 percent) in the case of the
Cleveland study area for which current
conditions are estimated to be
approximately one fourth of the current
NAAQS, up to approximately 1 µg/dL
(an increase of 50 to 70%) for the
Chicago and Los Angeles study areas for
which current conditions are estimated
to be at or below one tenth of the
current NAAQS.
Estimates of IQ loss (for child with
median total IQ loss estimate) associated
with recent air plus past air Pb at
exposures allowed by just meeting the
current NAAQS in the primary Pb
smelter case study differ when
considering the full study area (10 km
radius) or the 1.5 km radius subarea.
Estimates for median IQ loss associated
with the recent air plus past air
categories of exposure pathways for the
full study area range from 0.6 point to
2.3 points (for the range of
concentration-response functions),
while these estimates for the subarea
range from 3.2 points to 9.4 points IQ
loss. The estimates (recent plus past) for
the median based on the LLL
concentration-response function are 1.9
points IQ loss for the full study area and
6.0 points for the subarea. The 95th
percentile estimates of total IQ loss in
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the subarea range from 5.0 to 12.4
points, with an associated range for the
recent air plus past air of 4.2 to 10.4
points.
For the current NAAQS scenario in
the three location-specific case studies,
estimates of IQ loss associated with
policy-relevant Pb for the median total
IQ loss range from 0.6 points loss
(recent air estimate using low-end
concentration-response function) to 7.4
points loss (recent plus past air estimate
using the high-end concentrationresponse function). The corresponding
estimates based on the LLL
concentration-response function range
from 2.7 points (lowest location-specific
recent air estimate) to 4.7 points IQ loss
(highest location-specific recent plus
past air estimate). The comparable
estimates of IQ loss for children at the
95th percentile range from 2.6 to 7.6
points for the LLL concentrationresponse function.
Further, in comparing current
NAAQS scenario estimates to current
conditions estimates for the three
location-specific urban case studies, the
estimated difference in total Pb-related
IQ loss for the median is about 0.5 to 1.4
points using the LLL concentrationresponse function and a similar
magnitude of difference is estimated for
the 95th percentile. The corresponding
estimate for the general urban case
study is 1.1 to 1.3 points higher total Pbrelated IQ loss for the current NAAQS
scenario compared to the two current
conditions scenarios.
Estimates of median and 95th
percentile IQ loss associated with
policy-relevant Pb exposure for air
quality scenarios under current
conditions (which meet the current
NAAQS) and, particularly those
reflecting conditions simulated to just
meet the current standard,65 indicate
levels of IQ loss that some may
reasonably consider to be significant
from a public health perspective.
Further, for the three location-specific
urban case studies, the estimated
differences in incidences of children
with IQ loss greater than one point and
with IQ loss greater than seven points in
comparing current conditions to those
associated with the current NAAQS
indicate the potential for significant
numbers of children to be negatively
affected if air Pb concentrations
increased to levels just meeting the
65 As recognized in section III.B.2.d above, to
simulate air concentrations associated with the
current NAAQS, a proportional roll-up of
concentrations from those for current conditions
was performed for the location-specific urban case
studies. This was not necessary for the primary Pb
smelter case study in which air concentrations
currently exceed the current standard.
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current standard. Estimates of the
additional number of children with IQ
loss greater than one point (based on the
LLL concentration-response function) in
these three study areas with the current
NAAQS scenario compared to current
conditions range from 100 to 6,000
across the three locations. The
corresponding estimates for the
additional number of children with IQ
loss greater than seven points, for the
current NAAQS as compared to the
current conditions scenario range from
600 to 35,000. These latter values for the
change in incidence of children with
greater than seven points Pb-related IQ
loss represent 5 to 17 percent of the
children (aged less than 7 years of age)
in these study areas. This increase
corresponds to approximately a
doubling in the number of children with
this magnitude of Pb-related IQ loss in
the study area most affected.
While the risk assessment has
quantified risks associated with IQ
impacts in childhood, there are other,
unquantified adverse neurocognitive
effects that may occur at similarly low
exposures which might additionally
contribute to reduced academic
performance, which may have adverse
consequences over a lifetime (CD, pp. 8–
29 to 8–30). Additional impacts at low
levels of childhood exposure that were
not quantified in the risk assessment
include: other neurological effects
(sensory, motor, cognitive and
behavioral), immune system effects
(including some related to allergic
responses and asthma), and early effects
related to anemia.
c. CASAC Advice and
Recommendations
Beyond the evidence- and risk/
exposure-based information discussed
above, in considering the adequacy of
the current standard, EPA will also
consider the advice and
recommendations of CASAC, based on
their review of the Criteria Document
and the drafts of the Staff Paper and the
related technical support document, as
well as comments from the public on
drafts of the Staff Paper and related
technical support document.66 With
regard to the public comments, those
that addressed adequacy of the current
standard concluded that the current
standard is inadequate and should be
revised, suggesting appreciable
reductions in the level. No comments
66 All
written comments submitted to the Agency
will be available in the docket for this rulemaking,
as will be transcripts of the public meeting held in
conjunction with CASAC’s review of the first draft
of the Staff Paper and the first draft of the related
technical support document, and of draft and final
versions of the Criteria Document.
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were received expressing the view that
the current standard is adequate. One
comment was received arguing not that
the standard was inadequate but rather
that conditions justified that it should
be revoked. In both the 1990 review and
this review of the standard set in 1978,
CASAC, has recommended
consideration of more health protective
NAAQS. In CASAC’s review of the 1990
Staff Paper, as discussed in Section
5.2.2, they generally recommended
consideration of levels below 1.0 µg/m3,
specifically recommended analyses of a
standard set at 0.25 µg/m3, and also
recommended a monthly averaging time
(CASAC, 1990). In two letters to the
Administrator during the current
review, CASAC has consistently
recommended that the primary NAAQS
should be ‘‘substantially lowered’’ from
the current level of 1.5 µg/m3 to a level
of ‘‘0.2 µg/m3 or less’’ (Henderson,
2007a, b). CASAC drew support for this
recommendation from the current
evidence, described in the Criteria
Document, of health effects occurring at
dramatically lower blood Pb levels than
those indicated by the evidence
available when the standard was set.
CASAC concluded that the current Pb
NAAQS ‘‘are totally inadequate for
assuring the necessary decreases of lead
exposures in sensitive U.S. populations
below those current health hazard
markers identified by a wealth of new
epidemiological, experimental and
mechanistic studies’’, and stated that
‘‘Consequently, it is the CASAC Lead
Review Panel’s considered judgment
that the NAAQS for Lead must be
decreased to fully-protect both the
health of children and adult
populations’’ (Henderson, 2007a, p. 5).
d. Policy Options
In considering the adequacy of the
current standard, EPA first notes the
dramatic changes in the basic patterns
of air Pb emissions in the U.S. since the
standard was set, reflecting the phaseout of Pb in gasoline, as well as changes
to the CAA related to the inclusion of
Pb compounds on the list of HAPs and
associated requirements for technologyand risk-based standards for major
stationary sources. We are aware that
questions have been raised about the
appropriateness of retaining Pb on the
list of criteria pollutants and/or
maintaining a NAAQS for Pb in light of
these changed circumstances. We take
note of the views of CASAC,
summarized above, and the conclusions
and recommendations in the OAQPS
Staff Paper on these questions, which do
not support delisting Pb or revoking the
Pb NAAQS. We recognize, however,
that there may be differing views on
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interpreting or weighing the available
information. Thus, EPA solicits
comment related to the questions of
delisting and revocation. The EPA also
solicits comment on whether the broad
range of current multimedia Federal and
State Pb control programs, summarized
above in section II.C, are sufficient to
provide appropriate public health
protection in lieu of a Pb NAAQS.
In further considering the adequacy of
the current standard, EPA will focus on
the body of available evidence
(summarized above in section III.A and
discussed in the Criteria Document) that
is much expanded from that available
when the current standard was set. The
presentation of the evidence in the
Criteria Document describes the
occurrence of adverse health effects at
appreciably lower blood Pb levels than
those demonstrated by the evidence at
the time the standard was set. We
recognize that the current health effects
evidence together with findings from
the exposure and risk assessments
(summarized above in section III.B), like
the information available at the time the
standard was set, supports the
conclusion that air-related Pb exposure
pathways (by inhalation and ingestion)
contribute to blood Pb levels in young
children. Furthermore, we take note of
the information that suggests that the
air-to-blood relationship (i.e., the air-toblood ratio), is likely larger, with regard
to increase in blood Pb per unit air
concentration, when air inhalation and
ingestion are considered than that
estimated when the standard was set
using only inhalation and may be
several times larger. EPA recognizes
there is uncertainty in estimates of this
relationship and solicits comment on on
ratios supported by the current
evidence.
In areas projected to just meet the
current standard, the quantitative
estimates of risk (for IQ decrement)
associated with policy-relevant Pb
indicate risk of a magnitude that some
may consider to be significant from a
public health perspective.67 Further,
although the current monitoring data
indicate few areas with airborne Pb near
or just exceeding the current standard,
we recognize significant limitations
with the current monitoring network
and thus the potential that the
prevalence of such levels of Pb
67 As recognized in section III.B.2.d above, to
simulate air concentrations associated with the
current NAAQS, a proportional roll-up of
concentrations from those for current conditions
was performed for the location-specific urban case
studies. This was not necessary for the primary Pb
smelter case study in which air concentrations
currently exceed the current standard.
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concentrations may be underestimated
by currently available data.
As summarized above, CASAC
conclusions and recommendations and
recommendations presented in the
OAQPS Staff Paper reflect the view that
the current standard is not adequate and
support consideration of a revised
standard to provide an adequate margin
of safety for sensitive groups. Taking
these views into account, we recognize
that one approach is to consider a
revised standard. We also recognize that
there may be differing interpretations of
the available information. Thus, EPA
solicits comment on delisting,
revocation, and the adequacy of the
current standard and the rationale upon
which such views are based.
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4. Elements of the Standard
The four elements of the standard—
indicator, averaging time, form and level
serve to define the standard and must be
considered collectively in evaluating the
health and welfare protection afforded
by the standard. In considering
revisions to the current primary Pb
standard, as discussed in the following
sections, EPA will consider each of the
four elements of the standard as to how
they might be revised to provide a
primary standard for Pb that is requisite
to protect public health with an
adequate margin of safety.
a. Indicator
The indicator for the current standard
is Pb–TSP. When the standard was set,
the Agency considered identifying Pb in
particles less than or equal to 10 µm in
diameter (Pb–PM10) as the indicator in
response to comments expressing
concern that because only a fraction of
airborne particulate matter is respirable,
an air standard based on total air Pb is
unnecessarily stringent. The Agency
responded that while it agreed that
some Pb particles are too small or too
large to be deposited in the respiratory
system, a significant component of
exposures can be ingestion of materials
contaminated by deposition of Pb from
the air. In addition to the route of
ingestion and absorption from the
gastrointestinal tract, nonrespirable Pb
in the environment may, at some point,
become respirable through weathering
or mechanical action. EPA concluded
that total airborne Pb, both respirable
and nonrespirable fractions should be
addressed by the air standard.
More recently, in the 1990 Staff Paper,
this issue was reconsidered in light of
information regarding limitations of the
high-volume sampler used for the Pb–
TSP measurements and the continued
use of total suspended particulate
matter (TSP) as the indicator was
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supported by OAQPS staff (USEPA,
1990).
Given that exposure to lead occurs not only
via direct inhalation, but via ingestion of
deposited particles as well, especially among
young children, the hi-vol provides a more
complete measure of the total impact of
ambient air lead. * * * Despite its
shortcomings, the staff believes the highvolume sampler will provide a reasonable
indicator for determination of compliance
* * *
In the current review, CASAC has
recommended that EPA consider a
change in the indicator to utilize lowvolume PM10 sampling (Henderson,
2007a, b). In so doing, CASAC
recognized that a scaling of the NAAQS
level would be needed to accommodate
the loss of very large coarse-mode Pb
particles and concurrent Pb–PM10 and
Pb–TSP sampling would be needed to
inform development of scaling factors.
The September 2007 CASAC letter
states that the CASAC Lead Panel
‘‘strongly encourages the Agency to
consider revising the Pb reference
method to allow sample collection by
PM10, rather than TSP samplers,
accompanied by analysis with low-cost
multi-elemental techniques like X-Ray
Fluorescence (XRF) or Inductively
Coupled Plasma-Mass Spectroscopy
(ICP–MS).’’ While recognizing the
importance of coarse dust contributions
to total Pb exposure via the ingestion
route and acknowledging that TSP
sampling is likely to capture additional
very coarse particles which are
excluded by PM10 samplers, the Panel
raised some concerns. The concerns
were regarding the precision and
variability of TSP samplers, and the
inability to efficiently capture the nonhomogeneity of very coarse particles in
a national monitoring network, which
the Panel indicated may need to be
addressed in implementing additional
monitoring sites and an increased
frequency of sample collection that
might be required with the substantial
reduction in the level of the standard
and shorter averaging time that they
recommend (Henderson, 2007b).
In considering the appropriate
indicator, EPA takes note of and solicits
comment on previous Agency
conclusions that the health evidence
indicates that Pb in all particle size
fractions, not just respirable Pb,
contributes to Pb in blood and to
associated health effects. Additionally,
the current information does not
support the derivation of a single
scaling factor, which might be used to
relate a level for Pb–TSP to a monitoring
result using Pb–PM10 on a national
scale. The EPA recognizes, however,
that an indicator that exhibits low
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spatial variability is desirable such that
it facilitates implementation of an
effective monitoring network, i.e., one
that assures identification of areas with
the potential to exceed the NAAQS.
To the extent that Pb–PM10 exhibits
less spatial variability and that a
‘‘crosswalk’’ can be developed between
a level in terms of Pb–TSP, EPA
recognizes that it is appropriate to
consider moving to a Pb–PM10 indicator
in the future. One of the issues to
consider when moving to a Pb–PM10
indicator is whether regulating
concentrations of Pb–PM10 will lead to
appropriate controls on Pb emissions
from sources with a large percentage of
Pb in the greater than 10 micron size
range (e.g., fugitive dust emissions from
Pb smelters). It is reasonable to believe
that Pb–PM10/Pb–TSP ratios are
sensitive to distance from emissions
sources (due to faster deposition of
larger particles). As such, the use of a
Pb–PM10 indicator may have a
significant influence on the degree of Pb
controls needed from emission sources.
The EPA will consider several options
that might improve the available
database and facilitate such a move in
the future, while retaining Pb–TSP as
the indicator for the NAAQS at this
time, consistent with the
recommendations in the Staff Paper. For
example, we might consider describing
a FEM in terms of PM10 that might be
acceptably applied on a site-by-site
basis where an appropriate relationship
between Pb–TSP and Pb–PM10 can be
developed based on site-specific data.
Alternatively, use of such an FEM might
be approved, in combination with more
limited Pb–TSP monitoring, in areas
where the Pb–TSP data indicate ambient
Pb levels are well below the NAAQS
level.
These examples were intended purely
for purposes of illustrating the types of
options the Agency might consider.
Specific details of any options would
need to be supported by appropriate
data analyses. We solicit information
and comments that would help inform
such analyses and the Agency’s views
on the indicator for the primary Pb
NAAQS.
b. Averaging Time and Form
The basis for the averaging time of the
current standard reflects consideration
of the evidence available when the Pb
NAAQS were promulgated in 1978. At
that time, the Agency had concluded
that the level of the standards, 1.5 µg/
m3, would be a ‘‘safe ceiling for
indefinite exposure of young children’’
(43 FR 46250), and that the slightly
greater possibility of elevated air Pb
levels within the quarterly averaging
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period as contrasted to the monthly
averaging period proposed in 1977 (43
FR 63076), was not significant for
health. These conclusions were based in
part on the Agency’s interpretation of
the health effects evidence as indicating
that 30 µg/dL was the maximum safe
level of blood Pb for an individual
child.
As discussed above, the currently
available health effects evidence 68
indicates a variety of neurological
effects, as well as immune system and
hematological effects, associated with
levels below 10 µg/dL as a central
tendency metric of study cohorts of
young children. Further, EPA recognizes
that today ‘‘there is no level of Pb
exposure that can yet be identified, with
condfidence, as clearly not being
associated with some risk of deleterious
health effects’’ (CD, p. 8–63).
Accordingly, to the extent that air Pb
contributes to variation in blood Pb, we
currently cannot identify a safe ceiling
for indefinite exposure of young
children.
Additionally, several aspects of the
current health effects evidence for Pb
pertain to the consideration of averaging
time:
• Children are exposed to ambient Pb
via inhalation and ingestion, with Pb
taken into the body absorbed through
the lungs and through the
gastrointestinal tract. Studies on Pb
uptake, elimination and distribution
show that Pb is absorbed into peripheral
tissues in adults within a few days
(USEPA 1986a; USEPA 1990b, p. IV–2).
Absorption of Pb from the
gastrointestinal tract appears to be
greater and faster in children as
compared to adults (CD, Section 4.2.1).
Once absorbed, it is quickly distributed
from plasma to red blood cells and
throughout the body.
• Lead accumulates in the body and
is only slowly removed, with bone Pb
serving as a blood Pb source for years
after exposure and as a source of fetal
Pb exposure during pregnancy (CD,
Sections 4.3.1.4 and 4.3.1.5).
• Blood Pb levels, including levels of
the toxicologically active fraction,
respond quickly to increased Pb
exposure, such that an abrupt increase
in Pb uptake rapidly changes blood Pb
levels, with the time to reach a new
quasi-steady state with the total body
burden after such an occurrence
projected to be approximately 75 to 100
days (CD, p. 4–27).
• The elimination half-life, which
describes the time for blood Pb levels to
68 The differing evidence and associated strength
of the evidence for these different effects is
described in detail in the Criteria Document.
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stabilize after a reduction in exposure,
for the dominant phase for blood Pb
responses to changes in exposure is on
the order of 20 to 30 days for adults (CD,
p. 4–25). Blood elimination half-lives
are influenced by contributions from
bone. Given the tighter coupling in
children of bone stores with blood
levels, children’s blood Pb is expected
to respond more quickly than adults
(CD, pp. 4–20 and 4–27).
• Data from NHANES II and an
analysis of the temporal relationship
between gasoline consumption data and
blood lead data generally support the
inference of a prompt response of
children’s blood Pb levels to changes in
exposure in that children’s blood Pb
levels and the number of children with
elevated blood Pb levels appear to
respond to monthly variations in Pb
emissions from Pb in gasoline (EPA,
1986a, p. 11–39; Rabinowitz and
Needleman, 1983; Schwartz and Pitcher,
1989).
• The evidence with regard to
sensitive neurological effects is limited
in what it indicates regarding the
specific duration of exposure associated
with effect, although it indicates both
the sensitivity of the first 3 years of life
and a sustained sensitivity throughout
the lifespan as the human central
nervous system continues to mature and
be vulnerable to neurotoxicants (CD,
Section 8.4.2.7). The animal evidence
supports our understanding of periods
of development with increased
vulnerability to specific types of effect
(CD, Section 5.3), and indicates a
potential importance of exposures on
the order of months.
• Evidence of a differing sensitivity of
the immune system to Pb across and
within different periods of life stages
indicates a potential importance of
exposures as short as weeks to months
duration. For example, the animal
evidence suggests that the gestation
period is the most sensitive life stage
followed by early neonatal stage, and
within these life stages, critical
windows of vulnerability are likely to
exist (CD, Section 5.9 and p. 5–245).
Further, evidence described in the
Criteria Document and the risk
assessment indicate that ingestion of
dust can be a predominant exposure
pathway for young children to policyrelevant Pb, and that there is a strong
association between indoor dust Pb
levels and children’s blood Pb levels. As
stated in the Criteria Document, ‘‘given
the large amount of time people spend
indoors, exposure to Pb in dusts and
indoor air can be significant’’ (CD, p. 3–
27). The Criteria Document further
describes studies that evaluated the
influence of dust Pb exposure on
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children’s blood Pb: ‘‘Using a structural
equation model, Lanphear and
Roghmann (1997) also found the
exposure pathway most influential on
blood Pb was interior dust Pb loading,
directly or through its influence on
hand Pb. Both soil and paint Pb
influenced interior dust Pb; with the
influence of paint Pb greater than that
of soil Pb. Interior dust Pb loading also
showed the strongest influence on blood
Pb in a pooled multivariate regression
analysis (Lanphear et al., 1998).’’ (CD, p.
4–134).
While some of these aspects of the
health effects evidence would be
consistent with a quarterly averaging
time, taken as a whole, and in
combination with information on
potential response time for indoor dust
Pb levels, EPA recognizes that there is
also support for consideration of an
averaging time shorter than a calendar
quarter.
When the standard was set in 1978,
an analysis of ambient measurements
available at the time indicated that the
distribution of air Pb levels was such
that there was little possibility that there
could be sustained periods greatly above
the average value in situations where
the quarterly standard was achieved.
This may have been related to the
pattern of Pb emissions at the time the
standard was set, which differed from
the pattern today in that, due to
emissions from cars and trucks at that
time, emissions were more spatially
distributed. In this review, based on
data from 2003–2005, the air quality
analysis in Chapter 2 of the Staff Paper
indicates the presence of areas in the
U.S. currently where temporal
variability does create differences
between average quarterly levels and
levels sustained for shorter than
quarterly periods. For example, four
percent of the monitoring sites in the
three-year analysis dataset that meet the
current standard as an average over a
calendar quarter exceed the level of the
current standard when considering an
average for any individual month. The
same analysis indicates that this number
is as high as ten percent for some
alternate lower levels.
In further considering the appropriate
form of the standard that might
accompany a shorter averaging time,
EPA will take into account analyses
using air quality data for 2003–2005 that
characterize maximum quarterly average
and various monthly statistics for each
year across the three year Pb-TSP
dataset and also across the three year
period. The latter time period is
consistent with the three calendar year
attainment period that has been adopted
for the ozone and particulate matter
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NAAQS subsequent to the promulgation
of the Pb NAAQS. For the three year
period, the monthly statistics derived
are maximum monthly mean, second
maximum monthly mean, average of
three overall highest monthly means,
and average of three annual maximum
monthly means; these statistical forms
were also considered in the 1990 Staff
paper. Additionally, the maximum and
2nd maximum monthly means for each
year of the three year data set was
derived, as well as the averages of these
individual year statistics.
With regard to comparison of monthly
forms with the maximum quarterly
mean, the average Pb-TSP maximum
monthly mean among all 189 sites in the
analysis is notably higher (nearly a
factor of two) than the average of the
average maximum quarterly mean
among these sites. Further, this
difference is slightly greater for sourceoriented sites than non source-oriented
sites or urban sites (e.g., a factor of
approximately 1.8 as compared to one of
approximately 1.6), indicating perhaps
an influence of variability in emissions.
The alternate forms of a monthly
averaging time that were analyzed yield
an across-site average that is similar
although slightly higher than the
quarterly average (e.g., Figure 2–8 in
Chapter 2 of the Staff Paper).
The analyses described in Chapter 2
of the Staff Paper consider both a period
of three calendar years and one of an
individual calendar year (with the form
of the current standard being the
maximum quarterly mean in any one
year). These analyses indicate that with
regard to either single-year or 3-year
statistics for the 2003–2005 dataset, a
2nd maximum monthly mean yields
very similar, although just slightly
greater, numbers of sites exceeding
various alternate levels as a maximum
quarterly mean, with both yielding
fewer exceedances than a maximum
monthly mean.
In their advice to the Agency, CASAC
has recommended that consideration be
given to changing from a calendar
quarter to a monthly averaging time
(Henderson, 2007a, b). In making that
recommendation, CASAC emphasizes
support from studies that suggest that
blood Pb concentrations respond at
shorter time scales than would be
captured completely by quarterly
values, as indicated by their description
of their recommendation for adoption of
a monthly averaging time as ‘‘more
protective of human health in light of
the response of blood lead
concentrations that occur at subquarterly time scales’’ (Henderson,
2007b).
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c. Level
At this time, the Agency is interested
in soliciting comment on a wide range
of possible options for consideration
when making a proposed decision on
the level of the primary Pb NAAQS.
These policy options range from
lowering the standard, to the levels
recommended by CASAC and the
OAQPS Staff paper or lower, as well as
on other alternative levels, up to and
including the current level, and the
rationale upon which such views are
based.
initial matter, as summarized above and
discussed in greater depth in the
Criteria Document (CD, Sections 4.3 and
6.1.3), the epidemiological evidence that
associates Pb exposures with health
effects uses blood Pb as the dose metric,
not ambient air concentrations. Further,
for the health effects receiving greatest
emphasis in this review (neurological
effects on the developing nervous
system), no threshold levels can be
discerned from the evidence. As was
recognized at the time of the last review,
estimating a threshold for toxic effects
of Pb on the central nervous system
entails a number of difficulties (CD, pp.
6–10 to 6–11). The task is made still
more complex by support in the
evidence for a nonlinear rather than
linear relationship of blood Pb with
neurocognitive decrement, with greater
risk of decrement-associated changes in
blood Pb at the lower levels of blood Pb
in the exposed population (Section
3.3.7; CD, Section 6.2.13).
In considering how this evidence can
help inform the selection of the level of
the standard, EPA will consider how the
framework applied in the establishment
of the standard may be applied to the
much expanded body of evidence that is
now available. This consideration
builds upon the evidence-based
considerations of the adequacy of the
current standard, discussed above in
Section III.C.3.a.
As noted above, this review focuses
on young children as the key sensitive
population for Pb exposures, the same
population identified in 1978. In this
sensitive population, the current
evidence demonstrates the occurrence
of adverse health effects, including
those on the developing nervous system,
associated with blood Pb levels
extending well below 10 µg/dL to 5 µg/
dL and possibly lower. Some studies
indicate Pb effects on intellectual
attainment of young children at blood
Pb levels ranging from 2 to 8 µg/dL (CD,
Sections 6.2, 8.4.2 and 8.4.2.6),
including findings of similar Pb-related
effects in a study of a nationally
representative sample of children in
which the mean blood Pb level was 1.9
µg/dL (CD, pp. 6–31 to 6–32; Lanphear
et al., 2000).69 Further, the current
evidence does not indicate a threshold
for the more sensitive health endpoints
such as adverse effects on the
i. Evidence-Based Considerations
The EPA recognizes that there are
several aspects to the body of
epidemiological evidence available in
this review that complicate efforts to
translate the evidence into the basis for
selecting an appropriate level for an
ambient air quality standard. As an
69 These findings include significant associations
in the study sample subsets of children with blood
Pb levels less than 10 µg/dL, less than 7.5 µg/dL and
less than 5 µg/dL. A positive, but not statistically
significant association, was observed in the less
than 2.5 µg/dL subset, although the effect estimate
for this subset was largest among all the subsets.
The lack of statistical significance for this subset
may be due to the smaller sample size of this subset
which would lead to lower statistical power.
With regard to form of the standard,
CASAC stated that one could ‘‘consider
having the lead standards based on the
second highest monthly average, a form
that appears to correlated well with
using the maximum quarterly value’’,
while also indicating that ‘‘the most
protective form would be the highest
monthly average in a year.’’
The following observations support
consideration of a monthly averaging
time: (1) The health evidence indicates
that very short exposures can lead to
increases in blood Pb Pb levels, (2) the
time period of response of indoor dust
Pb to airborne Pb can be on the order
of weeks and, (3) the health evidence
indicates that adverse effects may occur
with exposures during relatively short
windows of susceptibility, such as
prenatally and in developing infants.
EPA also recognizes the limited
available evidence specific to the
consideration of the particular duration
of sustained airborne Pb levels having
the potential to contribute to the adverse
health effects identified as most relevant
to this review.
Based on the information and air
quality analyses discussed above, EPA
is requesting comment on a range of
options, including the recommendations
in the Staff Paper that include changing
the averaging time to monthly, with a
form of maximum or second maximum,
as well as retaining the quarterly
averaging time. The EPA is also
requesting comment on, the options of
changing the form to apply to a threeyear period as well as retaining a singleyear period. We solicit comments on
these ranges of averaging times and
forms as well as views and related
rationales that might support alternative
options.
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developing nervous system (CD, pp. 5–
71 to 5–74 and Section 6.2.13). This
differs from the Agency’s inference in
the 1978 rulemaking of a threshold of 40
µg/dL blood Pb for effects of Pb
considered clearly adverse to health at
that time, i.e., impairment of heme
synthesis and other effects which result
in anemia. Thus, the level of Pb in
children’s blood associated with adverse
health effect has dropped substantially.
As when the standard was set in 1978,
EPA recognizes that there remain today
contributions to blood Pb levels from
nonair sources. As discussed above,
these contributions have been reduced
since 1978, with estimates of reduction
in the dietary component of 70 to 95
percent (CD, Section 3.4). The evidence
is limited with regard to the aggregate
reduction since 1978 of all nonair
sources to blood Pb. However, the
available evidence and some
preliminary analysis led CASAC to
recommend consideration of 1.0 to 1.4
µg/dL or lower as an estimate of the
nonair component of blood Pb
(Henderson, 2007a). The value of 1.4 µg/
dL was the mean blood Pb level derived
from a simulation of current nonair
exposures using the IEUBK model
(Henderson, 2007a, pp. F–60 to F–61).
These current estimates are roughly an
order of magnitude lower than the value
of 12 µg/dL that was used in setting the
1978 standard.
Regarding the relationship between
air and blood, while the evidence
demonstrates that airborne Pb
influences blood Pb concentrations
through a combination of inhalation and
ingestion exposure pathways, estimates
of the precise quantitative relationship
(i.e., air-to-blood ratio) available in the
evidence vary (USEPA, 1986a;
Brunekreef, 1984) and there is
uncertainty as to the values that pertain
to current exposures. Studies
summarized in the 1986 Criteria
Document typically yield estimates in
the range of 1:3 to 1:5, with some as
high as 1:10 or higher (USEPA, 1986a;
Brunekreef, 1984). Findings in a more
recent study identified in the Criteria
Document of blood Pb response to
reduced air concentrations indicate a
ratio on the order of 1:7 (CD, pp. 3–23
to 3–24; Hilts et al., 2003). A value of
1:5 has been used by the World Health
Organization (2000). These ratios are
appreciably higher than the ratio of 1:2
that was used in setting the 1978
standard.
A standard setting approach being
considered is to apply the framework
relied upon in setting the standard in
1978 to the currently available
information. In applying that
framework, however, EPA recognizes
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that today ‘‘there is no level of Pb
exposure that can yet be identified, with
confidence, as clearly not being
associated with some risk of deleterious
health effects’’ (CD, p. 8–63). However,
there is increasing uncertainty with
regard to the magnitude and type of
effects at levels below 5 µg/dL 70. This
is in contrast to the situation in 1978
when the Agency judged that the
maximum safe blood Pb level (geometric
mean) for a population of young
children was 15 µg/dL based on its
conclusion that the maximum safe
blood Pb level of an individual child
was 30 µg/dL. 71
In illustrating the application of the
1978 framework, two blood Pb levels are
used here for illustrative purposes. A
level of 2 µg/dL was used because it
represents some of the lowest
population levels associated with
adverse effect in the current evidence
(e.g., CD, p. E–9; Lanphear et al., 2000).
In addition, a level of 5 µg/dL has been
used. This level has been associated
with adverse health effects with a higher
degree of certainty in the published
literature, and is a level where cognitive
deficits were identified with statistical
significance (Lanphear et al., 2000).
Using a blood Pb target of 2 µg/dL as
a substitute for the 1978 target of 15 µg/
dL for the child population geometric
mean, then subtracting 1 to 1.4 µg/dL for
background, yields 0.6 to 1 µg/dL as a
target for the air contribution to blood
Pb. Dividing the air target by 5,
consistent with currently available
information on the ratio of air Pb to
blood Pb, yields a potential standard
level of 0.1 to 0.2 µg/m3. Alternatively,
using the same approach substituting 5
µg/dL for the child population
geometric mean and subtracting 1 to 1.4
µg/dL for background, yields 3.6 to 4 µg/
dL as a target for the air contribution to
blood Pb. Dividing the air target by 5,
consistent with currently available
information on the ratio of air Pb to
blood Pb, yields a level of 0.7 to 0.8 µg/
m3. Similarly, substitution of other
blood Pb targets would result in still
other levels.
In light of the current CDC blood Pb
‘‘level of concern’’ of 10 µg/dL, some
might consider a blood Pb value of 10
µg/dL as a target blood Pb value for this
70 As stated in the Criteria Document ‘‘Some
recent studies of Pb neurotoxicity in infants have
observed effects at population average blood-Pb
levels of only 1 or 2 µg/dL; and some
cardiovascular, renal, and immune outcomes have
been reported at blood-Pb levels below 5 µg/dL.’’
(CD, p. E–16).
71 More specifically, the 1978 target of 15 µg/dL
was described as the geometric mean level
associated with a 99.5 percentile of 30 µg/dL which
the Agency described as a ‘‘safe level’’ for an
individual child (43 FR 46247–49).
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calculation to derive a level for the
primary standard. EPA notes, however,
that the CDC does not consider this
level of concern as a safe blood Pb level
or one without evidence of adverse
effects (CDC, 2005a). Rather, it is used
by CDC to identify children with
elevated blood Pb levels for follow-up
activities 72 at the individual level and
to trigger communitywide prevention
activities (CDC, 2005a). The level of
concern has been frequently
misinterpreted as a definitive
toxicologic threshold (CDC, 2005a). As
summarized in Section III.A and above,
and as described in detail in the Criteria
Document, various adverse effects have
been associated with children’s blood
Pb levels below 10 µg/dL. For example,
the Criteria Document states that the
currently available toxicologic and
epidemiologic information ‘‘includes
assessment of new evidence
substantiating risks of deleterious effects
on certain health endpoints beng
induced by distinctly lower than
previously demonstrated Pb exposures
indexed by blood-Pb levels extending
well below 10 µg/dL in children and/or
adults’’ (CD, p. 8–25). Accordingly, EPA
has not used a mean or an individual
target blood Pb value of 10 µg/dL as the
basis for an illustrative example of
deriving a standard that is intended to
protect public health with an adequate
margin of safety. In recognition of
differing views on this subject, however,
we solicit comment on the
appropriateness of using a mean or
individual target blood Pb value of 10
µg/dL as the foundation for deriving a
level for the primary Pb standard.
The above examples focus on the
mean target blood Pb level for the
sensitive population by way of
illustrating application of the 1978
framework. The EPA solicits comment
on mean target blood Pb levels as well
as other factors that would be important
in applying the 1978 framework. For
example, the distribution of blood Pb
levels within the sensitive population is
an important aspect of the 1978
framework. When the standard was set
in 1978, the Agency stated that the
population mean, measured as the
geometric mean, must be 15 µg/dL in
order to ensure that 99.5 percent of
children in the United States would
72 Activities such as taking an environmental
history, educating parents about Pb and conducting
follow-up blood Pb monitoring were among those
suggested for children with blood Pb levels greater
than or equal to 10 µg/dL (CDC, 2005a). Recently,
CDC’s Advisory Committee on Childhood Lead
Poisoning Prevention has also provided information
and recommendations relevant to clinical
management of children with blood Pb levels below
10 µg/dL (ACCLPP, 2007).
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have a blood Pb level below 30 µg/dL,
which was identified as the maximum
safe blood Pb level for individual
children based on the information
available at that time (43 FR 46252).
Target values for the mean of the
population necessarily imply higher
values for individuals associated with
the upper percentiles of the blood Pb
distribution. For example, the 2001–
2002 NHANES information indicates
that a geometric mean blood level of 1.7
µg/dL for children nationally, aged 1–5
years, is associated with a 95th
percentile blood Pb level of 5.8 µg/dL
(CDC, 2005b).
Additionally, the nonair (background)
contribution to total blood Pb is an
important input to the framework and
we solicit comment on the definition
and appropriate values for this
parameter.73 In the assessment
presented in this notice, contributions
attributed to ‘‘recent air’’ and to ‘‘recent
plus past air’’ may include some Pb
from the historic use of Pb in paint and
gasoline and other sources.
Further, there are a range of estimates
for the air-to-blood ratio that include
estimates higher than that used in 1978
when the standard was set. We solicit
comment and supporting information
regarding the air-to-blood ratio and
differences in the available estimates.
All of these factors are important in
applying a framework such as that used
in 1978, and we solicit comment, along
with supporting information, on all of
these factors.
Beyond the 1978 framework
illustrated above, EPA recognizes a
variety of approaches can be used in
translating the current evidence to a
level for the standard. With this notice,
EPA solicits comment on the 1978
standard setting framework and on
alternate approaches and the factors that
are relevant to those approaches.
ii. Exposure- and Risk-Based
Considerations
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To inform judgments about a range of
levels for the standard that could
provide an appropriate degree of public
health protection, in addition to
considering the health effects evidence,
EPA will also consider the quantitative
estimates of exposure and health risks
attributable to policy-relevant Pb upon
meeting specific alternative levels of
73 As noted above, in 2001 when establishing
standards for lead-based paint hazards in most pre1978 housing and child-occupied facilities (66 FR
1206), the Agency grappled with the uncertainties
in what environmental levels of historic Pb in soil
and dust (from the historical use of Pb in paint and
gasoline) in which specific medium may cause
blood Pb levels that are associated with adverse
effects (see Section II.C).
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alternative Pb standards and the
uncertainties in the estimated exposures
and risks, as discussed above in Section
III.B. As discussed above, the risk
assessment conducted by EPA is based
on exposures that have been estimated
for children of less than 7 years of age
in six case studies. The assessment
estimated the risk of adverse
neurocognitive effects in terms of IQ
decrements associated with total and
policy-relevant Pb exposures, including
incidence of different levels of IQ loss
in three of the six case studies. In so
doing, EPA is mindful of the important
uncertainties and limitations that are
associated with the exposure and risk
assessments. For example, with regard
to the risk assessment important
uncertainties include those related to
estimation of blood Pb concentrationresponse functions, particularly for
blood Pb concentrations at and below
the lower end of those represented in
the epidemiological studies
characterized in the Criteria Document.
EPA also recognizes important
limitations in the design of, and data
and methods employed in, the exposure
and risk analyses. For example, the
available monitoring data for Pb, relied
upon for estimating current conditions
for the urban case studies is quite
limited, in that monitors are not located
near some of the larger known Pb
sources, which provides the potential
for underestimation of current
conditions, and there is uncertainty
about the proximity of existing monitors
to other Pb sources potentially
influencing exposures, such as old
urban roadways and areas where
housing with Pb paint has been
demolished. All of these limitations
raise uncertainty as to whether these
data adequately capture the magnitude
of ambient Pb concentrations to which
the target population is currently
exposed. Additionally, EPA recognizes
that there is not sufficient information
available to evaluate all relevant
sensitive groups (e.g., adults with
chronic kidney disease) or all Pb-related
adverse health effects (e.g., neurological
effects other than IQ decrement,
immune system effects, adult
cardiovascular or renal effects), and the
scope of our analyses was generally
limited to estimating exposures and
risks in six case studies intended to
illustrate a variety of Pb exposure
situations across the U.S., with three of
them focused on specific areas in three
cities. As noted above, however,
coordinated intensive efforts over the
last 20 years have yielded a substantial
decline in blood Pb levels in the United
States. Recent NHANES data (2003–
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2004) yield blood lead level estimates
for children age 1 to 5 years of 1.6 µg/
dL (median) and 3.9 µg/dL (90th
percentile). These median and 90th
percentile national-level data are lower
than modeled values generated for the
three location-specific urban case
studies current conditions scenarios (see
footnote 39). It is noted, however, that
the urban case studies and the NHANES
study are likely to differ with regard to
factors related to Pb exposure, including
ambient air levels.
EPA also recognizes limitations in our
ability to characterize the contribution
of policy-relevant Pb to total Pb
exposure and Pb-related health risk. For
example, given various limitations of
our modeling tools, blood Pb levels
associated with air-related exposure
pathways and current levels of Pb
emitted to the air (including via
resuspension) may fall between the
estimates for ‘‘recent air’’ and those for
‘‘recent’’ plus ‘‘past air’’. However, there
are limitations associated with the
indoor dust Pb models that affect our
ability to discern differences in the
recent air category among different
alternate air quality scenarios and both
categories may include Pb in soil and
dust from the historical use of Pb in
paint.
With these limitations in mind, EPA
will consider the estimates of IQ loss
associated with policy-relevant Pb at air
Pb concentrations near those currently
occurring in urban areas as illustrated
by conditions in the three cities chosen
for the location-specific urban case
studies, e.g., 0.09 to 0.36 µg/m3 as a
maximum quarterly average or 0.17 to
0.56 µg/m3 as a maximum monthly
average. Recognizing, as described
above, that estimates of IQ loss
associated with air-related exposure
pathways and current levels of Pb
emitted to the air (including via
resuspension) may fall between the
estimates for ‘‘recent air’’ and those for
‘‘recent’’ plus ‘‘past air’’, EPA will
consider ranges reflecting those two
categories. Further, as noted above, we
will focus on risk estimates derived
using the LLL (log-linear with low
exposure linearization) concentrationresponse function.
The ambient air Pb related IQ loss
(based on LLL function) associated with
the median IQ loss for current
conditions in the three location-specific
case studies (see Tables 5–9 and 5–10 of
the Risk Assessment Report)—estimated
to fall between the estimates for recent
air (0.6–0.7 points) and those for recent
plus past air (2.9 points)—appears to be
of a magnitude in the range that CASAC
considered to be highly significant from
a public health perspective (e.g., a
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population IQ loss of 1–2 points).
Comparable estimates for the current
conditions scenarios in the general
urban case study are still more
significant with estimates for the general
urban case study ranging from 1.3–1.8
for recent air and 3.2–3.6 for recent plus
past air. For the primary Pb smelter case
study, in which air quality exceeds the
current NAAQS, IQ loss reductions in
the recent plus past air category
associated with the alternate NAAQS
levels of 0.2 and 0.5 µg/m3 ranging from
4.0 to 4.9 points IQ loss for the subarea.
Focusing only on the recent air
estimates, estimates of IQ loss (based on
the LLL function) associated with
policy-relevant Pb at the 95th percentile
of population total IQ loss are greater
than 1 point for all current conditions
scenarios in all three urban case studies
for which the lowest air Pb
concentrations are 0.09 µg/m3 maximum
quarterly average, and 0.17 µg/m3
maximum monthly average.
EPA will also consider the extent to
which alternative standard levels below
current conditions are estimated to
reduce blood Pb levels and associated
health risk in young children (Tables 4–
1 through 4–4 in the Staff Paper),
looking first to the estimates of total
blood Pb. In the general urban case
study, blood Pb levels for the median of
the population associated with the
lowest alternative NAAQS (0.02 µg/m3)
are estimated to be reduced from levels
in the two current conditions scenarios
by 14% (0.3 µg/dL) and 24% (0.5 µg/
dL), respectively. For the 95th
percentile of the population, the
estimated reductions are similar in
terms of percentage, but are higher in
absolute values (1.7 and 1.0 µg/dL). For
the three location-specific urban case
studies, median blood Pb estimates
associated with the lowest alternative
standard are reduced from those
associated with current conditions by
approximately 10% in the Chicago and
Cleveland study areas and 6% in the
Los Angeles study area; similar percent
reductions are estimated at the 95th
percentile total blood Pb. For the
localized subarea of the primary Pb
smelter case study, a 65% reduction in
both median and 95th percentile blood
Pb (3 and 8.1 µg/dL, respectively) is
estimated for the lowest alternative
NAAQS as compared to the current
NAAQS.74
74 This can be compared to reductions in blood
Pb, for the primary Pb smelter case study subarea
estimated to be associated with a change in the
level from the current standard to the 0.2 µg/m3
level (either averaging time) which are
approximately 45–50% for both the median and
95th percentile values.
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EPA will also consider the extent to
which specific levels of alternative Pb
standards reduce the estimated risks in
terms of IQ loss attributable to policyrelevant exposures to Pb (Tables 4–3
and 4–4 in the Staff Paper). For the
general urban case study, estimated
reductions in median Pb-related IQ loss
associated with reduced exposures at
the lowest alternative NAAQS level
(0.02 µg/m3) were 0.5 and 0.7 points
(LLL function) for the two current
conditions scenarios. Reductions at the
95th percentile were of a similar
magnitude. Among the three locationspecific case study areas, estimated
reductions in median Pb-related IQ loss
associated with reduced exposures at
the lowest alternate NAAQS as
compared to current conditions range
from 0.4 to 0.6 points for the high-end
concentration-response function to 0.1
to 0.2 points for the low-end
concentration-response functions, with
estimates for the LLL function ranging
from 0.2 to 0.3 points. The reduction at
the 95th percentile, based on the LLL
function, is 0.3–0.4 points. Reduced
exposures associated with the lowest
alternative NAAQS in the primary Pb
smelter case study subarea as compared
with the current NAAQS (which is not
currently met by this area) were more
substantial, ranging from 2.8 points at
the median and 3 points at the 95th
percentile (based on LLL function).
Based on estimated reductions in Pbassociated IQ loss discussed above, EPA
observes that estimates for the 95th
percentile of the population are quite
similar to (for the LLL concentrationresponse function) or smaller (for the
high- and low-end concentrationresponse functions) than those at the
median for all case studies. This is
because of the nonlinear relationship
between IQ decrement and blood Pb
level such that relatively smaller IQ
decrement is associated with changes in
blood Pb at higher blood Pb levels.
Reductions in air Pb concentrations
from current conditions to meet the
lower alternative NAAQS (0.02 and 0.05
µg/m3, maximum monthly mean) are
estimated to reduce the number of
children having Pb-related IQ loss
greater than one point by one half to one
percent in each of the three locationspecific urban case studies. More
specifically, within the three study areas
this corresponds to a range of
approximately 100 to 3,000 fewer
children having total IQ loss greater
than 1.0 for an alternative standard of
0.02 µg/m3, maximum monthly mean.
Further, just meeting the lowest
alternative standard in these three study
areas is estimated to reduce the number
of children having an IQ loss greater
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than seven points by one to two percent.
This corresponds to a range of
approximately 350 (for the Cleveland
study area) up to 8,000 (for the Chicago
study area) fewer children with total Pbrelated IQ loss greater than 7.0.
As discussed above, CASAC
considered a population IQ loss of 1–2
points to be highly significant from a
public health perspective. Estimates of
IQ loss associated with policy-relevant
Pb are of a magnitude that appears to
fall near or within this range for air
quality scenarios involving levels at or
above 0.09 µg/m3, maximum quarterly
mean, or 0.17 µg/m3, maximum monthly
mean. Estimated reductions in risk
associated with reducing air Pb
concentrations from current conditions
(in the urban case studies) to the two
lower alternative levels evaluated (0.02
and 0.05 µg/m3) appear to range from a
few tenths to just below one IQ point
(for the LLL concentration-response
function) (and up to 1.5 IQ points for
the highest concentration-response
function). Based on estimated changes
in risk across the population associated
with the two lower alternative levels (as
compared to current conditions),
reductions in the number of children
with total Pb-related IQ loss greater than
1 or greater than 7 are estimated to be
on the order of hundreds to thousands
of children in the three location-specific
urban case studies.
In considering the exposure and risk
information with regard to a level for
the standard, EPA notes that at the time
the standard was set, the Agency
recognized a particular blood Pb level as
‘‘safe’’. Today, current evidence does
not support the recognition of a ‘‘safe’’
level. This is generally reflected in the
concentration-response functions used
in the risk assessment and in CASAC
recommendations on these functions
with regard to a lack of a threshold. EPA
will therefore consider a different
approach in this review.
In considering these risk estimates,
EPA is mindful of CASAC’s
recommendation regarding the public
health significance of a population loss
of 1 to 2 IQ points, the significant
implications of potential shifts in the
distribution of IQ for the exposed
population, and other unquantified Pbrelated health effects. Based on these
factors and the range of estimates
summarized above for IQ loss associated
with policy-relevant Pb for the current
conditions scenarios of the locationspecific case studies, we recognize that
some may consider reducing the
NAAQS as important from a public
health perspective (from air-related
ambient Pb) relative to that afforded by
the current standard.
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In considering the public health
significance of IQ loss beyond CASAC’s
recommendation on this issue, we note
that some may consider that any IQ loss
at the population level is of potential
public health significance. That is, there
is no amount of IQ loss at the
population level that is clearly
recognized as being of no importance
from a public health perspective. On the
other hand, we also recognize that some
may hold different views. Thus, the
magnitude of IQ loss that could be
allowed by a standard that protects
public health with an adequate margin
of safety is clearly a public health policy
judgment to be made by the
Administrator.
In considering the magnitudes of IQ
loss estimated in our assessment for the
lowest alternative levels considered,
EPA will focus on total IQ loss and on
the contribution to total IQ loss from
policy-relevant pathways. In so doing,
we recognize that nonair contributions
to total Pb-related IQ loss are estimated
to reach and exceed an IQ loss of 1–2
points, and we also recognize that air Pb
contributions are generally of a much
smaller magnitude. Thus, we recognize
that it may be appropriate to consider
smaller estimates of IQ loss from air Pb
contributions (e.g., less than 1 point IQ
loss) in identifying the appropriate
target for the policy-relevant
component.
Placing weight on incremental
changes in policy-relevant Pb-related IQ
loss of less than one point IQ would
lead to consideration of the lower
standard levels evaluated in the risk
assessment as part of a judgment as to
what standard would protect public
health with an adequate margin of
safety. EPA recognizes, however, the
significant uncertainties in the
quantitative risk estimates and that
uncertainty in the estimates increases
with increasing difference of the air
quality scenarios from current
conditions. Thus, to the extent that
incremental exposure reductions
achieved through lowering the NAAQS
might contribute to incremental
reductions in children’s blood Pb and to
associated reductions in health effects,
consideration of NAAQS levels below
0.1 µg/m3 (e.g., the lower levels
included in the risk assessment of 0.02
and 0.05 µg/m3) may be appropriate. On
the other hand, to the extent that the
uncertainties and limitations in the
exposure and risk assessments are
judged to be so great as to prevent
meaningful conclusions from being
drawn for these low alternative standard
levels, consideration of such low levels
may not be appropriate.
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If the policy goal for the Pb NAAQS
was to be defined, for example, so as to
provide protection that limited
estimates of IQ loss from policy-relevant
exposures to no more than 1–2 points IQ
loss at the population-level, EPA notes
that standard levels in the range of 0.1
to 0.2 µg/m3 may achieve that goal. We
also note that even with lower levels of
the standard evaluated, while the range
of policy-relevant IQ loss estimates is
lower, the upper end of the range still
extends up to and in some cases above
1 point IQ loss. We note, however,
appreciably greater uncertainty
associated with these estimates that
increases with increasing difference of
the alternative standards from current
conditions.
Alternatively, if the policy goal was to
be defined so as to provide somewhat
greater public health protection by
limiting the air-related component of
risk to somewhat less than 1 point IQ
loss at the population level, this would
suggest greater consideration for
standards in the lower part of the range
evaluated (0.02–0.05 µg/m3). Such a
goal might reflect recognition that
nonair sources, in and of themselves,
are estimated to contribute 1–2 points or
more of IQ loss, such that the
incremental risk for policy-relevant Pb
is adding to a level of total Pb exposure
that is already in a range that can be
reasonably judged to be highly
significant from a public health
perspective. We note, however that
considering standards in this lower
range places greater weight on the more
highly uncertain risk estimates and thus
would be more precautionary in nature.
iii. CASAC Advice and
Recommendations
Beyond the evidence- and risk/
exposure-based information discussed
above, EPA’s consideration of the level
for the NAAQS will also take into
account the advice and
recommendations of CASAC, based on
their review of the Criteria Document
and drafts of the Staff Paper and the
related technical support document, as
well as comments from the public on
drafts of the Staff Paper and related
technical support document. Public
comments pertaining to the level of the
standard recommended appreciable
reductions in the level, e.g., setting it at
0.2 µg/m3 or less.
In their advice to the Agency during
this review CASAC has recognized the
importance of both the health effects
evidence and the exposure and risk
information in selecting the level for the
standard (Henderson, 2007a,b). In two
separate letters, CASAC has stated that
it is the unanimous judgement of the
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CASAC Lead Panel that the primary
NAAQS should be ‘‘substantially
lowered’’ to ‘‘a level of about 0.2 µg/m3
or less’’, reflecting their view of the
health effects evidence (Henderson,
2007a,b). In their March 2007 letter
conveying comments on the pilot phase
risk assessment, CASAC based their
recommendation as to level on
consideration of the health effects
evidence they provided initial
recommendations that the level should
be substantially lower, reflecting their
view of the evidence itself.
The CASAC Pb Panel also provided
advice regarding how the Agency
should consider IQ loss estimates
derived from the risk assessment in
selecting a level for the standard. The
Panel stated that they consider a
population loss of 1–2 IQ points to be
‘‘highly significant from a public health
perspective.’’ Further they
recommended that ‘‘the primary Pb
standard should be set so as to protect
99.5% of the population from exceeding
that IQ loss.’’ The Agency anticipates
further advice from CASAC with regard
to level at the time of their review of this
ANPR.
iv. Policy Options
In considering alternative levels of the
primary Pb standard, EPA will consider
the health effects evidence and the
exposure and risk assessment, as well as
the important uncertainties and
limitations in the evidence and the
assessment results. To help inform
public health policy judgments, we
specifically solicit comment on levels of
IQ loss considered to be significant from
a public health perspective.
Additionally, we solicit comment on the
magnitude of IQ loss associated with
exposures to ambient Pb by the
pathways categorized as ‘‘recent air’’ in
the risk assessment described in this
notice that are considered to be
significant from a public health
perspective. We also solicit comment on
the approach of adopting a public health
policy goal of limiting policy-relevant
air exposure such that the incremental
blood Pb level (and the associated
resulting IQ loss) are below a specified
level (e.g., to a magnitude of 0.5 or 1 µg/
dL, or other alternative values).
The EPA takes note of the views of
CASAC on these matters, summarized
above, the conclusions and
recommendations in the OAQPS Staff
Paper,75 and the views of public
commenters. We also note other views,
75 The OAQPS Staff Paper recommends
consideration of a range of alternative standard
levels from as high as 0.1 to 0.2 µg/m3 down to the
lower levels evaluated in the risk assessment of 0.02
to 0.05 µg/m3.
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including retaining the current standard
level or a range of alternative levels that
includes the upper end of the
alternative standards considered in the
risk assessment (i.e., 0.5 µg/m3 as a
maximum monthly average). The EPA
recognizes that there may be differing
interpretations of the available
evidence, the public health significance
of various changes in population IQ
loss, and various aspects of the evidence
and exposure and risk assessments,
including important uncertainties and
limitations associated with the evidence
and assessments. Thus, EPA solicits
comment on the range of alternative
standard levels identified above, as well
as on other alternative levels, up to and
including the current level, and the
rationale upon which such views are
based.
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IV. The Secondary Standard
This section presents information
relevant to the review of the secondary
Pb NAAQS, including information on
the welfare effects associated with Pb
exposures, results of the screening-level
ecological risk assessment, and
considerations related to evaluating the
adequacy of the current standard and
alternative standards that might be
appropriate for the Administrator to
consider.
A. Welfare Effects Information
Welfare effects addressed by the
secondary NAAQS include, but are not
limited to, effects on soils, water, crops,
vegetation, manmade materials,
animals, wildlife, weather, visibility and
climate, damage to and deterioration of
property, and hazards to transportation,
as well as effects on economic values
and on personal comfort and well-being.
A qualitative assessment of welfare
effects evidence related to ambient Pb is
summarized in this section, drawing
from Chapter 6 of the Staff Paper. The
presentation here first recognizes
several key aspects of the welfare
evidence for Pb. Lead is persistent in the
environment and accumulates in soils,
aquatic systems (including sediments),
and some biological tissues of plants,
animals and other organisms, thereby
providing long-term, multipathway
exposures to organisms and ecosystems.
Additionally, EPA recognizes that there
have been a number of uses of Pb,
especially as an ingredient in
automobile fuel but also in other
products such as paint, lead-acid
batteries, and some pesticides, which
have significantly contributed to
widespread increases in Pb
concentrations in the environment, a
portion of which remains today (e.g.,
CD, Chapters 2 and 3).
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Ecosystems near smelters, mines and
other industrial sources of Pb have
demonstrated a wide variety of adverse
effects including decreases in species
diversity, loss of vegetation, changes to
community composition, decreased
growth of vegetation, and increased
number of invasive species.
Apportioning these effects between Pb
and other stressors is complicated
because these point sources also emit a
wide variety of other heavy metals and
sulfur dioxide which may cause toxic
effects. There are no field studies which
have investigated effects of Pb additions
alone but some studies near large point
sources of Pb have found significantly
reduced species composition and
altered community structures. While
these effects are significant, they are
spatially limited: The majority of
contamination occurs within 20 to 50
km of the emission source (CD,
AX7.1.4.2).
By far, the majority of Pb found in
terrestrial ecosystems was deposited in
the past during the use of Pb additives
in gasoline. This gasoline-derived Pb
was emitted predominantly in small
size particles which were widely
dispersed and transported across large
distances. Many sites receiving Pb
predominantly through such long-range
transport have accumulated large
amounts of Pb in soils (CD, p.l AX7–98).
There is little evidence that terrestrial
sites exposed as a result of this long
range transport of Pb have experienced
significant effects on ecosystem
structure or function (CD, AX7.1.4.2, p.
AX7–98). Strong complexation of Pb by
soil organic matter may explain why
few ecological effects have been
observed (CD, p. AX7–98). Studies have
shown decreasing levels of Pb in
vegetation which seems to correlate
with decreases in atmospheric
deposition of Pb resulting from the
removal of Pb additives to gasoline (CD,
AX7.1.4.2).
Terrestrial ecosystems remain
primarily sinks for Pb but amounts
retained in various soil layers vary
based on forest type, climate, and litter
cycling (CD, Section 7.1). Once in the
soil, the migration and distribution of
Pb is controlled by a multitude of
factors including pH, precipitation,
litter composition, and other factors
which govern the rate at which Pb is
bound to organic materials in the soil
(CD, Section 2.3.5).
Like most metals the solubility of Pb
is increased at lower pH. However, the
reduction of pH may in turn decrease
the solubility of dissolved organic
material (DOM). Given the close
association between Pb mobility and
complexation with DOM, a reduced pH
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does not necessarily lead to increased
movement of Pb through terrestrial
systems and into surface waters. In areas
with moderately acidic soil (i.e., pH of
4.5 to 5.5) and abundant DOM, there is
no appreciable increase in the
movement of Pb into surface waters
compared to those areas with neutral
soils (i.e., pH of approximately 7.0).
This appears to support the theory that
the movement of Pb in soils is limited
by the solubilization and transport of
DOM. In sandy soils without abundant
DOM, moderate acidification appears
likely to increase outputs of Pb to
surface waters (CD, AX7.1.4.1).
Lead exists in the environment in
various forms which vary widely in
their ability to cause adverse effects on
ecosystems and organisms. Current
levels of Pb in soil also vary widely
depending on the source of Pb but in all
ecosystems Pb concentrations exceed
natural background levels. The
deposition of gasoline-derived Pb into
forest soils has produced a legacy of
slow moving Pb that remains bound to
organic materials despite the removal of
Pb from most fuels and the resulting
dramatic reductions in overall
deposition rates. For areas influenced by
point sources of air Pb, concentrations
of Pb in soil may exceed by many orders
of magnitude the concentrations which
are considered harmful to laboratory
organisms. Adverse effects associated
with Pb include neurological,
physiological and behavioral effects
which may influence ecosystem
structure and functioning. Ecological
soil screening levels (Eco-SSLs) have
been developed for Superfund site
characterizations to indicate
concentrations of Pb in soils below
which no adverse effects are expected to
plants, soil invertebrates, birds and
mammals. Values like these may be
used to identify areas in which there is
the potential for adverse effects to any
or all of these receptors based on current
concentrations of Pb in soils.
Atmospheric Pb enters aquatic
ecosystems primarily through the
erosion and runoff of soils containing Pb
and deposition (wet and dry). While
overall deposition rates of atmospheric
Pb have decreased dramatically since
the removal of Pb additives from
gasoline, Pb continues to accumulate
and may be re-exposed in sediments
and water bodies throughout the United
States (CD, Section 2.3.6).
Several physical and chemical factors
govern the fate and bioavailability of Pb
in aquatic systems. A significant portion
of Pb remains bound to suspended
particulate matter in the water column
and eventually settles into the substrate.
Species, pH, salinity, temperature,
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turbulence and other factors govern the
bioavailability of Pb in surface waters
(CD, Section 7.2.2).
Lead exists in the aquatic
environment in various forms and under
various chemical and physical
parameters which determine the ability
of Pb to cause adverse effects either
from dissolved Pb in the water column
or Pb in sediment. Current levels of Pb
in water and sediment also vary widely
depending on the source of Pb.
Conditions exist in which adverse
effects to organisms and thereby
ecosystems may be anticipated given
experimental results. It is unlikely that
dissolved Pb in surface water
constitutes a threat to ecosystems that
are not directly influenced by point
sources. For Pb in sediment, the
evidence is less clear. It is likely that
some areas with long-term historical
deposition of Pb to sediment from a
variety of sources as well as areas
influenced by point sources have the
potential for adverse effects to aquatic
communities. The long residence time
of Pb in sediment and its ability to be
resuspended by turbulence make Pb
likely to be a factor for the foreseeable
future. Criteria have been developed to
indicate concentrations of Pb in water
and sediment below which no adverse
effects are expected to aquatic
organisms. These values may be used to
identify areas in which there is the
potential for adverse effects to receptors
based on current concentrations of Pb in
water and sediment.
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B. Screening Level Ecological Risk
Assessment
This section presents a brief summary
of the screening-level ecological risk
assessment conducted by EPA for this
review. The assessment is described in
detail in Lead Human Exposure and
Health Risk Assessments and Ecological
Risk Assessment for Selected Areas,
Pilot Phase (ICF, 2006). Funding
constraints have precluded performance
of a full-scale ecological risk
assessment. The discussion here is
focused on the screening level
assessment performed in the pilot phase
(ICF, 2006) and takes into consideration
CASAC recommendations with regard
to interpretation of this assessment
(Henderson, 2007a, b). The following
summary focuses on key features of the
approach used in the assessment and
presents only a brief summary of the
results of the assessment. A complete
presentation of results is provided in the
pilot phase Risk Assessment Report
(ICF, 2006) and summarized in Chapter
6 of the Staff Paper.
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1. Design Aspects of Assessment and
Associated Uncertainties
The screening level risk assessment
involved several location-specific case
studies and a national-scale surface
water and sediment screen. The case
studies included areas surrounding a
primary Pb smelter and a secondary Pb
smelter, as well as a location near a
nonurban roadway. An additional case
study for an ecologically vulnerable
location was identified and described
(ICF, 2006), but resource constraints
have precluded risk analysis for this
location.
The case study analyses were
designed to estimate the potential for
ecological risks associated with
exposures to Pb emitted into ambient
air. Soil, surface water, and/or sediment
concentrations were estimated from
available monitoring data or modeling
analysis, and then compared to
ecological screening benchmarks to
assess the potential for ecological
impacts from Pb that was emitted into
the air. Results of these comparisons are
not definitive estimates of risk, but
rather serve to identify those locations
at which there is the greatest likelihood
for adverse effect. Similarly, the
national-scale screening assessment
evaluated surface water and sediment
monitoring locations across the United
States for the potential for ecological
impacts associated with atmospheric
deposition of Pb. The reader is referred
to the pilot phase Risk Assessment
Report (ICF, 2006) for details on the use
of this information and models in the
screening assessment.
The measures of exposure for these
analyses are total Pb concentrations in
soil, dissolved Pb concentrations in
fresh surface waters (water column), and
total Pb concentrations in freshwater
sediments. The hazard quotient (HQ)
approach was then used to compare Pb
media concentrations with ecological
screening values. The exposure
concentrations were estimated for the
three case studies and the national-scale
screening analyses as described below:
• For the primary Pb smelter case
study, measured concentrations of total
Pb in soil, dissolved Pb in surface
waters, and total Pb in sediment were
used to develop point estimates for
sampling clusters thought to be
associated with atmospheric Pb
deposition, rather than Pb associated
with nonair sources, such as runoff from
waste storage piles.
• For the secondary Pb smelter case
study, concentrations of Pb in soil were
estimated using fate and transport
modeling based on EPA’s MPE
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methodology (USEPA, 1998) and data
available from similar locations.
• For the near roadway nonurban
case study, measured soil concentration
data collected from two interstate
sampling locations, one with fairly highdensity development (Corpus Christi,
Texas) and another with mediumdensity development (Atlee, Virginia),
were used to develop estimates of Pb in
soils for each location.
• For the national-scale surface water
and sediment screening analyses,
measurements of dissolved Pb
concentrations in surface water and
total Pb in sediment for locations across
the United States were compiled from
available databases (USGS, 2004). Air
emissions, surface water discharge, and
land use data for the areas surrounding
these locations were assessed to identify
locations where atmospheric Pb
deposition may be expected to
contribute to potential ecological
impacts. The exposure assessment
focused on these locations.
The ecological screening values used
in this assessment were developed from
the Eco-SSLs methodology, EPA’s
recommended ambient water quality
criteria, and sediment screening values
developed by MacDonald and others
(2000, 2003). Soil screening values were
derived for this assessment using the
Eco-SSL methodology with the toxicity
reference values for Pb (USEPA, 2005d,
2005e) and consideration of the inputs
on diet composition, food intake rates,
incidental soil ingestion, and
contaminant uptake by prey (details are
presented in Section 7.1.3.1 and
Appendix L, of ICF, 2006). Hardnessspecific surface water screening values
were calculated for each site based on
EPA’s recommended ambient water
quality criteria for Pb (USEPA, 1984).
For sediment screening values, the
assessment relied on sediment
‘‘threshold effect concentrations’’ and
‘‘probable effect concentrations’’
developed by MacDonald et al. (2000).
The methodology for these sediment
criteria is described more fully in
section 7.1.3.3 and Appendix M of the
pilot phase Risk Assessment Report
(ICF, 2006).
The HQ is calculated as the ratio of
the media concentration to the
ecotoxicity screening value, and
represented by the following equation:
HQ = (estimated Pb media
concentration) / (ecotoxicity
screening value)
For each case study, HQ values were
calculated for each location where
either modeled or measured media
concentrations were available. Separate
soil HQ values were calculated for each
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ecological receptor group for which an
ecotoxicity screening value has been
developed (i.e., birds, mammals, soil
invertebrates, and plants). HQ values
less than 1.0 suggest that Pb
concentrations in a specific medium are
unlikely to pose significant risks to
ecological receptors. HQ values greater
than 1.0 indicate that the expected
exposure exceeds the ecotoxicity
screening value and that there is a
potential for adverse effects.
There are several uncertainties that
apply across case studies noted below:
• The ecological risk screen is limited
to specific case study locations and
other locations for which dissolved Pb
data were available and evaluated in the
national-scale surface water and
sediment screens. In identifying sites for
inclusion in the assessment, efforts were
made to ensure that the Pb exposures
assessed were attributable to airborne Pb
and not dominated by nonair sources.
However, there is uncertainty as to
whether other sources might have
actually contributed to the Pb exposure
estimates.
• A limitation to using the selected
ecotoxicity screening values is that they
might not be sufficient to identify risks
to some threatened or endangered
species or unusually sensitive aquatic
ecosystems (e.g., CD, p. AX7–110).
• The methods and database from
which the surface water screening
values (i.e., the AWQC for Pb) were
derived is somewhat dated. New data
and approaches (e.g., use of pH as
indicator of bioavailability) may now be
available to estimated the aquatic
toxicity of Pb (CD, Sections AX7.2.1.2
and AX7.2.1.3).
• No adjustments were made for
sediment-specific characteristics that
might affect the bioavailability of Pb in
sediments in the derivation of the
sediment quality criteria used for this
ecological risk screen (CD, Sections
7.2.1 and AX7.2.1.4; Appendix M, ICF,
2006). Similarly, characteristics of soils
for the case study locations were not
evaluated for measures of
bioavailability.
• Although the screening value for
birds used in this analysis is based on
reasonable estimates for diet
composition and assimilation efficiency
parameters, it was based on a
conservative estimate of the relative
bioavailability of Pb in soil and natural
diets compared with water soluble Pb
added to an experimental pellet diet
(Appendix L, ICF, 2006).
2. Summary of Results
The following is a brief summary of
key observations related to the results of
the screening-level ecological risk
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assessment. A more complete
discussion of the results is provided in
Chapter 6 of the Staff Paper and the
complete presentation of the assessment
and results is presented in the pilot
phase Risk Assessment Report (ICF,
2006).
• The national-scale screen of surface
water data initial identified some 42
sample locations of which 15 were then
identified as unrelated to mining sites
and having water column levels of
dissolved Pb that were greater than
hardness adjusted chronic criteria for
the protection of aquatic life (with one
location having a HQ of 15), indicating
a potential for adverse effect if
concentrations were persistent over
chronic periods. Acute criteria were not
exceeded at any of these locations. The
extent to which air emissions of Pb have
contributed to these surface water Pb
concentrations is unclear.
• In the national-scale screen of
sediment data associated with the 15
surface water sites described above,
threshold effect concentration-based
HQs at nine of these sites exceeded 1.0.
Additionally, HQs based on probable
effect concentrations exceeded 1.0 at
five of the sites, indicating probable
adverse effects to sediment dwelling
organisms. Thus, sediment Pb
concentrations at some sites are high
enough that there is a likelihood that
they would cause adverse effects to
sediment dwelling organisms. However,
the contribution of air emissions to
these concentrations is unknown.
• In the primary Pb smelter case
study, all three of the soil sampling
clusters (including the ‘‘reference
areas’’) had HQs that exceeded 1.0 for
birds. Samples from one cluster also had
HQs greater than 1.0 for plants and
mammals. The surface water sampling
clusters all had measurements below the
detection limit of 3.0 µg/L. However,
three sediment sample clusters had HQs
greater than 1.0. In summary, the
concentrations of Pb in soil and
sediments exceed screening values for
these media indicating potential for
adverse effects to terrestrial organisms
(plants, birds and mammals) and to
sediment dwelling organisms. While the
contribution to these Pb concentrations
from air as compared to nonair sources
is not quantified, air emissions from this
facility are substantial (see Appendix D,
USEPA 2007b; ICF 2006).
• In the secondary Pb smelter case
study, the soil concentrations,
developed from soil data for similar
locations, resulted in avian HQs greater
than 1.0 for all distance intervals
evaluated. The scaled soil
concentrations within 1 km of the
facility also showed HQs greater than
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1.0 for plants, birds, and mammals.
These estimates indicate a potential for
adverse effect to those receptor groups.
• In the nonurban, near roadway case
study, HQs for birds and mammals were
greater than 1.0 at all but one of the
distances from the road. Plant HQs were
greater than 1.0 at the closest distance.
In summary, HQs above one were
estimated for plants, birds and
mammals, indicating potential for
adverse effect to these receptor groups.
C. Considerations in Review of the
Standard
This section presents an integrative
synthesis of information in the Criteria
Document together with EPA analyses
and evaluations. EPA notes that the
final decision on retaining or revising
the current secondary Pb standard is a
public policy judgment to be made by
the Administrator. The Administrator’s
final decision will draw upon scientific
information and analyses about welfare
effects, exposure and risks, as well as
judgments about the appropriate
response to the range of uncertainties
that are inherent in the scientific
evidence and analyses.
The NAAQS provisions of the Act
require the Administrator to establish
secondary standards that, in the
judgment of the Administrator, are
requisite to protect the public welfare
from any known or anticipated adverse
effects associated with the presence of
the pollutant in the ambient air. In so
doing, the Administrator seeks to
establish standards that are neither more
nor less stringent than necessary for this
purpose. The Act does not require that
secondary standards be set to eliminate
all risk of adverse welfare effects, but
rather at a level requisite to protect
public welfare from those effects that
are judged by the Administrator to be
adverse.
The following discussion starts with
background information on the current
standard (Section IV.C.1). The general
approach for this current review is
summarized in Section IV.C.2.
Considerations with regard to the
adequacy of the current standard are
discussed in section IV.C.3, with
evidence and exposure-risk-based
considerations in subsections IV.C.3.a
and b, respectively, followed by a
summary of CASAC advice and
recommendations (section IV.C.3.c) and,
lastly, solicitation of comment on the
broad range of policy options (section
IV.C.3.d). Considerations with regard to
elements of alternative standards are
discussed in Section IV.C.4.
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1. Background on the Current Standard
The current standard was set in 1978
to be identical to the primary standard
(1.5 µg Pb/m3, as a maximum arithmetic
mean averaged over a calendar quarter),
the basis for which is summarized in
Section III.C.1. At the time the standard
was set, the Agency concluded that the
primary air quality standard would
adequately protect against known and
anticipated adverse effects on public
welfare, as the Agency stated that it did
not have evidence that a more restrictive
secondary standard was justified. In the
rationale for this conclusion, the Agency
stated that the available evidence cited
in the 1977 Criteria Document indicated
that ‘‘animals do not appear to be more
susceptible to adverse effects from lead
than man, nor do adverse effects in
animals occur at lower levels of
exposure than comparable effects in
humans’’ (43 FR 46256). The Agency
recognized that Pb may be deposited on
the leaves of plants and present a hazard
to grazing animals. With regard to
plants, the Agency stated that Pb is
absorbed but not accumulated to any
great extent by plants from soil, and that
although some plants may be
susceptible to Pb, it is generally in a
form that is largely nonavailable to
them. Further the Agency stated that
there was no evidence indicating that
ambient levels of Pb result in significant
damage to manmade materials and Pb
effects on visibility and climate are
minimal.
The secondary standard was
subsequently considered during the
1980s in development of the 1986
Criteria Document (USEPA, 1986a) and
the 1990 Staff Paper (USEPA, 1990). In
summarizing OAQPS staff conclusions
and recommendations at that time, the
1990 Staff Paper stated that a qualitative
assessment of available field studies and
animal toxicological data suggested that
‘‘domestic animals and wildlife are as
susceptible to the effects of lead as
laboratory animals used to investigate
human lead toxicity risks.’’ Further, the
1990 Staff Paper highlighted concerns
over potential ecosystem effects of Pb
due to its persistence, but concluded
that pending development of a stronger
database that more accurately quantifies
ecological effects of different Pb
concentrations, consideration should be
given to retaining a secondary standard
at or below the level of the then-current
secondary standard of 1.5 µg/m3.
2. Approach for Current Review
To evaluate whether it is appropriate
to consider retaining the current
secondary Pb standard, or whether
consideration of revisions is
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appropriate, EPA is considering an
approach in this review like that used
in the Staff Paper that considers the
evidence and risk analyses. This
approach recognizes that the available
welfare effects evidence generally
reflects laboratory-based evidence of
toxicological effects on specific
organisms exposed to concentrations of
Pb at which scientists generally agree
that adverse effects are likely to occur.
It is widely recognized, however, that
environmental exposures are likely to be
at lower concentrations and/or
accompanied by significant
confounding factors (e.g., other metals,
acidification), which increases our
uncertainty about the likelihood and
magnitude of the organism and
ecosystem response.
3. Adequacy of the Current Standard
a. Evidence-Based Considerations
In considering the welfare effects
evidence with respect to the adequacy
of the current standard, EPA will
consider not only the array of evidence
newly assessed in the Criteria Document
but also that assessed in the 1986
Criteria Document and summarized in
the 1990 Staff Paper. As discussed
extensively in the latter two documents,
there was a significantly improved
characterization of environmental
effects of Pb in the ten years after the Pb
NAAQS was set. And, in the subsequent
nearly 20 years, many additional studies
on Pb effects in the environment are
now available (2006 Criteria Document).
Some of the more relevant aspects of the
evidence available since the standard
was set include the following:
• A more quantitative determination
of the mobility, distribution, uptake,
speciation, and fluxes of
atmospherically delivered Pb in
terrestrial ecosystems shows that the
binding of Pb to organic materials in the
soil slows its mobility through soil and
may prevent uptake by plants (CD,
Sections 7.1.2, 7.1.5, AX7.1.4.1,
AX7.1.4.2, AX7.1.4.3 and AX7.1.2 ).
Therefore, while atmospheric
deposition of Pb has decreased, Pb may
be more persistent in some ecosystems
than others and may remain in the
active zone of the soil, where exposure
may occur, for decades (CD, Sections
7.1.2, AX7.1.2 and AX7.1.4.3).
• Plant toxicity may occur at lower
levels than previously identified as
determined by data considered in
development of Eco-SSLs (CD, pp. 7–11
to 7–12, AX7–16 and Section
AX7.1.3.2), although the range of
reported soil Pb effect levels is large
(tens to thousands of mg/kg soil).
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• Avian and mammalian toxicity may
occur at lower levels than those
previously identified, although the
range of Pb effect levels is large (<1 to
>1,000 mg Pb/kg bw-day) (CD, p. 7–12,
Section AX7.1.3.3).
• There is an expanded
understanding of the fate and effects of
Pb in aquatic ecosystems and of the
distribution and concentrations of Pb in
surface waters throughout the United
States (CD, Section AX7.2.2).
• New methods for assessing the
toxicity of metals to water column and
sediment-dwelling organisms and data
collection efforts (CD, Sections 7.2.1,
7.2.2, AX7.2.2, and AX7.2.2.2) have
improved our understanding of Pb
aquatic toxicity and findings include an
indication that in some estuarine
systems Pb deposited during historic
usage of leaded gasoline may remain in
surface sediments for decades. (CD, p.
7–23).
• A larger dataset of aquatic species
assessed with regard to Pb toxicity, and
findings of lower effect levels for
previously untested species (CD, p.
AX7–176 and Section AX7.2.4.3).
• Currently available studies have
also shown effects on community
structure, function and primary
productivity, although some
confounders (such as co-occurring
pollutants) have not been well
addressed (CD, Section AX7.1.4.2).
• Evidence in ecological research
generally indicates the value of a critical
loads approach; however, current
information on Pb critical loads is
lacking for many processes and
interactions involving Pb in the
environment and work is ongoing (CD,
Section 7.3).
Given the full body of current
evidence, despite wide variations in Pb
concentrations in soils throughout the
country, Pb concentrations are likely in
excess of concentrations expected from
geologic or other non-anthropogenic
forces. In particular, the deposition of
gasoline-derived Pb into forest soils has
produced a legacy of slow moving Pb
that remains bound to organic materials
despite the removal of Pb from most
fuels and the resulting dramatic
reductions in overall deposition rates
(CD, Section AX7.1.4.3). For areas
influenced by point sources of air Pb
that meet the current standard,
concentrations of Pb in soil may exceed
by many orders of magnitude the
concentrations which are considered
harmful to laboratory organisms (CD,
Section 3.2 and AX7.1.2.3).
There are several difficulties in
quantifying the role of current ambient
Pb in the environment: Some Pb
deposited before the standard was
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enacted is still present in soils and
sediments; historic Pb from gasoline
continues to move slowly through
systems as does current Pb derived from
both air and nonair sources.
Additionally, the evidence of adversity
in natural systems is very sparse due in
no small part to the difficulty in
determining the effects of confounding
factors such as multiple metals or
factors influencing bioavailability in
field studies. However, the evidence
summarized above and in Section 4.2 of
the Staff Paper and described in detail
in the Criteria Document informs our
understanding of Pb in the environment
today and evidence of environmental Pb
exposures of potential concern.
Conditions exist in which Pbassociated adverse effects to aquatic
organisms and thereby ecosystems may
be anticipated given experimental
results. While the evidence does not
indicate that dissolved Pb in surface
water constitutes a threat to those
ecosystems that are not directly
influenced by point sources, the
evidence regarding Pb in sediment is
less clear (CD, Sections AX7.2.2.2.2 and
AX7.2.4). It is likely that some areas
with long term historical deposition of
Pb to sediment from a variety of sources
as well as areas influenced by point
sources have the potential for adverse
effects to aquatic communities. The long
residence time of Pb in sediment and its
ability to be resuspended by turbulence
make Pb contamination likely to be a
factor for the foreseeable future. Based
on this information, the Staff Paper
concluded that the evidence suggests
that the environmental levels of Pb
occurring under the current standard,
set nearly thirty years ago, may pose risk
of adverse environmental effect.
b. Risk-based Considerations
In addition to the evidence-based
considerations described in the previous
section, the screening level ecological
risk assessment is informative, taking
into account key limitations and
uncertainties associated with the
analyses.
The screening level risk assessment
involved a comparison of estimates of
environmental media concentrations of
Pb to ecological screening levels to
assess the potential for ecological
impacts from Pb that was emitted into
the air. Results of these comparisons are
not considered to be definite predictors
of risk, but rather serve to identify those
locations at which there is greatest
likelihood for adverse effect. Similarly,
the national-scale screening assessment
evaluated the potential for ecological
impacts associated with the atmospheric
deposition of Pb released into ambient
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air at surface water and sediment
monitoring locations across the United
States.
The ecological screening levels
employed in the screening level risk
assessment for different media are
drawn from different sources.
Consequently there are somewhat
different limitations and uncertainties
associated with each. In general, their
use here recognizes their strength in
identifying media concentrations with
the potential for adverse effect and their
relative nonspecificity regarding the
magnitude of risk of adverse effect.
As discussed in the previous section,
as a result of its persistence, Pb emitted
in the past remains today in aquatic and
terrestrial ecosystems of the United
States. Consideration of the
environmental risks associated with the
current standard is complicated by the
environmental burden associated with
air Pb concentrations that exceeded the
current standard, predominantly in the
past.
Concentrations of Pb in soil and
sediments associated with the primary
Pb smelter case study exceeded
screening values for those media
indicating potential for adverse effect in
terrestrial organisms (plants, birds and
mammals) and in sediment dwelling
organisms. While the contribution to
these Pb concentrations from air as
compared to nonair sources has not
been quantified, air emissions from this
facility are substantial (see Appendix D,
USEPA 2007b; ICF 2006). Additionally,
estimates of Pb concentration in soils
associated with the nonurban near
roadway case study and the secondary
Pb smelter case study were also
associated with HQs above 1 for plants,
birds and mammals, indicating potential
for adverse effect to those receptor
groups. The industrial facility in the
secondary Pb smelter case study is
much younger than the primary Pb
smelter and apparently became active
less than ten years prior to the
establishment of the current standard.
The national-scale screens, which are
not focused on particular point source
locations, indicate the ubiquitous nature
of Pb in aquatic systems of the United
States today. Further the magnitude of
Pb concentrations in several aquatic
systems exceeded screening values. In
the case of the national-scale screen of
surface water data, 15 locations were
identified with water column levels of
dissolved Pb that were greater than
hardness adjusted chronic criteria for
the protection of aquatic life (with one
location having a HQ as high as 15),
indicating a potential for adverse effect
if concentrations were persistent over
chronic periods. Further, sediment Pb
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concentrations at some sites in the
national-scale screen were high enough
that the likelihood that they would
cause adverse effects to sediment
dwelling organisms may be considered
‘‘probable’’.
A complicating factor in interpreting
the findings for the national-scale
screening assessments is the lack of
clear apportionment of Pb contributions
from air as compared to nonair sources,
such as industrial and municipal
discharges. While the contribution of air
emissions to the elevated concentrations
has not been quantified, documentation
of historical trends in the sediments of
many water bodies has illustrated the
sizeable contribution that airborne Pb
can have on aquatic systems (e.g.,
Section 2.8.1). This documentation also
indicates the greatly reduced
contribution in many systems as
compared to decades ago (presumably
reflecting the banning of Pb-additives
from gasoline used by cars and trucks).
However, the timeframe for removal of
Pb from surface sediments into deeper
sediment varies across systems, such
that Pb remains available to biological
organisms in some systems for much
longer than in others (Section 2.8, CD,
pages AX7–141 to AX7–145).
The case study locations included in
the screening assessment, with the
exception of the primary Pb smelter site,
are currently meeting the current Pb
standard, yet Pb occurs in some
locations at concentrations, particularly
in soil, and aquatic sediment above the
screening levels, indicative of a
potential for harm to some terrestrial
and sediment dwelling organisms.
While the role of airborne Pb in
determining these Pb concentrations is
unclear, the historical evidence
indicates that airborne Pb can create
such concentrations in sediments and
soil. Further, environmental
concentrations may be related to
emissions prior to establishment of the
current standard and such
concentrations appear to indicate a
potential for harm to ecological
receptors today.
c. CASAC Advice and
Recommendations
In the CASAC letter transmitting
advice and recommendations pertaining
to the review of the first draft Staff
Paper and draft Pb Exposure and Risk
Assessments, the CASAC Pb panel
provided recommendations regarding
the need for a Pb NAAQS, and the
adequacy of the current Pb NAAQS, as
well as comments on the draft
documents. With regard to the need for
a Pb NAAQS and adequacy of the
current NAAQS, the CASAC letter said:
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The unanimous judgment of the Lead
Panel is that lead should not be delisted as
a criteria pollutant, as defined by the Clean
Air Act, for which primary (public health
based) and secondary (public welfare based)
NAAQS are established, and that both the
primary and secondary NAAQS should be
substantially lowered.
Specifically with regard to the
secondary NAAQS, the CASAC Pb
Panel stated that the December 2006
draft documents presented ‘‘compelling
scientific evidence that current
atmospheric Pb concentrations and
deposition—combined with a large
reservoir of historically deposited Pb in
soils, sediments and surface waters—
continue to cause adverse
environmental effects in aquatic and/or
terrestrial ecosystems, especially in the
vicinity of large emissions sources.’’ The
Panel went on to state that ‘‘These
effects persist in some cases at locations
where current airborne lead
concentrations are below the level of the
current primary and secondary lead
standards’’ and ‘‘Thus, from an
environmental perspective, there are
convincing reasons to both retain lead
as a regulated criteria air pollutant and
to lower the level of the current
secondary standard.’’
In making this recommendation, the
CASAC Pb Panel also cites the
persistence of Pb in the environment,
the possibility of some of the large
amount of historically deposited Pb
becoming resuspended by natural
events, and the expectation that humans
are not uniquely sensitive among the
many animal and plant species in the
environment. In summary, with regard
to the recommended level of a revised
secondary standard, the CASAC panel
stated that:
Therefore, at a minimum, the level of the
secondary Lead NAAQS should be at least as
low as the lowest-recommended primary lead
standard.
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CASAC provided further advice and
recommendations on the Agency’s
consideration of the secondary standard
in this review in their letter of
September 2007 (Henderson, 2007b). In
that letter they recognized the role of the
secondary standard in influencing the
long-term environmental burden of Pb
and a need for environmental
monitoring to assess the success of the
standard in this role.
d. Policy Options
In considering the adequacy of the
current secondary standard, EPA will
consider, for reasons discussed above in
III.C.3.d on the primary standard,
whether it is appropriate to maintain a
NAAQS for Pb or to retain Pb on the list
of criteria pollutants. We take note of
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the views of CASAC, summarized
above, the conclusions and
recommendations in the OAQPS Staff
Paper, and the views of public
commenters on these questions. We
recognize that there may be differing
views on interpreting or weighing the
available information. Thus, EPA
solicits comment related to the
questions of delisting and revocation.
In further considering the adequacy of
the current standard in providing
requisite protection from Pb-related
adverse effects on public welfare, EPA
will focus on the body of available
evidence (briefly summarized above in
Section IV.A). Depending on the
interpretation, the available data and
evidence, primarily qualitative, may
suggest the potential for adverse
environmental impacts under the
current standard. Given the limited data
on Pb effects in ecosystems, it is
necessary to look at evidence of Pb
effects on organisms and extrapolate to
ecosystem effects. Therefore, taking into
account the available evidence and
current media concentrations in a wide
range of areas, EPA seeks comment on
whether the evidence suggests that
adverse effects are occurring,
particularly near point sources, under
the current standard. While the role of
current airborne emissions is difficult to
apportion, it is conclusive that
deposition of Pb from air sources is
occurring and that this ambient Pb is
likely to be persistent in the
environment. Historically deposited Pb
has persisted, although location-specific
dynamics of Pb in soil result in
differences in the timeframe during
which Pb is retained in surface soils or
sediments where it may be available to
ecological receptors (USEPA, 2007b,
section 2.3.3). EPA seeks comment on
the role of deposition of Pb from current
sources and the availability of this Pb to
ecological receptors.
There is only very limited information
available pertinent to assessing whether
groups of organisms which influence
ecosystem function are subject to
similar effects as those in humans. The
screening-level risk information, while
limited and accompanied by various
uncertainties, also suggests occurrences
of environmental Pb concentrations
existing under the current standard that
could have adverse environmental
effects. Environmental Pb levels today
are associated with atmospheric Pb
concentrations and deposition that have
combined with a large reservoir of
historically deposited Pb in
environmental media.
The EPA takes note of the views of
CASAC, summarized above, the
conclusions and recommendations in
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the OAQPS Staff Paper, and views of
public commenters on the adequacy of
the current standard. EPA solicits
comment on the adequacy of the current
standard and the rationale upon which
such views are based.
4. Elements of the Standard
The secondary standard is defined in
terms of four basic elements: indicator,
averaging time, level and form, which
serve to define the standard and must be
considered collectively in evaluating the
welfare protection afforded by the
standards. In considering a revision to
the current standard, EPA will consider
the four elements of the standard, the
information available and advice and
recommendations from CASAC
regarding how the elements might be
revised to provide a secondary standard
for Pb that protects against adverse
environmental effect.
With regard to the pollutant indicator
for use in a secondary NAAQS that
provides protection for public welfare
from exposure to Pb, EPA notes that Pb
is a persistent pollutant to which
ecological receptors are exposed via
multiple pathways. While the evidence
indicates that the environmental
mobility and ecological toxicity of Pb
are affected by various characteristics of
its chemical form, and the media in
which it occurs, information are
insufficient to identify an indicator
other than total Pb that would provide
protection against adverse
environmental effect in all ecosystems
nationally.
Lead is a cumulative pollutant with
environmental effects that can last many
decades. In considering the appropriate
averaging time for such a pollutant the
concept of critical loads may be useful
(CD, Section 7.3). However, information
is currently insufficient for such use in
this review.
There is a general lack of data that
would indicate the appropriate level of
Pb in environmental media that may be
associated with adverse effects. The
EPA notes the influence of airborne Pb
on Pb in aquatic systems and of changes
in airborne Pb on aquatic systems, as
demonstrated by historical patterns in
sediment cores from lakes and Pb
measurements (Section 2.8.1; CD,
Section AX7.2.2; Yohn et al., 2004;
Boyle et al., 2005), as well as the
comments of the CASAC Pb panel that
a significant change to current air
concentrations (e.g., via a significant
change to the standard) is likely to have
significant beneficial effects on the
magnitude of Pb exposures in the
environment and Pb toxicity impacts on
natural and managed terrestrial and
aquatic ecosystems in various regions of
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the U.S., the Great Lakes and also U.S.
territorial waters of the Atlantic Ocean
(Henderson, 2007a, Appendix E). We
concur with CASAC’s conclusion that
the Agency lacks the relevant data to
provide a clear, quantitative basis for
setting a secondary Pb NAAQS that
differs from the primary in indicator,
averaging time, level or form. Thus, EPA
solicits comment on the option of a
reduction in the secondary standard
consistent with any reduction of the
primary standard that would provide
increased protection against adverse
environmental effect.
Beyond the views noted above, EPA
recognizes that there may be differing
interpretations of the available evidence
and various aspects of the evidence and
exposure and risk information,
including on the important
uncertainties and limitations associated
with the evidence and assessment.
Thus, EPA solicits additional
information pertaining to and comment
on the considerations described above,
as well as on other views with regard to
the elements of a secondary standard for
Pb, and the rationale upon which such
views are based.
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V. Considerations for Ambient
Monitoring
A determination of compliance with
the Pb NAAQS for any given area is
made based on ambient air monitoring
data collected by State and local
monitoring agencies. This section
discusses aspects of the Pb surveillance
monitoring requirements with regards to
the adequacy under the current primary
Pb NAAQS as well as under options
being considered for a revised primary
Pb NAAQS. These aspects include the
sampling and analysis methods,
network design, sampling schedule, and
data handling methods. In addition, this
section discusses the need for
monitoring in support of the secondary
Pb NAAQS.
A. Sampling and Analysis Methods
To be used in determination of
compliance with the Pb NAAQS, the Pb
data must be collected and analyzed
using a Federal Reference Method
(FRM), or a Federal Equivalent Method
(FEM). The current FRM for Pb
sampling and analyses is based on the
use of a high-volume TSP sampler to
collect the sample and the use of atomic
absorption for the analysis of Pb in the
sample (40 CFR 50 Appendix G). There
are 21 FEMs currently approved for PbTSP (https://www.epa.gov/ttn/amtic/
criteria.html). All 21 FEMs are based on
the use of high-volume TSP samplers,
but with a variety of different analysis
methods (e.g., XRF and ICP/MS).
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Concerns have been raised over the
use of high-volume TSP samplers.
CASAC has commented that TSP
samplers have poor precision, that the
upper particle cut size varies widely as
a function of wind speed and direction,
and that the spatial non-homogeneity of
very coarse particles cannot be
efficiently captured by a national
monitoring network (Henderson,
2007b). For these reasons, CASAC
recommended considering a revision to
the Pb reference method to allow
sample collection using PM10 samplers.
CASAC suggested that it may be
possible to develop a single quantitative
adjustment factor from a short period of
collocated sampling at multiple sites, or
a Pb-PM10/Pb-TSP equivalency ratio
could be determined on a regional or
site-specific basis.
The EPA evaluated the precision and
bias of the high-volume Pb-TSP sampler
based on data reported to AQS for
collocated samplers and results of infield sampler flow audits and laboratory
audits for Pb (Camalier and Rice, 2007).
In this evaluation, we found that the
average precision of the high-volume
Pb-TSP sampler was approximately
12%, with a standard deviation of 19%,
and average sampling bias (based on
flow audits) was ¥0.7%, with a
standard deviation of 4.2%. We also
estimated the average bias for the lab
analyses at ¥1.1% (with a standard
deviation of 5.5%) based on spiked filter
audits. Total bias, which includes bias
from both sampling and laboratory
analysis, was estimated at ¥1.7%, with
a standard deviation of 3.4%. This level
of precision and bias is comparable to
the goal of the FRM and FEM for other
criteria pollutants (e.g., within 10% for
PM2.5, 40 CFR 58 Appendix A). We
attempted to look at the precision of
low-volume Pb-PM10 samplers based on
data reported to AQS, however, we did
not have enough data (18 paired data
points for one site) to make any
conclusions on the precision of this
sampler.
Evaluations of the high-volume TSP
sampler have demonstrated that the
sampler’s cutpoint can vary between 25
and 50 µm depending on wind speed
and direction (Wedding et al., 1977,
McFarland and Rodes, 1979). A study
was conducted during the last Pb
NAAQS review to evaluate the effect of
wind speed and direction on sampler
efficiency (Purdue, 1988). This
demonstration showed that the Pb
collection efficiency of the high-volume
TSP sampler ranged from 80% to 90%
over a wide range of wind speeds and
directions. In comparison, a study
conducted near a primary Pb smelter
indicated that the ratio of Pb-PM10 to
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Pb-TSP ranged from 17% to 186% for 22
collocated samples (Brion, 1988). We
believe that the variability of the
collection efficiency of the high-volume
TSP sampler does not warrant the
discontinuation of its use. However,
with this notice, we are soliciting
comments on this issue.
We analyzed data from a number of
monitoring sites where collocated PbTSP and Pb-PM10 data have been
collected in order to evaluate the
appropriateness of using Pb-PM10 data
as a surrogate for Pb-TSP (Cavender,
2007). From this analysis it is clear that
a single relationship can not be made
that would allow one to accurately
estimate Pb-TSP concentrations from
Pb-PM10 measurements at all sites.
However, at many locations it does
appear a strong linear relationship can
be shown between Pb-TSP and Pb-PM10
concentrations. As such, it may be
feasible for a monitoring agency to
develop a site-specific relationship,
using conservative assumptions, to
estimate Pb-TSP based on Pb-PM10
measurements. We invite comments on
the appropriateness of using Pb-PM10
data as a surrogate for Pb-TSP.
While all current FRM and FEM are
based on the high-volume TSP sampler,
several vendors market low-volume TSP
samplers. These samplers are identical
to low-volume PM10 samplers with the
exception of the sampling head and
corresponding cut size. These samplers
have a number of advantages over the
high-volume TSP sampler including the
capability of sequential sampling (i.e.,
the ability to collect more than one
sample between operator visits).
Sequential sampling would be highly
desirable if the sampling frequency is
increased as part of a change to a
monthly averaging period. Currently,
the FEM demonstration requirements
[40 CFR 53.33(i)] dictate that the FEM
testing must be performed with an
ambient Pb-TSP concentration between
0.5 µg/m3 to 4.0 µg/m3. Due to the
dramatic decrease in ambient Pb
concentrations, there are few (if any)
areas in the country where a vendor
could be assured that the average
ambient Pb-TSP concentrations would
meet the FEM demonstration
requirements during the field testing
period. If the Pb NAAQS is lowered, we
believe it is appropriate to lower the
FEM requirement to a level more
consistent with current ambient Pb
concentrations and the lowered NAAQS
to allow for continued development and
approval of Pb-TSP FEM. We invite
comment on the appropriate range of
concentrations for an FEM
demonstration.
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We also reviewed the method
detection capabilities of the current lab
methods for the FRM and FEM to ensure
that these methods had the necessary
sensitivity to accurately measure PbTSP at the low concentrations
considered in the Risk Assessment
Report and Staff Paper. Based on data
submitted to AQS, the method detection
limits for these methods are all 0.01 µg/
m3 or less (Rice, 2007). From these
findings, we request comment on
whether the current lab analysis
methods are adequate for continued use
even at the lowest alternative NAAQS
levels considered in the Risk
Assessment Report and Staff Paper.
B. Network Design
The existing Pb-TSP network has
decreased substantially over the last few
decades. In 1980 there were over 900
Pb-TSP sites, this number has been
reduced to approximately 200 sites.
These reductions were made because of
substantially reduced ambient Pb
concentrations and shifting priorities to
other criteria pollutants. Now several
states have no Pb-TSP monitors
resulting in large portions of the country
with no data on current ambient Pb-TSP
concentrations. In addition, many of the
largest Pb emitting sources in the
country do not have nearby monitors,
and there is substantial uncertainty
about ambient air Pb levels resulting
from historic Pb deposits near
roadways. For these reasons, we request
comment on whether the existing PbTSP network may not be adequate, and
that additional monitoring sites may be
needed to determine compliance with
either the current or revised Pb NAAQS.
The minimum network design
requirements are given in 40 CFR 58
Appendix D. The current network
design requirements are for 2 FRM or
FEM sites in any area where Pb
concentrations exceed or have exceeded
the NAAQS in the most recent 2 years.
These requirements may make it
difficult to persuade state and local
monitoring agencies to add monitors in
areas without existing monitors. As
such, we believe that these requirements
are not adequate and should be
modified (as part of this rulemaking) to
ensure monitoring is conducted in areas
where NAAQS violations may occur.
We request comment on options for
improving the coverage of the Pb
network. One option would be to adopt
network requirements similar to those
recently promulgated for PM2.5 and
ozone which tie the number of required
monitors to the population of the urban
area and ambient Pb concentrations (40
CFR 58 Appendix D). Under this
approach, more monitoring sites would
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be required in areas with larger
populations and higher Pb
concentrations. This approach would
result in improved network coverage in
urban areas. However, large Pb emitting
sources that are not in urban areas may
still not be monitored.
A second option would be to require
one or more monitors near large Pb
emitting sources. For example, a
monitor could be required at the point
near the maximum predicted
concentrations for sources with a
potential Pb emission rate of 1 ton per
year or more (as provided by the most
recent National Emissions Inventory, or
permit data). Clearly, some effort would
be necessary to identify an appropriate
emissions threshold to ensure that all
emission sources with the potential to
exceed the NAAQS are monitored
without creating undue burden where
there is no potential to exceed the
NAAQS. This option would ensure
coverage of the highest Pb emitting
sources, but may not provide adequate
coverage in many populated areas
where a combination of smaller
emissions sources and re-entrained dust
may result in Pb concentrations in
excess of the NAAQS.
A third option could be created by the
combination of the first two options
discussed above: Establish a minimum
number of required monitors in urban
areas based on population and ambient
Pb concentrations and require monitors
near large Pb emission sources. This
option would provide good monitoring
coverage in urban areas and near Pb
emissions sources. Again, care would
need to be taken in establishing an
emissions threshold.
A fourth option would be to utilize
the current PM10 network if an
acceptable regional or site-specific
correlation of Pb-TSP and Pb-PM10 can
be made. This option would provide a
substantial increase in monitoring
coverage without requiring a large
investment in new monitoring stations.
The current PM10 network has been
carefully established to include both
rural and urban ambient levels, though
it was not designed to monitor near
large Pb emitting sources. We invite
comments on these options as well as
suggestions for additional options to
consider for improving the Pb network.
C. Sampling Schedule
The current sampling frequency
requirement is for one 24-hour sample
every six days [40 CFR 58.12(b)]. For the
current NAAQS, which is based on a
quarterly average, the 1-in-6 sampling
schedule yields 15 samples per quarter
on average with 100% completeness, or
12 samples with 75% completeness. A
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change to a monthly averaging period
would result in between 4 and 6
samples per month at the current
sampling frequency. If we change the
averaging time to a monthly average, we
would likely need to increase the
sampling frequency as 4 samples would
not result in a statistically valid estimate
of the actual air quality for the period.
Incomplete sampling results in
increased uncertainty in the estimate of
actual ambient air quality. While some
degree of uncertainty is unavoidable
due to the precision and bias inherent
to the sampling technique, it is
important to understand the level of
uncertainty for each sampling option
being considered and to select a
sampling frequency which achieves an
acceptable level of uncertainty. We plan
to go through the Data Quality
Objectives (DQO) process in order to
help us select an appropriate sampling
option. The DQO process is a series of
logical steps that guides decision
makers to a plan for the resourceeffective acquisition of environmental
data. The DQO process is used to
establish performance and acceptance
criteria, which serve as the basis for
designing a plan for collecting data of
sufficient quality and quantity to
support the goals of the study (EPA,
2006e, EPA/240/B–06/001).
We are considering several options for
sampling frequency. These options
include maintaining the current 1-in-6
day sampling schedule, increasing the
sampling frequency to 1-in-3 day, or
increasing the sampling frequency to 1in-1 day sampling (i.e., complete
sampling). In addition, we will be
considering an option that relates
sampling frequency to recent ambient
Pb-TSP concentrations, such that an
increased sampling frequency is
required as the recent ambient Pb-TSP
concentrations approach the NAAQS
level. Other options that we will be
considering include—
• Increasing sampling time duration
(e.g., changing from a 24 hour sampling
time duration to a 48 or 72 hour
sampling time duration).
• Allowing for compositing of
samples (i.e., analyzing sequential
samples together).
• Allowing for multiple samplers at
one site.
We invite comments on the
appropriateness of these sampling
options and suggestions for additional
options for consideration.
D. Data Handling
A number of data handling
conventions and computations are
necessary when using ambient
monitoring data to determine attainment
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or non-attainment of the NAAQS.
Recently, we have been codifying these
data handling conventions and
computations into a separate appendix
for each NAAQS. As such, we intend to
create an appendix for the interpretation
of the Pb NAAQS as part of this rule
making. Specific conventions we are
considering and invite comments on at
this time include the following—
• Design values will be developed
based on the most recent 3 calendar year
period.
• Design values will be rounded to
two significant figures using
conventional rounding methodology.
• 75% of the expected number of
samples is needed for a quarter to be
considered complete, or 50% for a
month.
• Only one period (i.e., one month or
one quarter depending on the final form
of the standard) is needed to
demonstrate non-attainment. Two
periods would be needed if the NAAQS
is based on the 2nd maximum.
• Three full consecutive years of
complete data are needed to redesignate an area attainment from nonattainment.
• Incomplete periods can be used to
demonstrate non-attainment, but not
attainment.
E. Monitoring for the Secondary NAAQS
Currently, the secondary NAAQS is
set equal to the primary NAAQS (1.5 µg/
m3, maximum quarterly average). We do
not expect there to be ambient air
concentrations in excess of the
secondary NAAQS in rural areas that
are not associated with a Pb emission
source. If the secondary standard
remains equal to the primary standard at
the completion of the current review,
we request comment on the option of
developing Pb surveillance monitoring
requirements for the primary NAAQS
that will be sufficient to determine
compliance with the secondary NAAQS.
While additional monitoring may not
be necessary to demonstrate compliance
with the secondary NAAQS, CASAC has
recommended additional monitoring to
gather information to better inform
consideration of the secondary NAAQS
in the next and future reviews.
Specifically, CASAC stated that ‘‘the
EPA needs to initiate new measurement
activities in rural areas—which quantify
and track changes in lead
concentrations in the ambient air, soils,
deposition, surface waters, sediments
and biota, along with other information
as may be needed to calculate and apply
a critical loads approach for assessing
environmental lead exposures and risks
in the next review cycle’’ (Henderson,
2007b).
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We currently monitor ambient Pb in
PM2.5 as part of the IMPROVE network.
There are 110 formally designated
IMPROVE sites located in or near
national parks and other Class I
visibility areas, virtually all of these
being rural. Approximately 80
additional sites at various urban and
rural locations, requested and funded by
various parties, are also informally
treated as part of the network. While we
believe it may not be appropriate to rely
on either Pb-PM10 or Pb-PM2.5
monitoring to demonstrate compliance
with a Pb-TSP NAAQS, we believe the
Pb-PM2.5 measurements provided by the
IMPROVE network can be used as a
useful indicator to track changes in
ambient Pb concentrations and resulting
Pb deposition in rural areas that are not
directly impacted by a Pb emission
source. It may also be desirable to
augment the IMPROVE network with a
small ‘‘sentinel’’ network of collocated
Pb-TSP monitors for a period of time in
order to develop a better understanding
of how Pb-PM2.5 and Pb-TSP relate in
these rural areas. Alternatively, since it
is likely that at rural locations nearly all
Pb is in the less than 10 µm size range,
we could analyze the PM10 mass
samples (which are already being
collected) for Pb for a period of time to
develop a better understanding of how
Pb-PM2.5 and Pb-PM10 relate in these
rural areas. We welcome comments on
the value and appropriateness of use of
the IMPROVE Pb-PM2.5 data for
assessing trends in ambient air
concentrations of Pb, and the need to
collocate a small network of Pb-TSP or
Pb-PM10 monitors at IMPROVE sites.
The National Water-Quality
Assessment (NAWQA), conducted by
the United States Geological Survey,
contains data on Pb concentrations in
surface water, bed sediment, and animal
tissue for more than 50 river basins and
aquifers throughout the country (CD,
AX7.2.2.2). NAWQA data are collected
during long-term, cyclical investigations
wherein study units undergo intensive
sampling for 3 to 4 years, followed by
low-intensity monitoring and
assessment of trends every 10 years.
Similarly, the USGS is collaborating
with Canadian and Mexican government
agencies on a multi-national project
called ‘‘Geochemical Landscapes’’ that
has as its long-term goal a soil
geochemical survey of North America
(https://minerals.cr.usgs.gov/projects/
geochemical_landscapes/).
The Geochemical Landscapes project
has the potential to fill the need for
periodic Pb soil sampling. We note the
value of the NAWQA and Geochemical
Landscapes data in the assessment of
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trends in Pb concentrations in both soil
and aquatic systems, and support the
continued collection of this data by the
USGS.
VI. Solicitation of Comment
With the issuance of this ANPR, the
Agency is soliciting broad public input
to inform the Agency’s proposed
rulemaking related to the review of the
Pb NAAQS. As noted in Section I above,
this ANPR, as a consequence of the
timing of the Pb NAAQS review relative
to the Agency’s initiation of the new
NAAQS process, summarizes
information from the OAQPS Staff
Paper, and from the Agency’s risk
assessment and Criteria Document. In so
doing, this notice presents OAQPS staff
views on the adequacy of the current
standard and on a range of policy
options for the Administrator’s
consideration, together with the views
of CASAC and the public as reflected in
their comments on the related
documents that have been previously
made available for review. The Agency
is soliciting comment on the range of
views discussed above as well as any
broader range of options that members
of the public feel appropriate for the
Administrator to consider. Comments
are solicited together with the rationales
for the views expressed in those
comments. The Agency is also soliciting
further advice from CASAC on the
issues discussed in this notice at an
upcoming public meeting (announced
in a separate Federal Register notice).
In soliciting public comment in
advance of reaching proposed decisions
on whether to retain or revise the
NAAQS under review, the Agency is
interested in general, specific, and
technical comments on all aspects of the
rulemaking discussed in this notice and
the related documents. These aspects
generally include characterization of Pb
in the ambient environment,
characterization of the health effects
evidence and the assessment of human
exposure and health risk,
characterization of the environmental
effects evidence and consideration of
environmental exposure and risk, as
well as an assessment of the adequacy
of the current primary and secondary
standards and of alternative standards
for the Administrator’s consideration in
reaching proposed decisions in this
review of the Pb NAAQS. We solicit
broad comment on these aspects of this
rulemaking, informed by the discussion
presented in this notice as well as the
more comprehensive discussion in the
Criteria Document, the Staff Paper, and
related risk assessment reports.
Several types of information pertinent
to the characterization of Pb in the
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ambient environment are considered for
this review. These include
characterization of sources of Pb,
including source distribution within the
U.S. and associated estimates of the
magnitude of air emissions. The
currently available information on the
magnitude, geographic distribution and
variability of Pb levels in the ambient
air is also considered. Further, given
that Pb is a multimedia pollutant,
characterization of Pb includes
consideration of atmospheric deposition
and Pb in ambient soil, surface waters
and sediment. Comments, including
information and views, are solicited in
all of these areas as well as any other
areas related to the characterization of
Pb in the ambient environment that are
relevant to this review.
The current health effects evidence
for Pb, evaluated in the Agency’s
Criteria Document, encompasses a broad
range of information regarding human
exposure to ambient Pb, toxicokinetics
of Pb, biological markers and models of
Pb burden in humans, toxicological
effects of Pb in laboratory animals and
in vitro test systems, and epidemiologic
studies of human health effects
associated with Pb exposure. In
addition, based on the information in
the Criteria Documents, quantitative
assessments of human exposures to Pb
and associated health risks as well as
environmental exposures and related
risks have been conducted and are
presented in related risk assessment
reports. We are soliciting comments,
including information and views,
informed by the Criteria Document,
Staff Paper, and risk assessment reports,
on characterization of the health effects
evidence and consideration of human
exposure and health risk associated
with Pb exposures. Similarly, the
Agency is soliciting comment on the
characterization of the environmental
effects evidence and environmental
risks of Pb relevant to this review.
With regard to the primary and
secondary standards, a wide range of
views have been expressed, reflecting
differing conclusions about the
scientific evidence and quantitative risk
assessments and differing public health
and welfare policy judgments about
appropriate standards. These views
range from asserting the need for
significant strengthening of the
standards to a recommendation in
public comments that the Pb NAAQS
should be revoked and/or Pb should be
delisted as a criteria pollutant. We
solicit comment on these views as well
as on any other views that are thought
to be appropriate for the Agency to
consider, together with rationales for the
views expressed. More specifically, we
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solicit comment, including views and
associated rationale, informed by the
Criteria Document, Staff Paper and
related risk assessment reports, on the
adequacy of the current primary and
secondary standards. We also solicit
comment on the range of alternative
primary and secondary standards the
Agency should consider, with a focus
on the four basic elements of the
standards, including indicator,
averaging time, level, and form. Further,
we are soliciting comment on the view
that it is appropriate to revoke the
NAAQS for Pb or to remove Pb from the
list of criteria pollutants.
Issues related to Pb surveillance
monitoring requirements relevant to this
review are also discussed in this notice.
These issues fall into several areas,
including sampling and analysis
methods related to Pb-TSP and Pb-PM10
measurements, monitoring network
design, sampling schedule, and data
handling. Specific aspects of monitoring
in support of the secondary standard are
also discussed. We are soliciting
comments on the issues related to Pb
surveillance monitoring requirements
identified in this notice as well as on
other issues relevant to these
requirements in this review.
The Agency will consider comments
received in response to this notice in
reaching proposed decisions in this
rulemaking. As noted above, the public
will have an additional opportunity for
comment on the proposed rulemaking,
which will further inform the
Administrator’s final decisions on the
Pb NAAQS.
VII. Statutory and Executive Order
Reviews
Executive Order 12866: Regulatory
Planning and Review
Under Executive Order (EO) 12866
(58 FR 51735, October 4, 1993), this
action is a ‘‘significant regulatory
action.’’ Accordingly, EPA submitted
this action to the Office of Management
and Budget (OMB) for review under EO
12866 and any changes made in
response to OMB recommendations
have been documented in the docket for
this action.
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List of Subjects in 40 CFR Part 50
Environmental protection, Air
pollution control, Carbon monoxide,
Lead, Nitrogen dioxide, Ozone,
Particulate matter, Sulfur oxides.
Dated: December 5, 2007.
Stephen L. Johnson,
Administrator.
[FR Doc. E7–23884 Filed 12–14–07; 8:45 am]
BILLING CODE 6560–50–P
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[Federal Register Volume 72, Number 241 (Monday, December 17, 2007)]
[Proposed Rules]
[Pages 71488-71544]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E7-23884]
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Part II
Environmental Protection Agency
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40 CFR Part 50
National Ambient Air Quality Standards for Lead; Proposed Rule
Federal Register / Vol. 72 , No. 241 / Monday, December 17, 2007 /
Proposed Rules
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ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 50
[EPA-HQ-OAR-2006-0735; FRL-8503-8 ]
RIN 2060-AN83
National Ambient Air Quality Standards for Lead
AGENCY: Environmental Protection Agency (EPA).
ACTION: Advance notice of proposed rulemaking (ANPR).
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SUMMARY: EPA is issuing this ANPR to invite comment from all interested
parties on policy options and other issues related to the Agency's
ongoing review of the national ambient air quality standards (NAAQS)
for lead (Pb). Consistent with recent modifications the Agency has made
to its process for reviewing NAAQS, we are seeking broad public comment
at this time to help inform the Agency's future proposed decisions on
the adequacy of the current Pb NAAQS and on any revisions of the Pb
NAAQS that may be appropriate. EPA is also soliciting comment on
retaining Pb on the list of criteria pollutants and on maintaining
NAAQS for Pb.
As part of this review, the Agency has released several key
documents that will inform the Agency's rulemaking. These documents
include the Air Quality Criteria for Lead, released in 2006, which
critically assesses and integrates relevant scientific information;
risk assessment reports including the most recent report, Lead: Human
Exposure and Health Risk Assessment for Selected Case Studies, which
documents quantitative exposure analyses and risk assessments conducted
for this review; and a recently released Staff Paper, Review of the
National Ambient Air Quality Standards for Lead: Policy Assessment of
Scientific and Technical Information, which presents an evaluation by
staff in EPA's Office of Air Quality Planning and Standards (OAQPS) of
the policy implications of the scientific information and quantitative
assessments and OAQPS staff conclusions and recommendations on a range
of policy options for the Agency's consideration.
Under the terms of a court order, the Administrator will sign by
September 1, 2008 a Notice of Final Rulemaking for publication in the
Federal Register. To meet this schedule, we anticipate the
Administrator will sign a Notice of Proposed Rulemaking in March 2008
for publication in the Federal Register, at which time further
opportunity for public comment will be provided.
DATES: Comments must be received by January 16, 2008.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2006-0735 by one of the following methods:
https://www.regulations.gov: Follow the on-line
instructions for submitting comments.
E-mail: a-and-r-Docket@epa.gov.
Fax: 202-566-9744.
Mail: Docket No. EPA-HQ-OAR-2006-0735, Environmental
Protection Agency, Mail code 6102T, 1200 Pennsylvania Ave., NW.,
Washington, DC 20460. Please include a total of two copies.
Hand Delivery: Docket No. EPA-HQ-OAR-2006-0735,
Environmental Protection Agency, EPA West, Room 3334, 1301 Constitution
Ave., NW., Washington, DC. Such deliveries are only accepted during the
Docket's normal hours of operation, and special arrangements should be
made for deliveries of boxed information.
Instructions: Direct your comments to Docket ID No. EPA-HQ-OAR-
2006-0735. The EPA's policy is that all comments received will be
included in the public docket without change and may be made available
online at https://www.regulations.gov, including any personal
information provided, unless the comment includes information claimed
to be Confidential Business Information (CBI) or other information
whose disclosure is restricted by statute. Do not submit information
that you consider to be CBI or otherwise protected through https://
www.regulations.gov or e-mail. The https://www.regulations.gov Web site
is an ``anonymous access'' system, which means EPA will not know your
identity or contact information unless you provide it in the body of
your comment. If you send an e-mail comment directly to EPA without
going through https://www.regulations.gov, your e-mail address will be
automatically captured and included as part of the comment that is
placed in the public docket and made available on the Internet. If you
submit an electronic comment, EPA recommends that you include your name
and other contact information in the body of your comment and with any
disk or CD-ROM you submit. If EPA cannot read your comment due to
technical difficulties and cannot contact you for clarification, EPA
may not be able to consider your comment. Electronic files should avoid
the use of special characters, any form of encryption, and be free of
any defects or viruses. For additional information about EPA's public
docket, visit the EPA Docket Center homepage at https://www.epa.gov/
epahome/dockets.htm.
Docket: All documents in the docket are listed in the https://
www.regulations.gov index. Although listed in the index, some
information is not publicly available, e.g., CBI or other information
whose disclosure is restricted by statute. Certain other material, such
as copyrighted material, will be publicly available only in hard copy.
Publicly available docket materials are available either electronically
in https://www.regulations.gov or in hard copy at the Air and Radiation
Docket and Information Center, EPA/DC, EPA West, Room 3334, 1301
Constitution Ave., NW., Washington, DC. The Public Reading Room is open
from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal
holidays. The telephone number for the Public Reading Room is (202)
566-1744 and the telephone number for the Air and Radiation Docket and
Information Center is (202) 566-1742.
FOR FURTHER INFORMATION CONTACT: Dr. Deirdre Murphy, Health and
Environmental Impacts Division, Office of Air Quality Planning and
Standards, U.S. Environmental Protection Agency, Mail code C504-06,
Research Triangle Park, NC 27711; telephone: 919-541-0729; fax: 919-
541-0237; e-mail: Murphy.deirdre@epa.gov.
SUPPLEMENTARY INFORMATION:
General Information
What Should I Consider as I Prepare My Comments for EPA?
1. Submitting CBI. Do not submit this information to EPA through
https://www.regulations.gov or e-mail. Clearly mark the part or all of
the information that you claim to be CBI. For CBI information in a disk
or CD ROM that you mail to EPA, mark the outside of the disk or CD ROM
as CBI and then identify electronically within the disk or CD ROM the
specific information that is claimed as CBI. In addition to one
complete version of the comment that includes information claimed as
CBI, a copy of the comment that does not contain the information
claimed as CBI must be submitted for inclusion in the public docket.
Information so marked will not be disclosed except in accordance with
procedures set forth in 40 CFR part 2.
2. Tips for Preparing Your Comments. When submitting comments,
remember to:
Identify the rulemaking by docket number and other
identifying
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information (subject heading, Federal Register date and page number).
Follow directions--the agency may ask you to respond to
specific questions or organize comments by referencing a Code of
Federal Regulations (CFR) part or section number.
Explain why you agree or disagree, suggest alternatives,
and substitute language for your requested changes.
Describe any assumptions and provide any technical
information and/or data that you used.
If you estimate potential costs or burdens, explain how
you arrived at your estimate in sufficient detail to allow for it to be
reproduced.
Provide specific examples to illustrate your concerns, and
suggest alternatives.
Explain your views as clearly as possible, avoiding the
use of profanity or personal threats.
Make sure to submit your comments by the comment period
deadline identified.
Availability of Related Information
A number of documents relevant to this rulemaking, including the
Air Quality Criteria for Lead (Criteria Document) (USEPA, 2006a), the
Staff Paper, related risk assessment reports, and other related
technical documents are available on EPA's Office of Air Quality
Planning and Standards (OAQPS) Technology Transfer Network (TTN) Web
site at https://www.epa.gov/ttn/naaqs/standards/pb/s_pb_index.html.
These and other related documents are also available for inspection and
copying in the EPA docket identified above.
Table of Contents
The following topics are discussed in this preamble:
I. Introduction
II. Background
A. Legislative Requirements
B. History of Lead NAAQS Reviews
C. Current Related Lead Control Programs
D. Current Lead NAAQS Review
E. Implementation Considerations
III. The Primary Standard
A. Health Effects Information
1. Internal Disposition--Blood Lead as Dose Metric
2. Nature of Effects
3. Lead-Related Impacts on Public Health
a. At-Risk Subpopulations
b. Potential Public Health Impacts
4. Key Observations
B. Human Exposure and Health Risk Assessments
1. Overview of Risk Assessment From Last Review
2. Design Aspects of Exposure and Risk Assessments
a. CASAC Advice
b. Health Endpoint, Risk Metric and Concentration-Response
Functions
c. Case Study Approach
d. Air Quality Scenarios
e. Categorization of Policy-Relevant Exposure Pathways
f. Analytical Steps
g. Generating Multiple Sets of Risk Results
h. Key Limitations and Uncertainties
3. Summary of Results
a. Blood Pb Estimates
b. IQ Loss Estimates
C. Considerations in Review of the Standard
1. Background on the Current Standard
a. Basis for Setting the Current Standard
b. Policy Options Considered in the Last Review
2. Approach for Current Review
3. Adequacy of the Current Standard
a. Evidence-Based Considerations
b. Exposure- and Risk-Based Considerations
c. CASAC Advice and Recommendations
d. Policy Options
4. Elements of the Standard
a. Indicator
b. Averaging Time and Form
c. Level
IV. The Secondary Standard
A. Welfare Effects Information
B. Screening Level Ecological Risk Assessment
1. Design Aspects of the Assessment and Associated Uncertanties
2. Summary of Results
C. Considerations in Review of the Standard
1. Background on the Current Standard
2. Approach for Current Review
3. Adequacy of the Current Standard
a. Evidence-Based Considerations
b. Risk-Based Considerations
c. CASAC Advice and Recommendations
d. Policy Options
4. Elements of the Standard
V. Considerations for Ambient Monitoring
A. Sampling and Analysis Methods
B. Network Design
C. Sampling Schedule
D. Data Handling
E. Monitoring for the Secondary NAAQS
VI. Solicitation of Comment
VII. Statutory and Executive Order Reviews
References
I. Introduction
In the past year EPA has instituted a number of changes to the
process that the Agency uses in reviewing the NAAQS to help to improve
the efficiency of the process while ensuring that the Agency's
decisions are informed by the best available science and broad
participation among experts in the scientific community and the public
(described at https://www.epa.gov/ttn/naaqs/). These changes apply to
the four major components of the NAAQS review process: planning,
science assessment, risk/exposure assessment, and policy assessment/
rulemaking. The process improvements will help the Agency meet the goal
of reviewing each NAAQS on a 5-year cycle as required by the Clean Air
Act (CAA) without compromising the scientific integrity of the process.
These changes are being incorporated into the various ongoing NAAQS
reviews being conducted by the Agency, including the current review of
the Pb NAAQS.
The issuance of this ANPR is one of the key features of the new
NAAQS review process. Historically, a policy assessment that evaluates
the policy implications of the available scientific information and
risk/exposure assessments has been presented in the form of a Staff
Paper, prepared by staff in EPA's OAQPS, which included OAQPS staff
conclusions and recommendations on a range of policy options for the
Agency's consideration. The new process will enable broader
participation of the scientific community and the public early in the
NAAQS review by providing scientific information, risk/exposure
assessments, and policy options in an ANPR rather than a Staff Paper.
The purpose of the ANPR is to identify conceptual evidence- and risk-
based approaches for reaching policy judgments, discuss what the
science and risk/exposure assessments say about the adequacy of the
current standards, and describe a range of options for standard
setting, in terms of indicators, averaging times, forms, and ranges of
levels for any alternative standards. Discussion of alternative
standards is to include a description of the underlying interpretations
of the scientific evidence and risk/exposure information that might
support such alternative standards and that could be considered by the
Administrator in making NAAQS decisions. The issuance of an ANPR
provides the opportunity for the Clean Air Scientific Advisory
Committee (CASAC) \1\ and the public to evaluate and provide comment on
a broad range of policy options being considered by the Administrator.
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\1\ As discussed below in section II, CASAC is the independent
scientific review committee that provides advice and recommendations
to the EPA Administrator related to periodic reviews of NAAQS, as
mandated by the Clean Air Act.
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In the case of this Pb NAAQS review, which was initiated well
before changes were instituted to the NAAQS review process, both an
OAQPS Staff Paper and an ANPR are being issued. As discussed below in
section II, the issuance of both documents reflects the terms of a
court order that governs this review and requires that a final OAQPS
Staff Paper be issued. As a consequence, in addition to soliciting
comment, this ANPR summarizes information from the OAQPS Staff Paper
(referred to as Staff Paper throughout this notice) and from
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the Agency's risk assessment and Criteria Document. This ANPR is
structured such that policy options on adequacy of the current
standards and aspects of potential alternative standards are discussed
in Sections III.C and IV.C. Preceding those policy discussions are
sections focused on health and welfare effects in Sections III.A and
IV.A, respectively, and on human exposure and risk and ecological risk
in Sections III.B and IV.B, respectively.
II. Background
A. Legislative Requirements
Two sections of the Clean Air Act (Act) govern the establishment
and revision of the NAAQS. Section 108 (42 U.S.C. 7408) directs the
Administrator to identify and list each air pollutant that ``in his
judgment, cause or contribute to air pollution which may reasonably be
anticipated to endanger public health and welfare'' and whose
``presence * * * in the ambient air results from numerous or diverse
mobile or stationary sources'' and to issue air quality criteria for
those that are listed. Air quality criteria are to ``accurately reflect
the latest scientific knowledge useful in indicating the kind and
extent of all identifiable effects on public health or welfare which
may be expected from the presence of [a] pollutant in ambient air * *
*''. Section 108 also states that the Administrator ``shall, from time
to time * * * revise a list'' that includes these pollutants, which
provides the authority for a pollutant to be removed from or added to
the list of criteria pollutants.
Section 109 (42 U.S.C. 7409) directs the Administrator to propose
and promulgate ``primary'' and ``secondary'' NAAQS for pollutants
listed under section 108. Section 109(b)(1) defines a primary standard
as one ``the attainment and maintenance of which in the judgment of the
Administrator, based on [air quality] criteria and allowing an adequate
margin of safety, are requisite to protect the public health.'' \2\ A
secondary standard, as defined in Section 109(b)(2), must ``specify a
level of air quality the attainment and maintenance of which, in the
judgment of the Administrator, based on criteria, is requisite to
protect the public welfare from any known or anticipated adverse
effects associated with the presence of [the] pollutant in the ambient
air.'' \3\
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\2\ The legislative history of section 109 indicates that a
primary standard is to be set at ``the maximum permissible ambient
air level * * * which will protect the health of any [sensitive]
group of the population,'' and that for this purpose ``reference
should be made to a representative sample of persons comprising the
sensitive group rather than to a single person in such a group.'' S.
Rep. No. 91-1196, 91st Cong., 2d Sess. 10 (1970)
\3\ Welfare effects as defined in section 302(h) (42 U.S.C.
7602(h)) include, but are not limited to, ``effects on soils, water,
crops, vegetation, man-made materials, animals, wildlife, weather,
visibility and climate, damage to and deterioration of property, and
hazards to transportation, as well as effects on economic values and
on personal comfort and well-being.''
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The requirement that primary standards include an adequate margin
of safety was intended to address uncertainties associated with
inconclusive scientific and technical information available at the time
of standard setting. It was also intended to provide a reasonable
degree of protection against hazards that research has not yet
identified. Lead Industries Association v. EPA, 647 F.2d 1130, 1154 (DC
Cir 1980), cert. denied, 449 U.S. 1042 (1980); American Petroleum
Institute v. Costle, 665 F.2d 1176, 1186 (D.C. Cir. 1981), cert.
denied, 455 U.S. 1034 (1982). Both kinds of uncertainties are
components of the risk associated with pollution at levels below those
at which human health effects can be said to occur with reasonable
scientific certainty. Thus, in selecting primary standards that include
an adequate margin of safety, the Administrator is seeking not only to
prevent pollution levels that have been demonstrated to be harmful but
also to prevent lower pollutant levels that may pose an unacceptable
risk of harm, even if the risk is not precisely identified as to nature
or degree.
In selecting a margin of safety, EPA considers such factors as the
nature and severity of the health effects involved, the size of the
sensitive population(s) at risk, and the kind and degree of the
uncertainties that must be addressed. The selection of any particular
approach to providing an adequate margin of safety is a policy choice
left specifically to the Administrator's judgment. Lead Industries
Association v. EPA, supra, 647 F.2d at 1161-62.
In setting standards that are ``requisite'' to protect public
health and welfare, as provided in section 109(b), EPA's task is to
establish standards that are neither more nor less stringent than
necessary for these purposes. In so doing, EPA may not consider the
costs of implementing the standards. See generally Whitman v. American
Trucking Associations, 531 U.S. 457, 471, 475-76 (2001).
Section 109(d)(1) of the Act requires that ``Not later than
December 31, 1980, and at 5-year intervals thereafter, the
Administrator shall complete a thorough review of the criteria
published under section 108 and the national ambient air quality
standards promulgated under this section and shall make such revisions
in such criteria and standards and promulgate such new standards as may
be appropriate in accordance with section 108 and subsection (b) of
this section. The Administrator may review and revise criteria or
promulgate new standards earlier or more frequently than required under
this paragraph.'' Section 109(d)(2)(A) requires that ``The
Administrator shall appoint an independent scientific review committee
composed of seven members including at least one member of the National
Academy of Sciences, one physician, and one person representing State
air pollution control agencies.'' Section 109(d)(2)(B) requires that,
``Not later than January 1, 1980, and at five-year intervals
thereafter, the committee referred to in subparagraph (A) shall
complete a review of the criteria published under section 108 and the
national primary and secondary ambient air quality standards
promulgated under this section and shall recommend to the Administrator
any new national ambient air quality standards and revisions of
existing criteria and standards as may be appropriate under section 108
and subsection (b) of this section.'' \4\ Since the early 1980's, this
independent review function has been performed by the Clean Air
Scientific Advisory Committee (CASAC) of EPA's Science Advisory Board.
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\4\ In addition to the provisions of Section 109(d)(2)(B),
concerning the role of CASAC in providing advice and recommendations
to the Administrator on the criteria and standards, Section
109(d)(2)(C) provides that CASAC shall also, ``(i) advise the
Administrator of areas in which additional knowledge is required to
appraise the adequacy and basis of existing, new, or revised
national ambient air quality standards, (ii) describe the research
efforts necessary to provide the required information, (iii) advise
the Administrator on the relative contribution to air pollution
concentrations of natural as well as anthropogenic activity, and
(iv) advise the Administrator of any adverse public health, welfare,
social economic, or energy effects which may result from various
strategies for attainment and maintenance of such national ambient
air quality standards.''
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B. History of Lead NAAQS Reviews
On October 5, 1978 EPA promulgated primary and secondary NAAQS for
Pb under section 109 of the Act (43 FR 46246). Both primary and
secondary standards were set at a level of 1.5 micrograms per cubic
meter ([mu]g/m\3\), measured as Pb in total suspended particulate
matter (Pb-TSP), not to be exceeded by the maximum arithmetic mean
concentration averaged over a calendar quarter. This standard was based
on the 1977 Air Quality Criteria for Lead (USEPA, 1977).
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A review of the Pb standards was initiated in the mid-1980s. The
scientific assessment for that review is described in the 1986 Air
Quality Criteria for Lead (USEPA, 1986a), the associated Addendum
(USEPA, 1986b) and the 1990 Supplement (USEPA, 1990a). As part of the
review, the Agency designed and performed human exposure and health
risk analyses (USEPA, 1989), the results of which were presented in a
1990 Staff Paper (USEPA, 1990b). Based on the scientific assessment and
the human exposure and health risk analyses, the 1990 Staff Paper
presented options for the Pb NAAQS level in the range of 0.5 to 1.5
[mu]g/m\3\, and suggested the second highest monthly average in three
years for the form and averaging time of the standard (USEPA, 1990b).
After consideration of the documents developed during the review and
the significantly changed circumstances since Pb was listed in 1976, as
noted above, the Agency did not propose any revisions to the 1978 Pb
NAAQS. In a parallel effort, the Agency developed the broad, multi-
program, multimedia, integrated U.S. Strategy for Reducing Lead
Exposure (USEPA, 1991). As part of implementing this strategy, the
Agency focused efforts primarily on regulatory and remedial clean-up
actions aimed at reducing Pb exposures from a variety of nonair sources
judged to pose more extensive public health risks to U.S. populations,
as well as on actions to reduce Pb emissions to air.
C. Current Related Lead Control Programs
States are primarily responsible for ensuring attainment and
maintenance of ambient air quality standards once EPA has established
them. Under section 110 of the Act (42 U.S.C. 7410) and related
provisions, States are to submit, for EPA approval, State
implementation plans (SIP's) that provide for the attainment and
maintenance of such standards through control programs directed to
sources of the pollutants involved. The States, in conjunction with
EPA, also administer the prevention of significant deterioration
program (42 U.S.C. 7470-7479) for these pollutants. In addition,
Federal programs provide for nationwide reductions in emissions of
these and other air pollutants through the Federal Motor Vehicle
Control Program under Title II of the Act (42 U.S.C. 7521-7574), which
involves controls for automobile, truck, bus, motorcycle, nonroad
engine, and aircraft emissions; the new source performance standards
under section 111 of the Act (42 U.S.C. 7411); and the national
emission standards for hazardous air pollutants under section 112 of
the Act (42 U.S.C. 7412).
As Pb is a multimedia pollutant, a broad range of Federal programs
beyond those identified above that focus on air pollution control
provide for nationwide reductions in environmental releases and human
exposures. The Centers for Disease Control and Prevention (CDC)
programs provide for the tracking of children's blood Pb levels
nationally and provide guidance on levels at which medical and
environmental case management activities should be implemented (CDC,
2005a; ACCLPP, 2007).\5\ In 1991, the Secretary of the Health and Human
Services (HHS) characterized Pb poisoning as the ``number one
environmental threat to the health of children in the United States''
(Alliance to End Childhood Lead Poisoning. 1991). And, in 1997,
President Clinton created, by Executive Order 13045, the President's
Task Force on Environmental Health Risks and Safety Risks to Children
in response to increased awareness that children face disproportionate
risks from environmental health and safety hazards (62 FR 19885).\6\ By
Executive Orders issued in October 2001 and April 2003, President Bush
extended the work for the Task Force for an additional three and a half
years beyond its original charter (66 FR 52013 and 68 FR 19931). The
Task Force set a Federal goal of eliminating childhood Pb poisoning by
the year 2010 and reducing Pb poisoning in children was the Task
Force's top priority.
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\5\ As described in Section III below the CDC stated in 2005
that no ``safe'' threshold for blood Pb levels in young children has
been identified (CDC, 2005a).
\6\ Co-chaired by the Secretary of the HHS and the Administrator
of the EPA, the Task Force consisted of representatives from 16
Federal departments and agencies.
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Federal abatement programs provide for the reduction in human
exposures and environmental releases from in-place materials containing
Pb (e.g., Pb-based paint, urban soil and dust and contaminated waste
sites). Federal regulations on disposal of Pb-based paint waste help
facilitate the removal of Pb-based paint from residences (See
``Criteria for Classification of Solid Waste Disposal Facilities and
Practices and Criteria for Municipal Solid Waste Landfills: Disposal of
Residential Lead-Based Paint Waste; Final Rule'' EPA-HQ-RCRA-2001-
0017). Further, in 1991, EPA lowered the maximum levels of Pb permitted
in public water systems from 50 parts per billion (ppb) to 15 ppb (56
FR 26460).
Federal programs to reduce exposure to Pb in paint, dust and soil
are specified under the comprehensive federal strategy developed under
the Residential Lead-Based Paint Hazard Reduction Act (Title X). Under
Title X and Title IV of the Toxic Substances Control Act, EPA has
established regulations in the following four categories: (1) Training
and certification requirements for persons engaged in lead-based paint
activities; accreditation of training providers; work practice
standards for the safe, reliable, and effective identification and
elimination of lead-based paint hazards; (2) Ensuring that, for most
housing constructed before 1978, lead-based paint information flows
from sellers to purchasers, from landlords to tenants, and from
renovators to owners and occupants; (3) Establishing standards for
identifying dangerous levels of lead in paint, dust and soil; and (4)
Providing information on lead hazards to the public, including steps
that people can take to protect themselves and their families from
lead-based paint hazards.
Under Title X of TSCA, EPA established dust lead standards for
residential housing and soil dust in 2001. This regulation supports the
implementation of other regulations which deal with worker training and
certification, lead hazard disclosure in real estate transactions, lead
hazard evaluation and control in federally-owned housing prior to sale
and housing receiving Federal assistance, and U.S. Department of
Housing and Urban Development grants to local jurisdictions to perform
lead hazard control. In addition, this regulation also establishes,
among other things, under authority of TSCA section 402, residential
lead dust cleanup levels and amendments to dust and soil sampling
requirements (66 FR 1206). The Title X term ``lead-based paint hazard''
implemented through this regulation identifies lead-based paint and all
residential lead-containing dusts and soils regardless of the source of
lead, which, due to their condition and location, would result in
adverse human health effects. One of the underlying principles of Title
X is to move the focus of public and private decision makers away from
the mere presence of lead-based paint, to the presence of lead-based
paint hazards, for which more substantive action should be undertaken
to control exposures, especially to young children. In addition the
success of the program will rely on the voluntary participation of
states and tribes as well as counties and cities to implement the
programs and on property owners to follow the standards and EPA's
recommendations. If EPA
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were to set unreasonable standards (e.g., standards that would
recommend removal of all lead from paint, dust and soil), States and
Tribes may choose to opt out of the Title X lead program and property
owners may choose to ignore EPA's advice believing it lacks credibility
and practical value. Consequently, EPA needed to develop standards that
would not waste resources by chasing risks of negligible importance and
that would be accepted by States, Tribes, local governments and
property owners.
On January 10, 2006, EPA issued a Notice of Proposed Rulemaking
covering renovations performed for compensation in target housing. The
2006 Proposal contains requirements designed to address lead hazards
created by renovation, repair, and painting activities that disturb
lead-based paint. The 2006 Proposal includes requirements for training
renovators, other renovation workers, and dust sampling technicians;
for certifying renovators, dust sampling technicians, and renovation
firms; for accrediting providers of renovation and dust sampling
technician training; for renovation work practices; and for
recordkeeping. The 2006 Proposal proposes to make the rule effective in
two stages. Initially, the rule proposes to apply to all renovations
for compensation performed in target housing where a child with an
increased blood lead level resided and rental target housing built
before 1960. The proposed rule also proposes application to owner-
occupied target housing built before 1960, unless the person performing
the renovation obtained a statement signed by the owner-occupant that
the renovation would occur in the owner's residence and that no child
under age 6 resided there. As proposed, the rule would take effect one
year later in all rental target housing built between 1960 and 1978 and
owner-occupied target housing built between 1960 and 1978. EPA also
proposes to allow interested States, Territories, and Indian Tribes the
opportunity to apply for and receive authorization to administer and
enforce all of the elements of the new renovation provisions.
A significant number of commenters observed that the proposal did
not cover buildings where children under age 6 spend a great deal of
time, such as day care centers and schools. Commenters noted that the
risk posed to children from lead-based paint hazards in schools and
day-care centers is likely to be equal to, if not greater than, the
risk posed from these hazards at home. These commenters suggested that
EPA expand its proposal to include such places, and several suggested
that EPA use the existing definition of ``child-occupied facility'' in
40 CFR Sec. 745.223 to define the expanded scope of coverage. EPA felt
that these comments had merit, and, because adding child-occupied
facilities was beyond the scope of the 2006 Proposal, an expansion of
the 2006 Proposal was necessary to give this issue full and fair
consideration. Accordingly, on June 5, 2007, EPA issued a Supplemental
Notice of Proposed Rulemaking to add child-occupied facilities to the
universe of buildings covered by the 2006 Proposal. EPA is working
expeditiously to finalize this rulemaking and expects to do so in the
first calendar quarter of 2008.
Programs associated with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA or Superfund) and Resource
Conservation Recovery Act (RCRA) also implement abatement programs,
reducing exposures to Pb and other pollutants. For example, EPA
determines and implements protective levels for Pb in soil at Superfund
sites and RCRA corrective action facilities. Federal programs,
including those implementing RCRA, provide for management of hazardous
substances in hazardous and municipal solid waste (e.g., ``Hazardous
Waste Management System; Identification and Listing of Hazardous Waste:
Inorganic Chemical Manufacturing Wastes; Land Disposal Restrictions for
Newly Identified Wastes and CERCLA Hazardous Substance Designation and
Reportable Quantities; Final Rule'', https://www.epa.gov/epaoswer/
hazwaste/state/revision/frs/fr195.pdf and https://www.epa.gov/epaoswer/
hazwaste/ldr/basic.htm). For example, Federal regulations concerning
batteries in municipal solid waste facilitate the collection and
recycling or proper disposal of batteries containing Pb (e.g., See
``Implementation of the Mercury-Containing and Rechargeable Battery
Management Act'' https://www.epa.gov/epaoswer/hazwaste/recycle/
battery.pdf and ``Municipal Solid Waste Generation, Recycling, and
Disposal in the United States: Facts and Figures for 2005'' https://
www.epa.gov/epaoswer/osw/conserve/resources/msw-2005.pdf). Similarly,
Federal programs provide for the reduction in environmental releases of
hazardous substances such as Pb in the management of wastewater (http:/
/www.epa.gov/owm/).
A variety of federal nonregulatory programs also provide for
reduced environmental release of Pb containing materials through more
general encouragement of pollution prevention, promote reuse and
recycling, reduce priority and toxic chemicals in products and waste,
and conserve energy and materials. These include the Resource
Conservation Challenge (https://www.epa.gov/epaoswer/osw/conserve/
index.htm), the National Waste Minimization Program (https://
www.epa.gov/epaoswer/hazwaste/minimize/leadtire.htm), ``Plug in to
eCycling'' (a partnership between EPA and consumer electronics
manufacturers and retailers; https://www.epa.gov/epaoswer/hazwaste/
recycle/electron/crt.htm#crts), and activities to reduce the practice
of backyard trash burning (https://www.epa.gov/msw/backyard/pubs.htm).
Efforts such as those programs described above have been successful
in that blood Pb levels in all segments of the population have dropped
significantly from levels around 1990. In particular, blood Pb levels
for the general population of children 1 to 5 years of age have dropped
to a median level of 1.6 [mu]g/dL and a level of 3.9 [mu]g/dL for the
90th percentile child in the 2003-2004 NHANES as compared to median and
90th percentile levels in 1988-1991 of 3.5 [mu]g/dL and 9.4 [mu]g/dL,
respectively (https://www.epa.gov/envirohealth/children/body_burdens/
b1-table.htm). These levels (median and 90th percentile) for the
general population of young children \7\ are at the low end of the
historic range of blood Pb levels for general population of children
aged 1-5 years and are below a level of 5 [mu]g/dL--a level that has
been associated with adverse effects with a higher degree of certainty
in the published literature (than levels such as 2 [mu]g/dL) and is a
level where cognitive deficits were identified with statistical
significance (Lanphear et al., 2000). The decline in blood Pb levels in
the United States has resulted from coordinated, intensive efforts at
the national, state and local levels. The Agency has continued to
grapple with soil and dust Pb levels from the historical use of Pb in
paint and gasoline and other sources. In doing so, the agency has faced
the difficulty of determining the level at which to set standards for
residential dust levels given the uncertainties at what environmental
levels and in which specific medium may actually cause particular blood
Pb levels that are
[[Page 71493]]
associated with adverse effects (66 FR 1206).\8\
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\7\ It is noted that although the 95th percentile value for the
2003-2004 NHANES is not currently available, that value for 2001-
2002 was 5.8 [mu]g/dL. Also, as discussed in Section III.A.1
(including footnote 15), levels have been found to vary among
children of different socioeconomic status and other demographic
characteristics (CD, p. 4-21).
\8\ See 2001 regulation to establish standards for lead-based
paint hazards in most pre-1978 housing and child-occupied facilities
(66 FR 1206).
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EPA's research program, with other Federal agencies defines,
encourages and conducts research needed to locate and assess serious
risks and to develop methods and tools to characterize and help reduce
risks. For example, EPA's Integrated Exposure Uptake Biokinetic Model
for Lead in Children (IEUBK model) for Pb in children and the Adult
Lead Methodology are widely used and accepted as tools that provide
guidance in evaluating site specific data. More recently, in
recognition of the need for a single model that predicts Pb
concentrations in tissues for children and adults, EPA is developing
the All Ages Lead Model (AALM) to provide researchers and risk
assessors with a pharmacokinetic model capable of estimating blood,
tissue, and bone concentrations of Pb based on estimates of exposure
over the lifetime of the individual. EPA research activities on
substances including Pb focus on better characterizing aspects of
health and environmental effects, exposure and control or management of
environmental releases (see https://www.epa.gov/ord/
researchaccomplishments/).
D. Current Lead NAAQS Review
EPA initiated the current review of the air quality criteria for Pb
on November 9, 2004 with a general call for information (69 FR 64926).
A project work plan (USEPA, 2005a) for the preparation of the Criteria
Document was released in January 2005 for CASAC and public review. EPA
held a series of workshops in August 2005, with invited recognized
scientific experts to discuss initial draft materials that dealt with
various lead-related issues being addressed in the Pb air quality
criteria document. The first draft of the Criteria Document (USEPA,
2005b) was released for CASAC and public review in December 2005 and
discussed at a CASAC meeting held on February 28-March 1, 2006.
A second draft Criteria Document (USEPA, 2006b) was released for
CASAC and public review in May 2006, and discussed at the CASAC meeting
on June 28, 2006. A subsequent draft of Chapter 7--Integrative
Synthesis (Chapter 8 in the final Criteria Document), released on July
31, 2006, was discussed at an August 15, 2006 CASAC teleconference. The
final Criteria Document was released on September 30, 2006 (USEPA,
2006a; cited throughout this preamble as CD). While the Criteria
Document focuses on new scientific information available since the last
review, it integrates that information with scientific criteria from
previous reviews.
In February 2006, EPA released the Plan for Review of the National
Ambient Air Quality Standards for Lead (USEPA 2006c) that described
Agency plans and a timeline for reviewing the air quality criteria,
developing human exposure and risk assessments and an ecological risk
assessment, preparing a policy assessment, and developing the proposed
and final rulemakings.
In May 2006, EPA released for CASAC and public review a draft
Analysis Plan for Human Health and Ecological Risk Assessment for the
Review of the Lead National Ambient Air Quality Standards (USEPA,
2006d), which was discussed at a June 29, 2006 CASAC meeting
(Henderson, 2006). The May 2006 assessment plan discussed two
assessment phases: a pilot phase and a full-scale phase. The pilot
phase of both the human health and ecological risk assessments was
presented in the draft Lead Human Exposure and Health Risk Assessments
and Ecological Risk Assessment for Selected Areas (ICF, 2006;
henceforth referred to as the first draft Risk Assessment Report) which
was released for CASAC and public review in December 2006. The first
draft Staff Paper, also released in December 2006, discussed the pilot
assessments and the most policy-relevant science from the Criteria
Document. These documents were reviewed by CASAC and the public at a
public meeting on February 6-7, 2007 (Henderson, 2007a).
Subsequent to that meeting, EPA conducted full-scale human exposure
and health risk assessments, although no further work was done on the
ecological assessment due to resource limitations. A second draft Risk
Assessment Report (USEPA, 2007a), containing full-scale human exposure
and health risk assessments, was released in July 2007 for review by
CASAC at a meeting held on August 28-29, 2007. Taking into
consideration CASAC comments (Henderson, 2007b) and public comments on
that document, we conducted additional human exposure and health risk
assessments. A final Risk Assessment Report (USEPA, 2007b) and final
Staff Paper (USEPA, 2007c) were released on November 1, 2007.
The final Staff Paper presents OAQPS staff's evaluation of the
policy implications of the key studies and scientific information
contained in the Criteria Document and presents and interprets results
from the quantitative risk/exposure analyses conducted for this review.
Further, the Staff Paper presents OAQPS staff recommendations on a
range of policy options for the Administrator to consider concerning
whether, and if so how, to review the primary and secondary Pb NAAQS.
Such an evaluation is intended to help ``bridge the gap'' between the
scientific assessment contained in the Criteria Document and the
judgments required of the EPA Administrator in determining whether it
is appropriate to retain or revise the NAAQS for Pb. In evaluating the
adequacy of the current standard and a range of policy alternatives,
the Staff Paper considered the available scientific evidence and
quantitative risk-based analyses, together with related limitations and
uncertainties, and focused on the information that is most pertinent to
evaluating the basic elements of air quality standards: Indicator,\9\
averaging time, form,\10\ and level. These elements, which together
serve to define each standard, must be considered collectively in
evaluating the health and welfare protection afforded by the Pb
standards. The information, conclusions, and OAQPS staff
recommendations presented in the Staff Paper were informed by comments
and advice received from CASAC in its reviews of the earlier draft
Staff Paper and drafts of related risk/exposure assessment reports, as
well as comments on these earlier draft documents submitted by public
commenters.
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\9\ The ``indicator'' of a standard defines the chemical species
or mixture that is to be measured in determining whether an area
attains the standard.
\10\ The ``form'' of a standard defines the air quality
statistic that is to be compared to the level of the standard in
determining whether an area attains the standard.
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The schedule for completion of this review is governed by a
judicial order resolving a lawsuit filed in May 2004, alleging that EPA
had failed to complete the current review within the period provided by
statute. Missouri Coalition for the Environment, v. EPA (No.
4:04CV00660 ERW, Sept. 14, 2005). The order that now governs this
review, entered by the court on September 14, 2005, provides that EPA
finalize the Staff Paper no later than November 1, 2007, which we have
done. The order also specifies that EPA sign, for publication, notices
of proposed and final rulemaking concerning its review of the Pb NAAQS
no later than May 1, 2008 and September 1, 2008, respectively. To
ensure that the ordered final rulemaking deadline will be met, EPA has
set an interim target date for a proposed rulemaking of March 2008.
[[Page 71494]]
The EPA invites general, specific, and/or technical comments on all
issues discussed in this ANPR, including issues related to the Agency's
review of the primary and secondary Pb NAAQS (sections III and IV
below) and associated monitoring considerations (section V below). EPA
also invites comments on all information, findings, and recommendations
presented in this notice (section VI below).
A public meeting of the CASAC will be held on December 12-13, 2007
for the purpose of providing advice and recommendations to the
Administrator based on its review of this ANPR and the recently
released final Staff Paper and Risk Assessment Report. Information
about this meeting was published in the Federal Register on November
20, 2007 (72 FR 65335-65336).
E. Implementation Considerations
Currently only two areas in the United States are designated as
non-attainment of the Pb NAAQS. If the Pb NAAQS is significantly
lowered as a result of this review, it is likely (based on a review of
the current air quality monitoring data) that many more areas would be
classified as non-attainment (see section 2.3.2.5 of the Staff Paper
for more details). States with Pb non-attainment areas would be
required to develop ``State Implementation Plans'' that identify and
implement specific air pollution control measures that would reduce the
ambient Pb concentrations to below the Pb NAAQS. If the Pb NAAQS is
revised to a lower level, States may be able to attain the revised
NAAQS by implementing air pollution controls on lead emitting
industrial sources. These controls include such measures as fabric
filter particulate controls and fugitive dust controls. However, at
some of the lower Pb concentration levels that have been identified for
consideration in this review, it may become necessary in some areas to
implement controls on nonindustrial sources such as dust from roadways,
dust from construction, and/or demolition sites.
As described in further detail in the Staff Paper (see Section
2.2), Pb is emitted from a wide variety of source types. The top five
categories of sources of Pb emissions included in the EPA's 2002
National Emissions Inventory (NEI) include: Mobile sources; \11\
industrial, commercial, institutional and process boilers; utility
boilers; iron and steel foundries; and primary Pb smelting (see Staff
Paper Section 2.2).
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\11\ The emissions estimates identified as mobile sources in the
current NEI are currently limited to combustion of general aviation
gas in piston-engine aircraft. Lead emissions estimates for other
mobile source emissions of Pb (e.g., brake wear, tire wear, and
others) are not included in the current NEI.
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III. The Primary Standard
This section presents information relevant to the review of the
primary Pb NAAQS, including information on the health effects
associated with Pb exposures, results of the human exposure and health
risk assessment, and considerations related to evaluating the adequacy
of the current standard and alternative standards that might be
appropriate for the Administrator to consider.
A. Health Effects Information
The following summary focuses on health endpoints associated with
the range of exposures considered to be most relevant to current
exposure levels and makes note of several key aspects of the health
evidence for Pb. First, because exposure to atmospheric Pb particles
occurs not only via direct inhalation of airborne particles, but also
via ingestion of deposited particles (e.g., associated with soil and
dust), the exposure being assessed is multimedia and multi-pathway in
nature, occurring via both the inhalation and ingestion routes. In
fact, ingestion of indoor dust can be recognized as a significant Pb
exposure pathway, particularly for young children, for which dust
ingested via hand-to-mouth activity can be a more important source of
Pb exposure than inhalation, although dust can be resuspended through
household activities and pose an inhalation risk as well (CD, p. 3-27
to 3-28).\12\ Some studies have found that dietary intake of Pb may be
a predominant source of Pb exposure among adults, greater than
consumption of water and beverages or inhalation (CD, p. 3-43).\13\
Second, the exposure index or dose metric most commonly used and
associated with health effects information is an internal biomarker
(i.e., blood Pb). Additionally, the exposure duration of interest
(i.e., that influencing internal dose pertinent to health effects of
interest) may span months to potentially years, as does the time scale
of the environmental processes influencing Pb deposition and fate.
Lastly, the nature of the evidence for the health effects of greatest
interest for this review, neurological effects in young children, are
epidemiological data substantiated by toxicological data that provide
biological plausibility and insights on mechanisms of action (CD,
sections 5.3, 6.2 and 8.4.2).
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\12\ For example, the Criteria Document states the following:
``Given the large amount of time people spend indoors, exposure to
Pb in dusts and indoor air can be significant. For children, dust
ingested via hand-to-mouth activity is often a more important source
of Pb exposure than inhalation. Dust can be resuspended through
household activities, thereby posing an inhalation risk as well.
House dust Pb can derive both from Pb-based paint and from other
sources outside the home. The latter include Pb-contaminated
airborne particles from currently operating industrial facilities or
resuspended soil particles contaminated by deposition of airborne Pb
from past emissions.'' (CD, p. E-6)
\13\ Some recent exposure studies have evaluated the relative
importance of diet to other routes of Pb exposure. In reports from
the NHEXAS, Pb concentrations measured in households throughout the
Midwest were significantly higher in solid food compared to
beverages and tap water (Clayton et al., 1999; Thomas et al., 1999).
However, beverages appeared to be the dominant dietary pathway for
Pb according to the statistical analysis (Clayton et al., 1999),
possibly indicating greater bodily absorption of Pb from liquid
sources (Thomas et al., 1999). Dietary intakes of Pb were greater
than those calculated for intake from home tap water or inhalation
on a [mu]g/day basis (Thomas et al., 1999). The NHEXAS study in
Arizona showed that, for adults, ingestion was a more important Pb
exposure route than inhalation (O'Rourke et al., 1999). (CD, p. 3-
43)
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In recognition of the multi-pathway aspects of Pb, and the use of
an internal exposure metric in health risk assessment, the next section
describes the internal disposition or distribution of Pb, and the use
of blood Pb as an internal exposure or dose metric. This is followed by
a discussion of the nature of Pb-induced health effects that emphasizes
those with the strongest evidence. Potential impacts of Pb exposures on
public health, including recognition of potentially susceptible or
vulnerable subpopulations, are then discussed. Finally, key
observations about Pb-related health effects are summarized.
1. Internal Disposition--Blood Lead as Dose Metric
The health effects of Pb are remote from the portals of entry to
the body (i.e., the respiratory system and gastrointestinal tract).
Consequently, the internal disposition and distribution of Pb is an
integral aspect of the relationship between exposure and effect. This
section briefly summarizes the current state of knowledge of Pb
disposition pertaining to both inhalation and ingestion routes of
exposure as described in the Criteria Document.
Inhaled Pb particles deposit in the different regions of the
respiratory tract as a function of particle size (CD, pp. 4-3 to 4-4).
Lead associated with smaller particles, which are predominantly
deposited in the pulmonary region, may, depending on solubility, be
absorbed into the general circulation or transported to the
gastrointestinal tract (CD, pp. 4-3). Lead associated with larger
particles, which are predominantly deposited in the head and conducting
airways (e.g., nasal
[[Page 71495]]
pharyngeal and tracheobronchial regions of respiratory tract), may be
transported into the esophagus and swallowed, thus making its way to
the gastrointestinal tract (CD, pp. 4-3 to 4-4), where it may be
absorbed into the blood stream. Thus, Pb can reach the gastrointestinal
tract either directly through the ingestion route or indirectly
following inhalation.
Once in the blood stream, where approximately 99% of the Pb
associates with red blood cells, the Pb is quickly distributed
throughout the body (e.g., within days) with the bone serving as a
large, long-term storage compartment, and soft tissues (e.g., kidney,
liver, brain, etc) serving as smaller compartments, in which Pb may be
more mobile (CD, sections 4.3.1.4 and 8.3.1.). Additionally, the
epidemiologic evidence indicates that Pb freely crosses the placenta
resulting in continued fetal exposure throughout pregnancy, and that
exposure increases during the later half of pregnancy (CD, section
6.6.2).
During childhood development, bone represents approximately 70% of
a child's body burden of Pb, and this accumulation continues through
adulthood, when more than 90% of the total Pb body burden is stored in
the bone (CD, section 4.2.2). Accordingly, levels of Pb in bone are
indicative of a person's long-term, cumulative exposure to Pb. In
contrast, blood Pb levels are usually indicative of recent exposures.
Depending on exposure dynamics, however, blood Pb may--through its
interaction with bone--be indicative of past exposure or of cumulative
body burden (CD, section 4.3.1.5).
Throughout life, Pb in the body is exchanged between blood and
bone, and between blood and soft tissues (CD, section 4.3.2), with
variation in these exchanges reflecting ``duration and intensity of the
exposure, age and various physiological variables'' (CD, p. 4-1). Past
exposures that contribute Pb to the bone, consequently, may influence
current levels of Pb in blood. Where past exposures were elevated in
comparison to recent exposures, this influence may complicate
interpretations with regard to recent exposure (CD, sections 4.3.1.4 to
4.3.1.6). That is, higher blood Pb concentrations may be indicative of
higher cumulative exposures or of a recent elevation in exposure (CD,
pp. 4-34 and 4-133).
In several recent studies investigating the relationship between Pb
exposure and blood Pb in children (e.g., Lanphear and Roghmann 1997;
Lanphear et al., 1998), blood Pb levels have been shown to reflect Pb
exposures, with particular influence associated with exposures to Pb in
surface dust. Further, as stated in the Criteria Document ``these and
other studies of populations near active sources of air emissions
(e.g., smelters, etc.), substantiate the effect of airborne Pb and
resuspended soil Pb on interior dust and blood Pb'' (CD, p. 8-22).
Blood Pb levels are extensively used as an index or biomarker of
exposure by national and international health agencies, as well as in
epidemiological (CD, sections 4.3.1.3 and 8.3.2) and toxicological
studies of Pb health effects and dose-response relationships (CD,
Chapter 5). The prevalence of the use of blood Pb as an exposure index
or biomarker is related to both the ease of blood sample collection
(CD, p. 4-19; Section 4.3.1) and by findings of association with a
variety of health effects (CD, Section 8.3.2). For example, the U.S.
Centers for Disease Control and Prevention (CDC), and its predecessor
agencies, have for many years used blood Pb level as a metric for
identifying children at risk of adverse health effects and for
specifying particular public health recommendations (CDC, 1991; CDC,
2005a). In 1978, when the current Pb NAAQS was established, the CDC
recognized a blood Pb level of 30 [mu]g/dL as a level warranting
individual intervention (CDC, 1991). In 1985, the CDC recognized a
level of 25 [mu]g/dL for individual child intervention, and in 1991,
they recognized a level of 15 [mu]g/dL for individual intervention and
a level of 10 [mu]g/dL for implementing community-wide prevention
activities (CDC, 1991; CDC, 2005). In 2005, with consideration of a
review of the evidence by their advisory committee, CDC revised their
statement on Preventing Lead Poisoning in Young Children, specifically
recognizing the evidence of adverse health effects in children with
blood Pb levels below 10 [mu]g/dL and the data demonstrating that no
``safe'' threshold for blood Pb had been identified, and emphasizing
the importance of preventative measures (CDC, 2005a, ACCLPP, 2007).\14\
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\14\ With the 2005 statement, CDC identified a variety of
reasons, reflecting both scientific and practical considerations,
for not lowering the 1991 level of concern, including a lack of
effective clinical or public health interventions to reliably and
consistently reduce blood Pb levels that are already below 10 [mu]g/
dL, the lack of a demonstrated threshold for adverse effects, and
concerns for deflecting resources from children with higher blood Pb
levels (CDC, 2005a). CDC's Advisory Committee on Childhood Lead
Poisoning Prevention recently provided recommendations regarding
interpreting and managing blood Pb levels below 10 [mu]g/dL in
children and reducing childhood exposures to Pb (ACCLPP, 2007).
---------------------------------------------------------------------------
Since 1976, the CDC has been monitoring blood Pb levels nationally
through the National Health and Nutrition Examination Survey (NHANES).
This survey has documented the dramatic decline in mean blood Pb levels
in the U.S. population that has occurred since the 1970s and that
coincides with regulations regarding leaded fuels, leaded paint, and
Pb-containing plumbing materials that have reduced Pb exposure among
the general population (CD, Sections 4.3.1.3 and 8.3.3; Schwemberger et
al., 2005). The Criteria Document summarizes related information as
follows (CD, p. E-6).
In the United States, decreases in mobile sources of Pb,
resulting from the phasedown of Pb additives created a 98% decline
in emissions from 1970 to 2003. NHANES data show a consequent
parallel decline in blood-Pb levels in children aged 1 to 5 years
from a geometric mean of ~15 [mu]g/dL in 1976-1980 to 1-2 [mu]g/dL
in the 2000-2004 period.
While levels in the U.S. general population, including geometric mean
levels in children aged 1-5, have declined significantly, mean levels
have been found to vary among children of different socioeconomic
status (SES) and other demographic characteristics (CD, p. 4-21).\15\
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\15\ For example, while the 2001-2004 median blood level for
children aged 1-5 of all races and ethnic groups is 1.6 [mu]g/dL,
the median for the subset living below the poverty level is 2.3
[mu]g/dL and 90th percentile values for these two groups are 4.0
[mu]g/dL and 5.4 [mu]g/dL, respectively. Similarly, the 2001-2004
median blood level for black, non-hispanic children aged 1-5 is 2.5
[mu]g/dL, while the median level for the subset of that group living
below the poverty level is 2.9 [mu]g/dL and the median level for the
subset living in a household with income more than 200% of the
poverty level is 1.9 [mu]g/dL. Associated 90th percentile values for
2001-2004 are 6.4 [mu]g/dL (for black, non-hispanic children aged 1-
5), 7.7 [mu]g/dL (for the subset of that group living below the
poverty level) and 4.1 [mu]g/dL (for the subset living in a
household with income more than 200% of the poverty level). (https://
www.epa.gov/envirohealth/children/body_burdens/b1-table.htm_then
click on ``Download a universal spreadsheet file of the Body Burdens
data tables'').
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Bone measurements, as a result of the generally slower Pb turnover
in bone, are recognized as providing a better measure of cumulative Pb
exposure (CD, Section 8.3.2). The bone pool of Pb in children, however,
is thought to be much more labile than that in adults due to the more
rapid turnover of bone mineral as a result of growth (CD, p. 4-27). As
a result, changes in blood Pb concentration in children more closely