Children's Health Protection Advisory Committee
Co-Chairs:
Pamela Shubat, PhD
Environmental Health Division
Minnesota Department of Health
625 N. Robert Street
St. Paul, MN 55155-2538
(651)201-4925
pamela.shubat@health.state.mn.us
Sheela Sathyanarayana, MD, MPH
University of Washington
Department of Pediatrics
Seattle Children's Research Institute
2001 8th Avenue
Seattle, WA 98101
(206) 884-1037
Sheela.sathvanaravana
@seattlechildren's.org
Committee Members:
Robert Amler, MD
Susan Buchanan, MD, MPH
Tyra Bryant-Stephens, MD
Gail Cynthia Christopher, ND
Nancy Clark, MA, CIH, CSP
Jennifer Counts, PhD
Rochelle Davis
Maida Galvez, MD, MPH
Peggy Nilsson Geimer, MD
Aaron Henderson
David Jacobs, PhD, CIH
Robin Johnson, MD, MPH
Lloyd Kolbe, PhD, MS
Sandra W. Kuntz, PhD, APRN, CNS
Amy D. Kyle, PhD, MPH
Lawrence Lash, PhD
Jeanne Leffers, PhD, RN
Jennifer Lowry, MD
Leyla McCurdy, MPhil
Marie Lynn Miranda, PhD
Thomas Neltner, JD, CHMM
Nsedu Obot-Witherspoon, MPH
Jerome Paulson, MD, FAAP
Brenda Reyes, MD, MPH
Martha S. Sandy, PhD, MPH
AdamSpanier, MD, PhD, MPH
March 29, 2012
Lisa P. Jackson, Administrator
United States Environmental Protection Agency
1200 Pennsylvania Ave, NW
Washington, DC 20460
RE: Childhood Lead Poisoning Prevention
Dear Administrator Jackson:
The Children's Health Protection Advisory Committee (CHPAC) has been
asked by the Office of Children's Health Protection (OCHP) to provide
input on upcoming lead regulations being considered by the US
Environmental Protection Agency (EPA) as well as childhood lead
poisoning prevention activities across EPA and in partnership with
stakeholders and other agencies. In the past, EPA has played a
leadership role in reducing exposures to lead and CHPAC encourages
EPA to continue. Despite this, childhood lead poisoning remains a
persistent public health problem especially among children living in older,
poorly maintained housing, children under the age of six years, children of
color, and among high risk women who are exposed before and during
pregnancy. No "safe" threshold of exposure has ever been identified. This
demonstrates the need for EPA to examine its current and pending
policies and programs aimed at preventing childhood lead exposure and
to take action.
CHPAC is concerned that both Congress and this Administration must
continue—not abandon—the battle to protect children from lead
poisoning.1 As a leader in children's health protection, your immediate
and urgent attention to CHPAC's recommendations is needed. The US
Centers for Disease Control and Prevention (CDC) lead poisoning
prevention program for 2012 has been largely eliminated and CHPAC
believes EPA and US Housing and Urban Development (HUD) programs
have inadequate and increasingly fewer resources.
We recognize that many recent funding changes may be beyond the
control of an EPA administrator. However, the 1992 Residential Lead
Hazard Reduction Act (Title X) and other statutes provided EPA with
authority under the Toxic Substances Control Act to address certain key
lead exposure sources related to housing.2 EPA also has statutory
authority to address lead in air, drinking water, hazardous waste and
other media. Housing with deteriorated lead-based paint, contaminated
house dust and contaminated bare residential soil accounts for
70 percent of the nation's lead poisoning cases.3 Title X and related
Children's Health Protection Advisory Committee is a Federal Advisory Committee for the
U.S. Environmental Protection Agency under the Federal Advisory Committee Act
http://vosemite.epa.gov/ochp/ochpweb.nsf/content/whatwe advisorv.htm

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Administrator Jackson
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statutes mandate that the nation's lead poisoning prevention efforts involve a three-legged stool
to address the problem:
•	EPA sets standards for exposure, training for inspectors and abatement contractors,
environmental laboratory quality control, and disclosure (with HUD);
•	CDC develops guidance for clinicians, supports staffing and surveillance at local lead
poisoning prevention programs, conducts population-based prevalence studies to find
children at greatest risk, ensures blood lead laboratory quality control, and conducts
intervention in certain international disasters, such as the hundreds of children who died
from lead poisoning in Nigeria;4 and
•	HUD supports local lead hazard control programs and enforces lead requirements in
federally assisted housing programs.
Without all three legs, the nation cannot succeed in addressing childhood lead poisoning.
There are nearly half a million children who have blood lead levels above 5 |jg/dl_,5 which has
recently been recommended by the CDC Advisory Committee on Childhood Lead Poisoning
Prevention as the reference value.6 Over 30 million houses still have lead-based paint.7 The
National Toxicology Program recently drafted a major review showing the harm that lead does
to children, pregnant women and breast feeding mothers is even worse than we thought
previously, with sufficient evidence now available to conclude that at levels of exposure less
than 5 |jg/dl_, a relationship clearly exists linking lead with decreased academic achievement
and specific cognitive measures, increased incidence of attention deficit hyperactivity disorder
(ADHD) and problem behaviors.8
How can education be a priority for the nation if at the same time we ignore the impact of lead
exposure on academic achievement? One estimate for New York suggests that it costs $38,000
to provide three years of special education to a child.9 Many studies have shown that lead
poisoning prevention saves billions of dollars.10 More than that, it avoids needless pain and
suffering.
The retreat from childhood lead poisoning prevention will disproportionately affect children of
color and from low-income families where the risks are greatest. Increasing the disparities and
environmental injustices will only serve to add to the burden of these families. The Executive
Order regarding Environmental Justice has recently been updated.11
EPA's recent lead poisoning prevention efforts have been wanting, mainly due to inadequate
resources. EPA has taken only a few enforcement actions to implement its Renovation, Repair
and Painting Rule in the four years after it was promulgated. EPA rejected a proposed rule to
require dust lead testing following renovation to ensure cleanup is done properly and that
children are protected,12 as is already required in federally assisted housing and many local
rules.13 EPA has not updated its dust lead standard, despite reports from its Science Advisory
Board (SAB)14 and well-documented evidence that the existing standards promulgated more
than a decade ago do not protect children adequately.15,16 A recently published study also
shows that even in high risk houses treated 12 years ago in the HUD lead hazard control grant
program, dust lead levels of 10 |jg/ft2 on floors and 100 |jg/ft2 on window sills can be readily
obtained and are feasible. These levels are far lower than the current EPA dust lead standards,
which are 40 |jg/ft2 for floors and 250 |jg/ft2 for window sills.16
The EPA Administrator co-chairs the President's Task Force on Environmental Health and
Safety Risks to Children with the Secretary of Health and Human Services (HHS). Previously,

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this Task Force issued the first federal interagency strategy to eliminate childhood lead
poisoning.17 The country did not meet the goals set for 2010. We recommend that the
Administrator meet with the HHS Secretary and convene a cabinet-level Task Force meeting to
determine how the federal government's lead poisoning prevention activities can be restored to
meet existing and new sources of lead exposure endangering our children. Specifically, such a
meeting should determine how the nation can avoid ending lead poisoning prevention programs
at hundreds of local health departments due to loss of CDC funding beginning this August.
CHPAC response to EPA charge questions
In July 2011, CHPAC was briefed on several current lead regulations under development at
EPA and subsequently considered a set of OCHP charge questions. Based on these
considerations, EPA should take actions on its own and/or with appropriate partners to address
four overarching CHPAC recommendations:
I.	Adopt a unified approach across EPA actions regarding target blood lead levels;
II.	Engage other federal agencies and stakeholders on implementing lead poisoning
prevention actions and communication strategies;
III.	Identify emerging sources of lead exposure and children who may be at risk for these
exposure sources; and
IV.	Eliminate production of residential lead-based paint and the production of other sources
of lead exposure in other countries.
I. CHPAC Recommends that EPA adopt a unified approach across EPA actions regarding
target blood lead levels.
I.a. CHPAC recommends that EPA revise its Integrated Exposure Uptake
Biokinetic (IEUBK) model for estimating children's blood lead levels associated
with different and multiple exposure pathways. Historically, EPA has used the IEUBK
model18 to attempt a unified approach to estimating potential blood lead levels from
environmental and other data. While the IEUBK model has been helpful in the past,
there are important limitations that CHPAC believes can be overcome in part by
simultaneous consideration of epidemiological data, consistent with recommendations
made by EPA's SAB.14 An important limitation of the model is the lack of a dust lead
loading metric. Instead, the model only permits input of dust lead concentration (loading
refers to lead mass divided by surface area (|jg/ft2) while concentration refers to lead
mass divided by total sample weight (mg/kg)). Dust lead exposure has been shown to be
one of the most significant sources of exposure to children and loading is the most
appropriate metric for exposure.19 The lack of the loading metric in the IEUBK model
means that conversion factors needed to be developed for use in the model, which
introduces another potential source of error. The model also necessitates the use of
default terms that may or may not be relevant to a specific regulatory action. CHPAC
agrees with the SAB recommendation that epidemiological studies should be evaluated
as well, because they do not require the use of conversion factors or default
assumptions. This recommendation will enable EPA policymakers to understand all
scientific evidence from both the IEUBK model and epidemiological data.
I.b. CHPAC recommends that EPA adopt an incremental approach to specifying
target blood lead levels. Ideally, regulations should be crafted to eliminate exposures
entirely and that should be an expressed goal in all EPA regulations. Because it is not
possible to eliminate all exposures, EPA regulatory actions should produce consistent

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results by using an incremental rather than a static target blood lead level. The blood
lead metric is both a measure of exposure and a measure of toxicity. Traditionally, EPA
has set an exposure limit for dust that is expected to achieve a static target blood lead
level, such as 1 or 5 or 10 |jg/dL. The alternative is to select and use incremental levels
in dust, soil, food, water, air and other relevant media that result in a corresponding
incremental change in blood lead level, such that the incremental change is no greater
than 1 or 2.5 |jg/dL. CHPAC believes that an incremental approach to exposure
assessment is superior, because it is more likely to be able to account for measured and
estimated contributions to exposures from all exposure pathways. However, programs
across EPA must also agree on the overall limit for an incremental change in blood level
(this will be based on the corresponding decrement in a health or cognitive measure
such as IQ). This recommendation is consistent with EPA's SAB14 and its Clean Air
Science Advisory Committee.20
I.e. CHPAC recommends that EPA collect data from its Environmental Lead
Proficiency Analytical Testing Program and assess feasibility for reliably
measuring low environmental lead levels and also analyze housing data to assess
the feasibility of meeting lower residential dust lead exposure limits. An important
consideration for lead poisoning prevention regulations is whether a given exposure limit
can be reliably measured and is achievable and is sustainable, because there is little
benefit to setting a regulatory standard that no one can meet or cannot be measured.
CHPAC recommends that EPA assess the ability of laboratories to detect levels of lead
in environmental samples as an essential component of its Environmental Lead
Proficiency Analytical Testing Program (ELPAT). This program provides standardized
approaches for assessing proficiency (e.g., blind testing of samples with known
quantities of lead) and assesses specific laboratory performance. CHPAC recommends
that EPA collect data on laboratory detection and reporting limits as part of its ELPAT
program to inform its regulatory efforts as they apply to feasibility. With regard to cost-
effectiveness, CHPAC recommends that EPA consider the health impact of regulatory
decisions and the costs associated with decrements to health, not just the cost
associated with compliance. EPA should also analyze new data from long-term follow-up
studies of the HUD Lead Hazard Control Grant Program to determine the feasibility of
meeting lower exposure limits for lead dust. EPA should revise the Renovation, Repair
and Painting rule to include clearance testing, which at this time is the only validated
method that has been correlated with children's blood lead levels,21 and it is the only
method that has a quality control system in place (the ELPAT).
I.d. CHPAC recommends developing new, evidence-based health protective lead
dust standards. Perform research and/or analyze existing data to determine what dust
loading standards are, in fact, health protective. Develop laboratory methodologies to
permit routine, precise and accurate dust loading measurements in the necessary range.
Incorporate the new standards into ongoing lead management education programs.
I.e. CHPAC recommends that EPA review hazard control studies across EPA
actions, including revisions to the Lead and Copper Rule. Durability of exposure
controls should be examined by EPA as it considers revisions to its Lead and Copper
Rule for drinking water. Specifically, EPA should examine the long-term effectiveness of
managing hazards from lead service lines through drinking water chemistry interventions
intended to reduce lead content in drinking water. CHPAC also recommends that any
revised regulation for drinking water end the practice of partial lead pipe replacements,

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which has been shown to at least temporarily increase lead in drinking water.22 Any new
regulation should provide the legal foundation to permit leaded drinking water lines to be
replaced completely, not only up to the property line.
II. CHPAC Recommends that EPA engage other federal agencies and stakeholders on
implementing lead poisoning prevention actions and communication strategies.
II.a. CHPAC recommends that the EPA Administrator and the Secretary of Health
and Human Services convene a cabinet-level meeting of the Interagency Task
Force on Children's Environmental Health and Safety Risks to develop and
coordinate strategies to advance childhood lead poisoning prevention through
enforcement, training and education of public health and health care
professionals, communication strategies, and engagement of other stakeholders.
CHPAC believes that one of the biggest areas of untapped opportunity in lead poisoning
prevention involves concerted and coordinated enforcement of existing laws with the
Department of Justice, State Attorneys General, local prosecutors and local health,
environmental and housing advocates. EPA should partner with the Health Resource
Service Administration (HRSA) and CDC, Health Maintenance Organizations (HMOs)
and health insurance companies to ensure that funds available for prevention, such as
those in the Affordable Care Act are used in a way that incorporates lead hazard control
activities. There are also important steps that other agencies, such as CDC, the Food
and Drug Administration (FDA) and the Consumer Product Safety Commission (CPSC),
can take to protect children and families from contaminated consumer products,23
especially those imported from other countries. For example, FDA and other agencies
should take action to prevent contaminated food, herbal remedies, and pottery from
entering the country and prevent lead shot fragments in the food chain. CPSC should
ensure that products recalled due to lead contamination are not allowed to be sent to
other countries where they could poison children. EPA should work with the
Occupational Safety and Health Administration (OSHA) to ensure workers do not
inadvertently take home lead on contaminated work clothing, vehicles, or other work
items and to conduct workforce training. CDC should continue to provide increased
technical assistance to countries battling epidemics of childhood lead poisoning, such as
the recent catastrophe in Nigeria that resulted in hundreds of children's deaths from lead
poisoning.4
II.b. CHPAC recommends that EPA engage health and other professionals who can
play an important role in providing information for families and communities regarding
other sources of lead exposure such as take-home lead from the workplace (renovation
sites, battery manufacturers, etc.), hobbies, sporting equipment (making lead weights for
fishing lines at home), and reloading of ammunition used for hunting. CHPAC
recommends that EPA work with other federal agencies, such as HHS and its Maternal
and Child Health Bureau (MCHB) and HUD, to standardize training of non-traditional
workers and utilize them to implement evidence-based lead exposure reduction
strategies and educate residents at the community level. CHPAC recommends that EPA
provide guidance for training of residents and practicing physicians as well as other
healthcare providers about the harmful effects of lead exposure and avoidance
practices. EPA should partner with American Academy of Pediatrics, American Academy
of Family Practitioners, American College of Obstetricians and Gynecologist, and CDC
to create a module for maintenance of certification on lead exposure, lead monitoring
and avoidance practices. EPA should partner with HHS operating divisions (CDC,

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Administrator Jackson
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HRSA, and MCHB) to create a training module for physicians, nurse practitioners, and
allied health professional that can be integrated into medical training.
III.	CHPAC recommends that EPA identify emerging sources of lead exposure to children
and women who are or may become pregnant or who are breastfeeding. Further research
is needed to identify emerging sources of lead exposure, such as those in consumer products.
The nation still has no good assessment of exposures related to consumer products containing
lead, like toys, jewelry, cosmetics, pottery, and batteries, especially those from other countries.
For example, it is not known whether new lead-based residential paint now being manufactured
in China, India, Nigeria and other countries is being imported into the US. Research is needed
to determine if lead stabilizers used in plastics and other products is being released. Fate and
transport studies are needed to determine sources of lead production and use in commercial
products. Further research is needed to estimate exposures from commercial buildings.
Sampling protocols to reliably measure lead in water in different building configurations is
needed, and policy research is needed to determine the best way to stop partial replacement of
lead drinking water lines. Specifically, the current practice is for public utilities to replace only the
portion of the lead drinking water line on public property, with the owner expected to pay for the
pipe replacement on the private property, which often cannot occur because owners do not
have adequate resources.
IV.	CHPAC recommends that EPA work to eliminate production of residential lead-based
paint and the production of other sources of lead exposure in other countries. EPA
should continue to provide financial and technical support for the Global Alliance to Eliminate
Lead in Paints through the United Nations Environment Programme (UNEP) and the World
Health Organization (WHO).24 EPA should also support voluntary compliance programs for lead
production activities in developing nations, such as BEST (Better Environmental Sustainability
Targets).25 EPA should work with the State Department, WHO and UNEP to help prevent lead
exposures to refugees and others, and to promote international trade agreements and other
instruments to eliminate the unnecessary use of lead in consumer and other products, as
recommended by the American Public Health Association.26
CHPAC urges you to consider these recommendations. We have the knowledge and ability to
ensure our children do not suffer from lead poisoning, which is entirely preventable.27 Our goal
to protect children from lead has not yet been achieved, and the problem remains large. CHPAC
urges you to continue the campaign to end childhood lead poisoning.
Thank you for your consideration of our recommendations and suggestions.
Respectfully,
Pamela Shubat, Ph.D.
CHPAC Co-Chair
Sheela Sathyanarayana, M.D., M.P.H.
CHPAC Co-Chair
cc: Peter Grevatt, Director, Office of Children's Health Protection
Gina McCarthy, Assistant Administrator, Office of Air and Radiation
Steve Page, Office Director, Office of Air Quality Planning and Standards

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Jim Jones, Acting Assistant Administrator, Office of Chemical Safety and Pollution
Prevention
Wendy Cleland-Hamnet, Office Director, Office of Pollution Prevention and Toxics
Cynthia Gyles, Assistant Administrator, Office of Enforcement and Compliance
Assurance
Pam Mazakas, Office Director, Office of Civil Enforcement
Mathy Stanislaus, Assistant Administrator, Office of Solid Waste and Emergency
Response
Jim Woolford, Office Director, Office of Superfund Remediation and Technology
Innovation
Nancy Stoner, Acting Assistant Administrator, Office of Water
Pam Bar, Acting Office Director, Office of Ground Water and Drinking Water
Lek Kadeli, Acting Assistant Administrator, Office of Research and Development
Becki Clark, Acting Director, National Center for Environmental Assessment
Endnotes
1	The President's budget for 2012 proposed to cut in half the lead poisoning prevention program at CDC.
Congress in the final budget appropriation reduced the CDC lead poisoning prevention program from
$30 million to only $2 million. As a result, health departments' lead programs across the country will be
forced to shut down as early as the summer of 2012, severely limiting the nation's ability to properly
identify children who are at risk and take action before harm is done.
2	Residential Lead-Based Paint Hazard Reduction Act of 1992 (Title X of Public Law 102-550)
www.hud.gov/offices/lead/librarv/lead/Title X.pdf
3	Levin R, Brown MJ, Kashtock ME, Jacobs DE, Whelan EA, Rodman J, Schock MR, Padilla A, Sinks T.
2008. Lead Exposure in US Children, 2008: Implications for Prevention. Environmental Health
Perspectives 116:1285-1293
4	Dooyema CA, Neri A, Lo YC, Durant J, Dargan PI, Swarthout T, Biya O, Gidado SO, Haladu S, Sani-
Gwarzo N, Nguku PM, Akpan H,ldris S, Bashir AM, Brown MJ. 2012. Outbreak of Fatal Childhood Lead
Poisoning Related to Artisanal Gold Mining in Northwestern Nigeria, 2010. Environmental Health
Perspectives 120:601-607
5	In 2005-06, data from the National Health and Nutrition Examination Survey showed that an estimated
590,100 children 1-5 had blood lead levels > 5 |jg/dL; in 2007-08 that number increased to 646,400; in
2009-10 the number declined slightly to 442,000 (data from: National Performance Measures of Blood
Lead in Children. Will Wheeler Presentation to the CDC Advisory Committee on Childhood Lead
Poisoning Prevention Nov 14, 2011)
6	Advisory Committee on Childhood Lead Poisoning Prevention of the Centers for Disease Control and
Prevention. 2012. Low Level Lead Exposure Harms Children: A Renewed Call for Primary Prevention.
http://www.cdc.gov/nceh/lead/ACCLPP/Final Document 030712.pdf
7	Jacobs DE, Clickner RL, Zhou JL, Viet SM, Marker DA, Rogers JW, Zeldin DC, Broene P and Friedman
W. 2002. The Prevalence of Lead-Based Paint Hazards in U.S. Housing. Environmental Health
Perspectives 110:A599-A606

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8	National Toxicology Program. 2011. Draft NTP monograph on health effects of low-level lead. National
Institute of Environmental Health Sciences, National Institutes of Health, U.S. Department of Health And
Human Services http://ntp.niehs.nih.qov/?obiectid=4F04B8EA-B187-9EF2-9F9413C68E76458E
9	Korfmacher, KS. 2003. Long-term costs of lead poisoning: How much can New York save by stopping
lead? http://www.afhh.org/action/action local lead costs NYrep.pdf
10
Gould E. 2009. Childhood lead poisoning: Conservative estimates of social and economic costs of lead
hazard control. Environmental Health Perspectives 117:1162-1167
11	Memorandum of Understanding on Environmental Justice and Executive Order 12898
(http://www.doi.gov/oepc/EJ MOU.pdf) and HHS 2012 Environmental Justice Implementation Progress
Report 02/12 (http://www.hhs.gov/environmentaliustice/progress 2012.pdf)
12	Lead; Clearance and Clearance Testing Requirements for the Renovation, Repair, and Painting
Program, Environmental Protection Agency, Final rule. 47918 Federal Register Vol. 76, No. 151 Friday,
August 5, 2011
13	HUD Lead Safe Housing Rule, 24 CFR Part 35.
http://portal.hud.gov/hudportal/documents/huddoc?id=DOC 12347.pdf
14	SAB letter to the EPA Administrator, July 7, 2011.
http://vosemite.epa.gov/sab/sabproduct.nsf/CD05EA314294B683852578C60060FB08/$File/EPA-SAB-
11-008-unsigned-revised.pdf
15	Gaitens JM, Dixon SL, Jacobs DE, Nagaraja J, Strauss W, Wilson JW, Ashley PJ. 2009. U.S.
Children's Exposure to Residential Dust Lead, 1999-2004: I. Housing and Demographic Factors
Associated with Lead-contaminated Dust, Environmental Health Perspectives 117: 461-467; and
Dixon SL, Gaitens JM, Jacobs DE, Strauss W, Nagaraja J, Pivetz T, Wilson JW, Ashley PJ. 2009. U.S.
Children's Exposure to Residential Dust Lead, 1999-2004: II. The Contribution of Lead-contaminated
Dust to Children's Blood Lead Levels, Environmental Health Perspectives 117: 468-474
16	Dixon SL, Jacobs DE, Wilson JW, Akoto JY, Nevin R, Clark CS. 2012. Window replacement and
residential lead paint hazard control 12 years later. Environmental Research. Accepted Jan 23, 2012.
17	Eliminating Childhood Lead Poisoning: A Federal Strategy, President's Task Force on Children's
Environmental Health Risks and Safety Risks, principal author, Washington DC (March 2000).
http://www.epa.gov/lead/pubs/fedstrategy2000.pdf
18	EPA user materials for the IEUBK model. See http://www.epa.gov/superfund/lead/products.htm
19	Lanphear BP, Matte TD, Rogers J, Clickner RP, Dietz B, Bornschein RL, Succop P, Mahaffey KR,
Dixon S, Galke W, Rabinowitz, Farfel M, Rohde C, Schwartz J, Ashley PJ, Jacobs DE. 1998. The
Contribution of Lead-Contaminated House Dust and Residential Soil to Children's Blood Lead Levels: A
Pooled Analysis of 12 Epidemiologic Studies, Environmental Research, 79:51-68
on
Lead Integrated Science Assessment CASAC Lead Review Panel. See
http://vosemite.epa.gov/sab/SABPRQDUCT.NSF/81e39f4c09954fcb85256ead006be86e/546fdc6ecc836f
158525795f0049242f!QpenDocument
21 Lanphear BP, Emond E, Weitzman M, Jacobs DE, Tanner M, Winter N, Yakir B, Eberly S. 1995. A
Side-By-Side Comparison of Dust Collection Methods for Sampling Lead-Contaminated House Dust,
Environmental Research 68, 114-123

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22	Brown MJ, Raymond J, Homa D, Kennedy C, Sinks T. 2011. Association between children's blood lead
levels, lead service lines, and water disinfection, Washington, DC, 1998-2006. Environmental Research
111 (2011) 67-74
23	Toys and other consumer products recalled. See http://www.cdc.gov/nceh/lead/Recalls/allhazards.htm
24	WHO Global Alliance to Eliminate Lead in Paints. See
http://www.who.int/ipcs/features/pb alliance/en/index.html
25	Occupational Knowledge International certification standard for lead battery manufacturers. See
http://www.okinternational.org/lead-batteries/BEST-Standard
26	American Public Health Association policy statement on lead. See
http://www.apha.org/advocacv/policv/policvsearch/default.htm?id=1348
27	Lanphear BP. 2007. The Conquest of Lead Poisoning: A Pyrrhic Victory. Environmental Health
Perspectives 115:A484-A485

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