EPA STRATEGY TO
REDUCE LEAD EXPOSURES
AND DISPARITIES
IN U.S. COMMUNITIES







www.epa.gov/lead

OCTOBER 2022


-------
EPA Strategy to Reduce
Lead Exposures and Disparities
in U.S. Communities

Published: October 27, 2022
EPA Publication Number: 540R22006


-------
TABLE OF CONTENTS

PREFACE	3

EXECUTIVE SUMMARY	5

LIST OF ACRONYMS	7

GLOSSARY OF TERMS	9

INTRODUCTION	11

LEAD STRATEGY STRUCTURE AND APPROACHES	14

LEAD STRATEGY GOALS AND OBJECTIVES	16

GOAL 1: REDUCE COMMUNITY EXPOSURES TO LEAD SOURCES	16

Objective A: Reduce Exposure to Lead in Homes and Child-Occupied Facilities with Lead-Based Paint
and Other Hazards	16

Objective B: Reduce Exposure to Lead from Drinking Water	21

Objective C: Reduce Exposure to Lead in Soils	29

Objective D: Reduce Exposure to Lead Associated with Emissions to Ambient Air	33

Objective E: Reduce Exposure to Lead Through Enforcement and Compliance Assurance	37

GOAL 2: IDENTIFY COMMUNITIES WITH HIGH LEAD EXPOSURES AND

IMPROVE THEIR HEALTH OUTCOMES	41

GOAL 3: COMMUNICATE MORE EFFECTIVELY WITH STAKEHOLDERS	45

GOAL 4: SUPPORT AND CONDUCT CRITICAL RESEARCH TO INFORM EFFORTS TO REDUCE LEAD
EXPOSURES AND RELATED HEALTH RISKS	50

CONCLUSION AND IMPLEMENTATION OF EPA's LEAD STRATEGY	56

APPENDIX: PERFORMANCE MEASURES AND MILESTONES	57


-------
PREFACE

At EPA, our mission is to protect people's health and the environment. Fulfilling our mission
requires that all people - regardless of the color of their skin, money in their pocket, or the
community they live in -benefit equally from the protections of our environmental laws and
policies.

Although naturally occurring, lead is undoubtedly one of society's most pervasive
environmental toxins. Lead exposure can have devastating impacts to human health and can be
especially harmful to developing children. We also know that because of existing racial and
socioeconomic disparities, communities that have been historically marginalized and
overburdened suffer the most. That's why on day one, President Biden committed to advancing
environmental justice and equity and directed every member of his Cabinet to embed
environmental justice into our decision-making.

At EPA, we have been hard at work embedding these values into the Agency's DNA. As part of
our commitment to advancing environmental justice and equity, I'm proud to present the U.S.
Environmental Protection Agency's (EPA) Strategy to Reduce Lead Exposures and Disparities in
U.S. Communities. The Lead Strategy will advance EPA's work to protect all people from lead
with an emphasis on high-risk communities. The strategy also reflects EPA's commitment to
fulfilling the Biden-Harris Administration's historic deployment of resources to replace lead
pipes and support lead paint removal under the Lead Pipe and Paint Action Plan.

I've traveled a lot as Administrator, but earlier this year I took a trip I'll never forget. Vice
President Harris and I visited Milwaukee to discuss how, with the help of Bipartisan
Infrastructure Law funding, we are working to remove lead pipes in communities across the
country. We met with a mother whose life had been turned upside down after she discovered
lead in her home. Her little boy was lead-poisoned and hospitalized repeatedly. Tragedies like
this unfortunately are not unique. Far too many families have a similar story, and the time to do
better is now.

EPA developed the Lead Strategy to lay out an ambitious plan to strengthen public health
protections and address legacy lead contamination for communities with the greatest
exposures. Through transformative funding from both the Bipartisan Infrastructure Law and the
Inflation Reduction Act, we will help communities identify and remove lead service lines and
eliminate lead from contaminated soil. EPA's Lead Strategy builds on the goals and objectives
set forth in the Federal Action Plan to Reduce Childhood Lead Exposures and Associated Health
Impacts published in 2018, and emphasizes efforts to protect children's health while also
addressing the racial and socioeconomic disparities of lead exposures in U.S. communities.

Engaging with communities across the country, as well as with federal, Tribal, state, and local
government partners, was an integral part of developing the Lead Strategy. In fact, EPA
engaged in an unprecedented effort to host public listening sessions in each of its 10
geographic regions and hosted an engagement session forTribes. EPA carefully considered the


-------
feedback provided during these sessions and the input brought us to a final version of the Lead
Strategy.

The Lead Strategy also includes meaningful performance measures that will track the Agency's
progress toward meeting the goals of the strategy. These performance measures demonstrate
our commitment to addressing led contamination and will hold EPA accountable to our
obligation to protect public health. EPA will provide annual reporting on its progress on our

website.

I want to thank the co-chairs of EPA's Lead Strategy Team—Carlton Waterhouse, Deputy
Assistant Administrator for EPA's Office of Land and Emergency Management, and Deborah
Jordan, Deputy Regional Administrator in EPA Region 9, as well as the co-chairs of the Lead
Coordinating Committee — Paul Amato and Ken Davidson in EPA Region 9, as well as Matthew
Lambert and Stiven Foster of EPA's Office of Land and Emergency Management — for their
leadership in developing and finalizing the Lead Strategy.

Every day, we are a step closer to achieving a lead-free future for all, and together, I know we
will make this vision a reality.

Michael S. Regan

Administrator, U.S. Environmental Protection Agency

4


-------
EXECUTIVE SUMMARY

The U.S. Environmental Protection Agency (EPA) developed this Strategy to Reduce Lead
Exposures and Disparities in U.S. Communities (Lead Strategy) to lay out an all-of-EPA plan to
strengthen public health protections, address legacy lead contamination for communities with
the greatest exposures, and promote environmental justice and equity.

Engaging with federal, tribal, state, and local government partners and the Agency's many
stakeholders was an integral part of developing this Lead Strategy. On October 28, 2021, EPA
released the draft and solicited feedback from the public through March of 2022. During the
public comment period, EPA hosted 11 public listening sessions on the draft, one in each of
EPA's 10 regions and an engagement session for tribes. The public also submitted hundreds of
substantive comments about the draft and thousands of additional comments were submitted
through mass comment campaigns. As a result of this concerted outreach, EPA received
feedback from a wide array of stakeholders and community members from around the country.
Public commenters shared many thoughtful ideas and impassioned perspectives on how to
improve the Lead Strategy and how EPA and the whole of government can better address lead
contamination in communities. EPA has carefully considered the comments received on the
draft, and public input has substantially improved the final version. The final Lead Strategy also
includes measures for tracking the Agency's progress in meeting the actions described within
the strategy, as well as milestones for regulatory actions and updates to guidance and
communication products.

Very low levels of lead in children's blood have been linked to adverse effects on intellect,
concentration, and academic achievement.1 The United States has made substantial progress in
reducing lead exposure, but significant disparities remain along racial, ethnic, and
socioeconomic lines. For example, Black children and those from low-income households have
persistently been found to have higher blood lead levels than non-Hispanic white children and
those from higher income households.2 Under this strategy, EPA will focus on eliminating the
disparities in blood lead levels by taking specific actions to prevent childhood exposures and
exposure inequities that could lead to lifelong health effects and barriers to social and
economic well-being.

The Biden-Harris Administration and EPA Administrator Michael Regan are committed to
addressing ongoing exposures to lead, exposure inequities, and associated health impacts in
communities across the nation. EPA developed the Lead Strategy to build on 40 years of
progress in reducing lead in the environment and to focus attention on overburdened
communities with environmental justice and civil rights concerns, consistent with the Executive
Order on Advancing Equity and Support for Underserved Communities Through the Federal

1	U.S. Environmental Protection Agency (2013) https://cfpub.epa.gov/ncea/isa/recordisplav.cfm?deid=255721

2	Egan et al. "Blood Lead Levels in U.S. Children Ages 1- 11 Years, 1976 - 2016" Env. Health Pers. (2021) 129(3):
https://doi.org/10.1289/EHP7932

5


-------
Government.3 The Lead Strategy also reflects EPA's commitment to fulfilling the Biden-Harris
Administration's historic commitment of resources to replace lead pipes and support lead paint
removal under the Lead Pipe and Paint Action Plan.4

The Fiscal Year 2022-2026 EPA Strategic Plan commits the Agency to taking actions that
minimize public health disparities.5 EPA's Lead Strategy will help achieve that ambitious
objective by significantly reducing lead exposure for all people and eliminating inequities in
elevated blood lead levels across population groups and life stages. To accomplish this
objective, the Lead Strategy sets out four key goals:

1)	Reduce community exposures to lead sources.

2)	Identify communities with high lead exposures and improve their health outcomes.

3)	Communicate more effectively with stakeholders.

4)	Support and conduct critical research to inform efforts to reduce lead exposures and
related health risks.

These four goals align with the goals in the 2018 Federal Action Plan to Reduce Childhood Lead
Exposure, which focused broadly on protecting children's environmental health.6 EPA's Lead
Strategy also seeks to protect children's health but particularly emphasizes reducing lead
exposure in communities with persistent disparities in children's blood lead levels and
promoting environmental justice and equity.

The Lead Strategy defines challenges to achieving each of these goals and identifies actions the
Agency will take to address them. Despite great progress over the past few decades to reduce
lead exposure, EPA still has important work to do, especially in communities already burdened
by pollution and other stressors. Exposure sources and pathways for lead are complex and
numerous, including lead-based paint, house dust, drinking water, soil, and air. Exposures can
be greatest and pose significant health risks to young children, who may also be exposed in
utero. Working locally, nationally, and with a whole of government approach, EPA is
determined to take ambitious actions that follow the science and advance justice and equity to
rid communities of harmful lead exposure and the resulting toxic effects.

3	https://www,whitehouse,gov/briefing-room/presidential-actions/2021/01/20/executive-order-advancing-racial-
equitv-and-support-for-underserved-communities-through-the-federal-government/

4	httpsi//www,wliitelioyse,eo₯/briefine-room/statemerits-releases/2021/12/16/fact-slieet jlie-:bideri-harris-lead--
pipe-and-pajnt-action-plan/

5	https://www.epa,eov/svstem/files/documents/2022-03/fv-2022-2026-epa-strategic-plan,pdf

6	https://www.epa.gov/sites/default/files/201S-12/documents/fedactionplan lead final.pdf

6


-------
LIST OF ACRONYMS

ATSDR - Agency for Toxic Substances and Disease Registry

Avgas - Aviation Gasoline

BIL - Bipartisan Infrastructure Law

CDC - Centers for Disease Control and Prevention

CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act

CHPAC - Children's Health Protection Advisory Committee

CPSC - Consumer Product Safety Commission

DLCL - Dust-Lead Clearance Levels

DLHS - Dust-Lead Hazard Standards

DOJ - Department of Justice

DWSRF - Drinking Water State Revolving Fund

EAGLE - Eliminate Aviation Gasoline Lead Emissions

ELSWPEO - Enhancing Lead-Safe Work Practices through Education and Outreach

EPA - Environmental Protection Agency

FAA - Federal Aviation Administration

FDA - Food and Drug Administration

FY - Fiscal Year

HHS - Department of Health and Human Services

HUD - Department of Housing and Urban Development

IEUBK - Integrated Exposure Uptake Biokinetic Model

IQ- Intelligence Quotient

ISA - Integrated Science Assessment

LCR - Lead and Copper Rule

LCRI - Lead and Copper Rule Improvements

LCRR - Lead and Copper Rule Revisions

LSL - Lead Service Line

LSLR - Lead Service Line Replacement

MOU - Memorandum of Understanding

NAAQS - National Ambient Air Quality Standard

NLPPW - National Lead Poisoning Prevention Week

NPDWR - National Primary Drinking Water Regulation

P&CBs - Public and Commercial Buildings

PAFI - Piston Aviation Fuels Initiative

Pb - Lead

PEHSU - Pediatric Environmental Health Specialty Units
PPA - Prospective Purchaser Agreement
RCRA - Resource Conservation and Recovery Act
RRP - Renovation, Repair and Painting

SC DHEC - South Carolina Department of Health and Environmental Control
SDWIS - Safe Drinking Water Information System
SEP - Supplemental Environmental Project

7


-------
SHEDS - Stochastic Human Exposure and Dose Simulation Model

SRF - State Revolving Fund

TSCA - Toxic Substances Control Act

USDA - United States Department of Agriculture

WIIN - Water Infrastructure Improvements for the Nation Act


-------
GLOSSARY OF TERMS

Blood Lead Level: The amount of lead in blood is referred to as the blood lead level, which is
measured in micrograms of lead per deciliter of blood (|ag/dL).

Cumulative Impacts: The total burden (i.e., health, ecological, aesthetic, historic, cultural,
economic, and/or social effects) that may result from chemical and non-chemical stressors,
exposures from multiple routes or sources, and factors that differentially affect exposure or
toxicity to communities.

Disadvantaged: Historically marginalized and overburdened.

Disproportionate Effects/Impacts: Situations of concern where there exists significantly higher
and more adverse health and environmental effects on people of color, low-income
populations or indigenous peoples.

Environmental Justice: The fair treatment and meaningful involvement of all people regardless
of race, color, national origin, or income with respect to the development, implementation and
enforcement of environmental laws, regulations, and policies.

Equity: The consistent and systematic fair, just, and impartial treatment of all individuals,
including individuals who belong to underserved communities that have been denied such
treatment, such as Black, Latino, and Indigenous and Native American persons, Asian Americans
and Pacific Islanders and other persons of color; members of religious minorities; lesbian, gay,
bisexual, transgender, and queer (LGBTQ+) persons; persons with disabilities; persons who live
in rural areas; and persons otherwise adversely affected by persistent poverty or inequality.

Exposure: Human contact with contaminants, such as lead, in media including air, water, soil,
dust, paint, food, and consumer/cultural products.

Fair Treatment: Fair treatment means no group of people should bear a disproportionate share
of the negative environmental consequences resulting from industrial, governmental, and
commercial operations or policies.

Hot Spot: A geographic area with a high level of pollution/contamination within a larger
geographic area of lower or more "normal" environmental quality.

Life Stage: A distinguishable time frame in an individual's life characterized by unique and
relatively stable behavioral and/or physiological characteristics that are associated with
development and growth that are characterized by economic resources.

Low-income: A reference to populations characterized by limited economic resources.

9


-------
Meaningful Involvement: Meaningful involvement means people have an opportunity to
participate in decisions about activities that may affect their environment and/or health; the
public's contribution can influence the regulatory agency's decision; community concerns will
be considered in the decision-making process; and decision makers will seek out and facilitate
the involvement of those potentially affected.

Overburdened: People of color, low-income, tribal, or indigenous populations or geographic
locations in the United States that potentially experience disproportionate environmental
harms and risks. This disproportionality can be as a result of greater vulnerability to
environmental hazards, lack of opportunity for public participation, or other factors. Increased
vulnerability may be attributable to an accumulation of negative or lack of positive
environmental, health, economic, or social conditions within these populations or places. The
term describes situations where multiple factors, including both environmental and socio-
economic stressors, may act cumulatively to affect health and the environment and contribute
to persistent environmental health disparities.

Risk: The probability of an adverse effect in an organism, system, or population caused under
specified circumstances by exposure to a contaminant, such as lead, or stressor.

Risk Management: In the context of human health, a decision-making process that accounts for
political, social, economic, and engineering implications together with risk-related information
in order to develop, analyze, and compare management options and select the appropriate
managerial response to a potential chronic health hazard.

Stakeholders: Broadly defined as persons concerned with the decisions made about how a risk
may be avoided, mitigated, or eliminated, as well as those who may be affected by regulatory
decisions.

Stressor: A stressor is any physical, chemical, or biological entity that can induce an adverse
response. Stressors may adversely affect specific natural resources or entire ecosystems,
including plants and animals, as well as the environment with which they interact.

Underserved Communities: Populations sharing a particular characteristic, as well as
geographic communities, that have been systematically denied a full opportunity to participate
in aspects of economic, social, and civic life, as exemplified in the preceding definition of
"equity."


-------
INTRODUCTION

In March of 2022, the U.S. Environmental Protection Agency (EPA) released the Fiscal Year (FY)
2022-2026 EPA Strategic Plan (Strategic Plan). The Strategic Plan communicates the Agency's
priorities and provides a roadmap for achieving its mission to protect human health and the
environment.7 One of the Strategic Plan's goals is to take action to advance environmental
justice and civil rights by achieving tangible progress for historically overburdened and
underserved communities. EPA's Strategy to Reduce Lead Exposures and Disparities in U.S.
Communities (Lead Strategy) will help achieve the Strategic Plan's ambitious objective by
addressing elevated blood lead levels in children at the greatest risk of exposure. This Lead
Strategy provides a framework to help achieve this goal and emphasizes the importance of
addressing racial, ethnic, and socioeconomic disparities in lead exposure from all sources.

EPA also has as one of its priorities ensuring that entities receiving any federal financial
assistance from EPA comply with Title VI of the Civil Rights Act of 1964, which prohibits
discrimination on the basis of race, color, or national origin (including limited English
proficiency), and with other federal civil rights laws that prohibit discrimination on the basis of
disability, sex, and age, as well as with EPA's nondiscrimination regulation at 40 C.F.R. Parts 5
and 7. Recipients of financial assistance from EPA have an affirmative obligation to ensure their
actions do not involve discriminatory treatment and do not have discriminatory effects. EPA will
work to ensure that the relevant actions described in the Lead Strategy will adhere to these civil
rights requirements.

Regulatory actions by EPA and other federal agencies have significantly reduced the use of lead
in automotive gasoline, paint, lead-soldered food containers, and plumbing water system
components (e.g., pipes, fittings, solder, and fixtures) in the past 40 years. Despite significant
progress in reducing lead exposures, EPA needs to continue its work to equitably protect
people of all races, ethnic groups, income levels, disabilities, and life stages, including young
children and pregnant women, who are the most vulnerable to the toxic effects of lead.

Children living in communities overburdened by pollution and other health and social stressors,
often communities of color and lower socioeconomic status, are at greater risk. For example,
lead-based paint, lead service lines (LSLs), and plumbing fixtures containing lead are more likely
to be found in older houses in lower-income areas. Communities of color can also face greater
risk due to the legacy of redlining, historic racial segregation in housing, and reduced access to
environmentally safe and affordable housing.8 Industrial sources of lead are more likely to be
closer to lower income neighborhoods and communities of color where soils in residential and
public places can be contaminated.

7	https://www.epa.gov/svstem/files/documents/2022-03/fv-2022-2Q26-epa-strategic-plan.pdf. Note that EPA's
"fiscal year" begins on October 1st and ends on September 30th of each year.

8	Williams, David R., et.al. "Racism and Health: Evidence and Needed Research" Annual Review of Public Health
(2019) 40:105-125. https://doi.org/10.1146/annurev-publhealth-040218-04375Q.


-------
Children are more susceptible than adults to an array of adverse health effects associated with
lead.9,10 This can relate to exposures across all childhood life stages. For example, exposures of
pregnant and nursing women can increase prenatal exposures. Fetuses can be exposed through
the placenta, and infants can be exposed through breast milk and formula made with lead-
contaminated water. Children can be exposed through "take home" exposures such as lead
carried home on a work uniform or work shoes, from their care givers, and other people. Even
very low levels of lead in children's blood have been linked to adverse effects on intellect,
concentration, and academic achievement. These effects may have later-in-life impacts on an
exposed individual's quality of life. Additionally, longer-term lead exposure over a lifetime is
associated with increased risk of other effects, such as increased blood pressure and
hypertension, which can lead to coronary heart disease.

Numerous and disparate sources of lead, coupled with many federal, tribal, state, and local
agencies having separate legal authorities to address those sources, create a challenging
landscape for tackling the problem. EPA and its federal partners need new approaches to
protect communities still experiencing the highest childhood blood lead levels by reducing
children's exposures to lead sources. EPA's Lead Strategy focuses the Agency's efforts to reduce
lead exposures in communities by addressing multi-media exposure pathways with all our
applicable statutory authorities and other tools, across all our relevant programs, and in
coordination with our federal partners, tribes, and other stakeholders.11

Engaging with federal, tribal, state, and local government partners and the Agency's many
stakeholders is an integral part of strategic planning. On October 28, 2021, EPA released the
draft Lead Strategy and solicited feedback from the public through March of 2022. During the
public comment period, EPA hosted 11 public listening sessions on the draft, one in each of
EPA's 10 regions and an engagement session for tribes.12 Participants were provided an
opportunity to provide verbal comments during these sessions, the transcripts of which were
submitted to the public docket that was created for the Lead Strategy.13

The public also submitted to the docket hundreds of substantive comments about the draft
Lead Strategy and thousands of additional comments submitted through mass comment

9	Environmental Protection Agency, Integrated Science Assessment for Lead: littpsi//www,epa,eo₯/isa/integrated-
science-assessment-isa-lead

10	Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological profile for Lead. (2020) Atlanta, GA: U.S.
Department of Health and Human Services, Public Health Service. DOI: 10.15620/cdc:95222

11	EPA also recognizes that the effect of cumulative impacts (i.e., the total burden from chemical and non-chemical
stressors) is best understood and addressed in specific situations to appropriately address public health risk. EPA is
currently developing a consistent and comprehensive framework for assessing and considering cumulative impacts
on populations and communities in its policies, programs, and activities. Such a framework will incorporate the
vulnerabilities and susceptibilities related to the accumulation of multiple environmental and social stressors,
which include those associated with lead. We anticipate that in the future, the Lead Strategy will reflect this
cumulative impacts framework as appropriate.

12	Recordings of these listening sessions are available at this website: https://www,epa,gov/lead/draft-strategy-
reduce-lead-expqsures-and-disparities-us-comm unities.

13	https://www.regulations.gov/docket/EPA-HQ-OLEiyi-2021-0762

12


-------
campaigns. EPA received feedback from a wide array of stakeholders and community members
from around the country. Public commenters shared many thoughtful ideas and impassioned
perspectives on how to improve the Lead Strategy and how EPA and the whole of government
can better address lead contamination in communities. EPA has carefully considered the
comments it received and has summarized the key themes from this public engagement in the
strategy. The public input the Agency received has substantially improved the final version of
the Lead Strategy.

As EPA implements this Lead Strategy, it will rely on scientific research and evidence as the
basis for decision making to mitigate lead exposure from all environmental sources of lead.14
For example, we will continue advancing and applying science for children's blood lead
modeling and exposure mapping, for contaminated soils remediation, and location of drinking
water LSLs. EPA expects that this strategy will be updated to ensure that we continue to engage
with stakeholders, to rely on the best available science, and to use clear relevant measures and
milestones to track our progress towards the goals of this strategy. The period for this strategy
is aligned with the Fiscal Year (FY) 2022-2026 EPA Strategic Plan and the measures and
milestones described below are generally expected to be completed annually or by the fall of
2026.

The remainder of the Lead Strategy is organized as follows. The first section outlines the goals
of the strategy, as well as the broad approaches the Agency has developed to achieve them.
The second section describes each Lead Strategy goal in detail. For each goal there is a
description of the problem, a summary of the relevant key themes the Agency received from
public comments, a list of the performance measures and milestones the Agency will use to
track and report progress associated with each goal, and detailed descriptions of specific
actions the Agency is taking, or will take, to achieve each goal. The final section provides
conclusions and next steps for EPA's Lead Strategy. An Appendix at the end of this document
lists all the performance measures and milestones that are included in the Lead Strategy.

14 Foundations of Evidence-Based Policymaking Act of 2018: https://www.epa.gov/data/foundations-eyidence-
based-policvmaking-act-2018

13


-------
LEAD STRATEGY STRUCTURE AND APPROACHES

EPA's Lead Strategy is organized around goals that align with those developed in the 2018
Federal Action Plan to Reduce Childhood Lead Exposure (Federal Lead Action Plan). The Federal
Lead Action Plan was produced by 17 federal agencies, including EPA, that serve on the
President's Task Force on Environmental Health Risks and Safety Risks to Children.15 Like the
2018 Federal Lead Action Plan, EPA's Lead Strategy seeks to protect children's health but places
a particular emphasis on reducing lead exposure in communities as a means to reduce
persistent inequities in children's blood lead levels and promoting environmental justice.

The four key goals of the Lead Strategy include:

Goal 1: Reduce Community Exposures to Lead Sources

Goal 2: Identify Communities with High Lead Exposures and Improve Their Health
Outcomes

Goal 3: Communicate More Effectively with Stakeholders

Goal 4: Support and Conduct Critical Research to Inform Efforts to Reduce Lead

Exposures and Related Health Risks

The Lead Strategy defines challenges to achieving each of these goals and, for each goal,
describes specific actions the Agency will take to address them. EPA has organized each of
these actions by three "approaches" that will guide how and where the Agency will accelerate
efforts to reduce lead exposures and eliminate racial and socioeconomic disparities in blood
lead levels across the United States. Those approaches are:

APPROACH 1: Reduce lead exposures locally with a focus on communities with
disparities and promote environmental justice

EPA will work with our partners to identify communities where lead exposure and blood
lead levels persist and are known or reasonably suspected to be highest, and then will
determine the dominant sources and cumulative exposure pathways. EPA will
subsequently use this knowledge and evidence-based best practices to focus the
Agency's actions, using all its tools to reduce health risk. EPA will also ensure that
regulations are developed and implemented so that they protect communities from
local exposures to lead.

APPROACH 2: Reduce lead exposures nationally through updated protective
standards, analytical tools, and outreach

EPA will work to prevent and reduce lead exposures by developing and implementing
national standards, policy, and guidance; updating regulations; enforcing regulations
and statutory requirements; using analytical tools, conducting research, and applying

15 https://www.epa.gov/lead/federal-action-plan-reduce-childhood-lead-exposure

14


-------
evidence to improve the scientific foundations for methods to reduce and mitigate lead
exposure; and soliciting stakeholder input to inform Agency decisions.

APPROACH 3: Reduce lead exposures with a "whole of EPA" and "whole of
government" approach

EPA will create and target opportunities to collaborate across EPA programs and with
federal partners and other governmental stakeholders, including states, tribes, cities,
and counties, as well as non-governmental organizations and industry stakeholders, to
focus the full range of resources to reduce lead exposures from all sources in the most
vulnerable communities across the country.16 The Agency will use evidence-based
strategies for communication and outreach designed to reduce these exposures.

EPA will use scientific research and evidence-based approaches to prioritize and focus the
Agency's actions. EPA's national program offices and ten regions will take a multi-pronged
approach by working at the national and community levels; tackling lead contamination across
all exposure pathways; and partnering with other federal agencies to combine resources and
authorities to take on the challenge of reducing blood lead level disparities in specific
communities.

The actions EPA will take to achieve these ambitious goals reflect consideration of the many
thoughtful comments the Agency received during the public comment period. EPA has also
identified performance measures and milestones the Agency will use to track and measure its
progress in meeting these goals and objectives. The development of performance measures
and milestones that accompany the Lead Strategy demonstrates EPA's commitment to
addressing legacy lead contamination by strengthening public health protections from all
routes of lead exposure. But there is still work to do; the Agency has not developed a
performance measure or milestone for every action described in this strategy. Many of the
actions described in this strategy have not yet been, or have only recently been, initiated and
funded. These out-year activities are subject to the availability of appropriations. As these
programs mature, so too will EPA's ability to set targets for measuring performance.

Where relevant, the Lead Strategy also presents specific case studies of past or ongoing EPA
actions to reduce lead exposure that can serve as models for future work.

16 Breysse, P, et.al. 'Targeting Coordinated Federal Efforts to Address Persistent Hazardous Exposures to Lead"
American Journal of Public Health (2022) 112, S640_S646, httm://doi. ora/10.2105/AJPH. 2022.306972

15


-------
LEAD STRATEGY GOALS AND OBJECTIVES

GOAL 1: REDUCE COMMUNITY EXPOSURES TO LEAD SOURCES

Problem: Lead exposure results from multiple sources. For example, longstanding sources of
lead exposure remain in homes, schools, child care facilities, and other buildings with lead-
based paint, old water distribution systems, and household plumbing. Soils of residential yards,
parks, and schoolgrounds across the United States also can be contaminated with lead.
Underserved and under-resourced communities are especially vulnerable to lead
contamination due to aging infrastructure and poor maintenance. EPA will leverage all its
regulatory, technical advisory, and risk management tools to provide greater protection to
communities from the effects of lead.

Because the actions necessary to reduce community exposures to lead are spread across
multiple routes of exposure, the Lead Strategy has identified five separate objectives specific to
achieving Goal 1:

Objective A: Reduce Exposure to Lead in Homes and Child-Occupied Facilities with Lead-
Based Paint and Other Hazards

Objective B: Reduce Exposure to Lead from Drinking Water
Objective C: Reduce Exposure to Lead in Soils

Objective D: Reduce Exposure to Lead Associated with Emissions to Ambient Air
Objective E: Reduce Exposure to Lead Through Enforcement and Compliance Assurance

Objective A: Reduce Exposure to Lead in Homes and Child-Occupied Facilities with Lead-Based

Paint and Other Hazards

Problem: Millions of people, especially those living in communities with environmental justice
concerns, continue to be exposed to lead at home and in other buildings where lead-based
paint is found in deteriorating condition (peeling, chipping, cracking, or damaged). Communities
that have a high percentage of housing or buildings built before 1978 —and especially those
built before 1940 — are at higher risk from historical use of lead-based paint.

Public Input:

Community and Contractor Training: Commenters on the draft Lead Strategy were widely
supportive of the Enhancing Lead-Safe Work Practices through Education and Outreach
(ELSWPEO) initiative. The initiative's purpose is to serve local communities and advance
environmental justice by increasing both the number of Renovation, Repair and Painting (RRP)
certified firms and the consumer demand for lead-safe work practices. This two-pronged
approach was designed to raise awareness about potential lead exposure while renovating

16


-------
older homes and making certified contractors more readily available in overburdened and
underserved communities across the country. Commenters requested more training and more
resources for communities with environmental justice concerns.

EPA appreciates support for the initiative, begun in 2021. In the future, EPA is committed to
supporting communities with environmental justice concerns by ensuring that certified
contractors are readily available to these communities. EPA is also committed to increasing
awareness of the hazards of lead in communities with environmental justice concerns through
training and outreach, thus increasing demand for certified contractors and improving the
public health of the community. To emphasize the dual goals of improving the general
understanding of lead dangers and increasing the supply of contractors available in
communities with environmental justice concerns, EPA will take two separate actions
consistent with Approach 1: Reduce Lead Exposures Locally, one to ensure that certified
contractors are more readily available in underserved communities, and another to improve
awareness in underserved communities of the dangers of lead-based paint.

Addressing Demolitions: Commenters requested that EPA address ongoing contamination from
demolitions and deconstruction in housing and public and commercial buildings (P&CBs).
Commenters stated that large amounts of dust and debris can be created during demolitions
which eventually end up in soil. Dust can spread to nearby properties and contaminate soil and
the interiors of homes.

EPA regulates partial demolitions of target housing and child-occupied facilities under the
existing RRP rule. In addition, the Toxic Substances Control Act (TSCA) Title IV provides EPA the
authority to regulate demolitions (and deleading) of P&CBs under Lead-based Paint Activities.
While EPA is not currently taking steps to promulgate additional regulations under Lead-based
Paint Activities authority, EPA is working on addressing P&CBs under a RRP rule that could
cover partial demolitions.

Rulemaking Timelines: Commenters expressed concern about EPA's progress in addressing
TSCA Title IV rulemaking obligations, including the Definition of Lead Based Paint, Soil Lead
Hazard Standards, and renovations in P&CBs, and urged EPA to commit to specific outcomes of
the rulemaking process, considering impacts to housing and exposure within communities with
environmental justice concerns.

EPA is committed to setting health protective standards and will use the best available science
for these rulemakings. The regulatory impact analyses for these rules will specifically consider
the impact on communities with environmental justice concerns. However, EPA cannot
prejudge the results of the analyses conducted to support the rulemaking and therefore cannot
commit to specific outcomes of the process.

TSCA Section 6 Authority: Commenters requested that EPA designate lead as a "high priority"
substance under TSCA for Section 6 risk evaluation and risk management. Stakeholders

17


-------
suggested this would be the most expeditious way to address total demolition, recreational
consumer products, non-residential lead paint, multimedia exposure, and legacy disposal.

EPA must have at least 20 chemical risk evaluations ongoing at any given time on High-Priority
Substances with at least half of those risk evaluation on chemicals drawn from the 2014 TSCA
Work Plan. Therefore, because lead and lead compounds are on the TSCA Work Plan, they will
at some point be brought into the TSCA existing chemicals prioritization process and if
designated as high priority, will undergo evaluation under section 6(b) of TSCA.

Cultural and Religious Products: Public comments on the draft Strategy included the
importance of raising awareness of lead from non-traditional sources such as cultural and
religious products and cookware and their disproportionate impact on certain communities,
such as recently settled refugees. Public commenters recommended dissemination of
information regarding lead exposure in these products through culturally informed public
awareness campaigns.

Performance Measures and Milestones:

•	By September 30, 2023, provide free or low-cost training to 500 contractors that are located
in and around communities with environmental justice concerns spread throughout the U.S.
over fiscal years 2022 and 2023.

•	By September 30, 2023, host national and community-based Lead Awareness Curriculum
sessions for 515 community leaders and Understanding Lead sessions for 340 community
members, which reflects a 10% increase in participation from fiscal year 2022 to fiscal year
2023.

•	By March 2023, publish the Heavy Metals in Cultural Products: Outreach and Educational
Resources Toolkit on the EPA website.

•	By February 2023, propose, and by June 2024, finalize the Dust-lead Hazard Standards
(DLHS) and Dust-lead Clearance Levels (DLCL) Rule.

EPA ACTIONS:

APPROACH 1: Reduce lead exposures locally with a focus on communities with disparities and
promote environmental justice

•	Ensure that certified contractors are more readily available in underserved communities:

EPA's Lead RRP Rule requires that firms performing RRP projects that disturb lead-based
paint in homes, child care facilities and preschools built before 1978 be certified by EPA (or
an EPA-authorized state, tribe, or territory) and use certified contractors who follow lead-
safe work practices. It can be difficult for people to find certified contractors to perform
these renovations. Free or low-cost RRP training, in either English or Spanish depending on
location, provided by EPA will increase the number of certified contractors located in and
around underserved and low-income communities. This encourages lead-safe work
practices and reduces lead exposure during renovations of pre-1978 housing. For fiscal


-------
years 2022 and 2023, EPA is providing this training in conjunction with community training
in the ELSWPEO initiative.

•	Improve awareness in underserved communities of the dangers of lead-based paint: An

important step in improving a community's health is raising awareness of the dangers of
lead-based paint and other lead hazards. EPA will continue to increase awareness by
offering free virtual webinars and/or in-person sessions in English and, when requested, will
provide simultaneous Spanish interpretation of the "Lead Awareness Curriculum Train-the-
Trainer" and "Understanding Lead" sessions. EPA is also striving to provide Understanding
Lead sessions in additional languages to address the needs of other communities with
limited English proficiency as they are identified. EPA will offer Lead Awareness Curriculum
Train-the-Trainer sessions for community leaders on how to educate their communities
about lead, lead exposures and actions that can be taken to reduce lead exposure, with a
focus on how to use and modify the Lead Awareness in Indian Country: Keeping our Children
Healthy! Curriculum for each community leader's specific audience. EPA will also offer
Understanding Lead sessions for anyone interested in learning about lead. For fiscal years
2022 and 2023, EPA is providing these sessions as part of the ELSWPEO initiative, which also
includes training for contractors.

APPROACH 2: Reduce lead exposures nationally through protective standards, analytical

tools, and outreach

•	Revisit the DLHS and DLCL: EPA has initiated a rule to reconsider the DLHS and DLCL in
accordance with the Executive Order 13990 and consistent with a May 2021 court decision
by the Ninth Circuit.17,18 Lead inspectors, risk assessors, and abatement professionals use
the DLHS to determine if dust-lead hazards are present and the DLCL to evaluate the
effectiveness of cleaning following an abatement in target housing (i.e., built before 1978)
and child-occupied facilities. As part of this rule, EPA plans to amend its regulatory
definition of target housing to conform with a 2017 statutory change to clear up regulatory
ambiguity and extend the regulatory coverage to zero-bedroom dwellings (e.g., studio
apartments) where children live.

•	Revisit the definition of lead-based paint: EPA will, in collaboration with the Department of
Housing and Urban Development (HUD), revisit the definition of lead-based paint, assess
the relevant scientific evidence, and if appropriate, revise the definition to make it more
protective. The definition is incorporated throughout the lead-based paint regulations, and
application of this definition is central to how the lead-based paint program functions. EPA
is currently evaluating next steps on this issue in light of the May 2021 court decision by the
Ninth Circuit.19

17	https://wyyyy.federalregister.gov/executive-order/13990

18	A Cmty. Voice v. U.S. EPA, 997 F.3d 983 (9th Cir. 2021),

https://cdn,ca9,uscourts,gov/datastore/opinions/2021/05/14/19~71930,pdf

19	A Cmty. Voice v. U.S. EPA, 997 F.3d 983 (9th Cir. 2021),

https://cdn,ca9,uscourts,gov/datastore/opinions/2021/05/14/19-71930,pdf

19


-------
•	Support lead-safe renovations in public and commercial buildings: EPA will continue its
work to evaluate risk from renovations of public and commercial buildings pursuant to TSCA
§ 402(c)(3) that directs EPA to promulgate regulations for renovations in target housing,
public buildings built before 1978, and commercial buildings that create lead-based paint
hazards. EPA will determine whether such renovations create lead-based paint hazards,
and, if they do, EPA will address any lead-based paint hazards by promulgating work
practice, training, and certification requirements for public and commercial buildings.

APPROACH 3: Reduce lead exposures with a "whole of EPA" and "whole of government"

approach

•	Collaborate on lead paint rulemakings: EPA will collaborate with HUD and other federal
agencies on rulemakings to address lead-based paint hazards, including dust, soil, and the
definition of lead-based paint. Closer coordination will improve the federal government's
ability to collectively address lead-based paint hazards.

•	Collaborate to address potential exposures to lead from food, cosmetics and consumer
products, and cultural/religious products: EPA will collaborate with the Food and Drug
Administration and the Consumer Product Safety Commission (CPSC) to address other
sources of potential lead exposure, such as foods, cosmetics, art supplies, herbal and folk
remedies, non-commercial pottery, recalled toys, jewelry, furniture, and other consumer
goods.

•	Develop an education and outreach toolkit focused on children's health and pregnant
women that identifies existing resources on lead (and other heavy metals) in cultural
products and cookware: This toolkit will serve as a resource for culturally competent
educational and outreach materials for members of various communities concerned about
lead contamination in culturally specific products.

•	Work internationally to assist other countries to establish laws to protect children and
consumers from lead-containing paint: More than 100 countries still allow the
manufacture and sale of paint with high levels of lead; most of them are lower- and middle-
income countries. Communities in lower- and middle-income countries, especially
underserved and vulnerable populations with children living in poverty, are
disproportionately at risk for health impacts from exposures to lead paint and other lead
sources. Building on the success of phasing out lead in gasoline globally, EPA is working
through a multi-stakeholder, international partnership to provide individual countries with
guidance on drafting strong and effective laws to regulate lead-based paint.

REGIONAL COMMUNITY CASE STUDY: St. Joseph, Missouri is a beautiful, vibrant city on the

Missouri River that struggles with a high incidence of elevated blood lead levels in children.

Blood lead level testing data from 2014-2017 showed between 16 and 20 percent of children

tested in St. Joseph zip code 64501 had blood lead levels at or above 5 ug/dl. Although the U.S.


-------
government banned consumer lead-based paint in 1978, lead-based paint, including lead-
contaminated dust generated from it, remains one of the leading causes of lead exposure in the
United States. In St. Joseph, most residential lead hazards come from homes built before 1978.

To combat this critical public health problem, EPA's Region 7 formed a cross-program outreach
team to raise awareness about lead-based paint hazards in the home. The team focused on
child care providers, renovators (professional and do-it-yourself), and the public. The team held
numerous events with state, local, and federal partners that educated child care providers,
trained home renovators, facilitated discussions with community leaders, conducted lead
screening in children, and provided important information to St. Joseph residents. In addition,
the St. Joseph Health Department, Kansas City Missouri Health Department, EPA, and HUD held
partnership meetings focused on leveraging resources and acquiring new ones to address lead
hazards in the community. This resulted in $90,000 to provide lead abatement work for low-
income families living in pre-1978 housing. The team's effort culminated in a lead education
summit, where federal, state, and local agencies, local nonprofits, and health providers came
together to discuss next steps for preventing lead poisoning in St. Joseph. While the effort to
reduce blood lead levels is ongoing, Region 7 is proud of the great strides St. Joseph and other
partners have made to prevent exposures to lead in their community.

Objective B: Reduce Exposure to Lead from Drinking Water

Problem: Lead exposure through drinking water continues to be a serious risk in many
communities, including those facing other environmental justice concerns. Lead can enter
drinking water from plumbing materials that contain lead or from lead pipes that connect the
home to the water main, also known as LSLs. In homes with LSLs, these pipes are typically the
most significant source of lead in the water. Among homes without LSLs, the most common
lead exposure problems are with old brass or chrome-plated brass faucets and plumbing with
lead solder. The amount of lead allowed in new pipes, solder, flux fittings or fixtures was limited
in 1986 and further reduced in 2014. Galvanized pipes are also a concern because they may
accumulate lead from upstream sources.

There are still 6 to 10 million LSLs in cities and towns across the country.20 Many of these are in
communities of color or low-income communities. The Biden-Harris Administration has set a
goal of removing 100% of LSLs. The Bipartisan Infrastructure Law (BlL)21 will provide a historic
$15 billion in funding - the first-ever dedicated federal funding - to address lead in drinking
water by replacing service lines and carrying out associated activities that are directly
connected to identifying, planning, designing, and replacing LSLs. All LSL replacement projects
funded by the BIL must replace the entire LSL. To address household affordability concerns, EPA
strongly encourages states to fund the private portion of service line replacements at no

20	Cornwell, D.A, et.al. "National Survey of Lead Service Line Occurrence. Journal American Water Works
Association" (2016) 108(4): E182-E191.

https://awwa.onlinejibrary.wilev.com/doi/abs/10.5942/iawwa.2016.108.0086

21	Also referred to as the Infrastructure Investment and Jobs Act, P.L 117-58 (Nov. 15, 2021).

21


-------
additional cost to the homeowner This means that a significant potential source of lead
exposure from drinking water will be eliminated for millions of families.

Unfortunately, the locations of lead pipes, solder, faucets, and fixtures are not always known,
which presents challenges for eliminating lead exposure from drinking water. Although
replacing LSLs and in-home water systems is quite costly, reducing drinking water lead exposure
generates significant health benefits for communities. EPA's 2021 economic analysis of the
costs and benefits of LSL replacement estimates that the labor and material costs of identifying,
excavating, and replacing LSLs are accompanied by significant increases in lifetime earnings
associated with avoided intelligence quotient (IQ) loss in children, and also noted that other
adverse health effects might be reduced as well.22

Public Input: Public comments related to lead and drinking water fell into several categories.
Many comments focused on the importance of ensuring equitable access and distribution of BIL
funding and resources in disadvantaged23 and tribal communities, improving lead regulations,
and enhancing programs for better protection of children in schools and child care facilities.

Public comments related to lead regulations focused on actions EPA should take to update the
Lead and Copper Rule Revisions, ensure equity in lead service line replacement (LSLR), develop
protective health-based standards, and improve public education. In addition, many comments
proposed creating incentives to encourage states, utilities, communities, and others to embark
upon full LSLR. The comments noted utilizing loans (e.g., Drinking Water State Revolving Funds
(DWSRF)), grants (e.g., Water Infrastructure Improvements for the Nation Act (WIIN)), and
voluntary programs.

Public comments related to how disadvantaged communities, and other communities such as
tribes, can access the resources they need to adequately address lead in drinking water focused
on use of BIL funds through the DWSRF to ensure equitable distribution of funds and resources.

Public comments related to protecting children in schools and child care facilities focused on
actions EPA should take to ensure disadvantaged communities have access to funds (e.g., WIIN
grants, BIL funds) for lead testing and remediation and asking EPA to ensure a coordinated
federal response providing resources, requiring lead testing and remediation, and addressing all
sources of lead exposure to children. In addition, public comments indicated EPA should
continue to provide training, outreach, and technical assistance to schools and child care
facilities.

22	httpsi//www,regulations,gov/document/EPA-HQ-QW-2017-0300-1769

23	For the purposes of Goal 1, Objective B, a small or disadvantaged community is one: that the state determines to
be a disadvantaged community under SDWA section 1452(d)(3) or may become a disadvantaged community as a
result of carrying out a project or activity; or, with a population of less than 10,000 individuals that does not have
the capacity to incur debt sufficient to finance a project to comply with the SDWA. Source:

https://www,epa,gov/sites/default/files/2019~

03/documents/assistance for small and disadvantaged communities factsheet 508.pdf

22


-------
EPA responds to this input through the actions described below. EPA is working to improve its
regulations to control lead in drinking water and has prioritized resources and technical
assistance to tribal communities as well as disadvantaged communities focused on replacing
lead services lines and reducing lead in drinking water. EPA continues to actively engage with
other agencies to leverage resources and better coordinate across the federal government,
tribes, water utilities, non-federal organizations, and the public health community. Together
with our federal partners, EPA intends to work with stakeholder communities in developing and
strengthening initiatives to reduce drinking water lead exposure in disadvantaged communities
and elsewhere.

Performance Measures and Milestones:

•	Track and report total funds to disadvantaged communities for projects that support
reduction of lead in drinking water.

•	By the end of 2022, partner with four states to establish LSLR Accelerators, which will
provide targeted technical assistance and develop best practices to help address the
barriers disadvantaged communities face in replacing LSLs.

•	By the end of 2022, conduct outreach on the new "Guidance for Developing and
Maintaining a Service Line Inventory" to help water systems develop LSL inventories as soon
as possible to begin replacement programs and no later than the Lead and Copper Rule
Revisions compliance deadline of October 2024.24

•	By the end of 2023, propose, and by October 2024, take final action on the Lead and Copper
Rule Improvements to strengthen the regulatory framework and address lead in drinking
water.

EPA ACTIONS:

APPROACH 1: Reduce lead exposures locally with a focus on communities with environmental
justice concerns

•	Target communities with lead in drinking water concerns: EPA will identify community
water systems with lead in drinking water concerns. EPA will then work with the states to
target technical assistance and provide funding to reduce lead exposure within these
communities, particularly in disadvantaged communities. The Agency understands the
effects of LSLs on communities, including those with environmental justice concerns, and
will focus on identifying and implementing solutions to identify and replace LSLs. EPA's
strategies, which continue to be tailored through community engagement, include
improving public outreach and education, encouraging the proactive and full replacement
of LSLs, providing technical assistance on proper sampling techniques, improving corrosion
control treatment, and supporting the 3Ts (Training, Testing, and Taking Action) programs
to reduce lead in drinking water at schools and child care facilities.

24 https://www.epa,gov/ground~water-and~drinking-water/revised~lead~and~copper-rule

23


-------
Consistent with the public comments, EPA continues to engage federal and non-federal
partners to coordinate data sharing to better target disadvantaged and other communities
with high levels of lead in drinking water. For example, EPA plans to collaborate with state
partners to launch a new EPA technical assistance initiative called LSLR Accelerators.

Starting in fall 2022, EPA will pilot the Accelerators in partnership with four states. The
Accelerators will address existing barriers and accelerate progress towards the Biden-Harris
Administration's goal of 100 percent LSLR. Disadvantaged communities struggling with LSL
identification and replacement may have limited technical, operational, and financial
resources. This technical assistance initiative will help those communities address barriers
by providing the tools needed to accelerate LSLR. EPA and the participating states will also
work to actively share lessons learned with other states, tribes, territories, local
municipalities, and public water systems.

• Provide DWSRF assistance to reduce lead in drinking water: The BIL provides $15 billion
through the DWSRF to replace LSLs and carry out associated activities that are directly
connected to the identification, planning, design, and replacement of LSLs. There is no state
match requirement for these funds, and 49% of the money will be provided as grants or
principal forgiveness loans to communities. States can also use funds from the additional
$11.7 billion in general-purpose DWSRF funds appropriated through the BIL for the
identification, planning, design, and replacement of LSLs.

EPA will increase awareness, particularly in small, underserved communities and
communities of color, about programs and funding opportunities to replace LSLs, regardless
of ownership, and reduce lead in drinking water. Funding from these programs can replace
LSLs, including lines on private property; develop LSL inventories; install or improve
corrosion control treatment (using BIL general supplemental funds); and remove lead from
drinking water in schools and child care facilities.

EPA will encourage states to ensure that BIL LSLR funding reaches disadvantaged
communities and will encourage states to leverage other funds, such as base and BIL
supplemental DWSRF funds to meet their LSLR needs. EPA released an implementation
memorandum in March 2022 that provides information and guidelines on how EPA will
implement the State Revolving Fund (SRF) program, including the capitalization grants
appropriated to states under the law.25 The implementation memorandum is expected to
be applicable to all five years of BIL appropriations. In addition, to address household
affordability concerns and encourage full and rapid LSLR, EPA encourages state DWSRF
programs to fund the private portion of LSLR projects at no additional cost to private
property owners. In particular, EPA encourages states and water systems to include low-
income homeowners, and landlords or property owners providing housing to low-income
renters in LSLR prioritization and private-side funding programs.

https://www.epa.gov/dwsrf/bipartisan-jnfrastructure-law-srf-memorandum

24


-------
EPA will collaborate with state SRF programs to share models and guidance, and to build
state capacity to assist local communities and ensure LSL funding is effectively and equitably
deployed. In particular, EPA will work with state partners to ensure that small, underserved
communities, communities of color, and other communities with high infrastructure
resource needs benefit from this funding. Finally, EPA will evaluate additional reporting
requirements for DWSRF projects to capture the impact of funding, including funds reaching
disadvantaged communities, LSL inventory information, and additional lead-reduction steps
that water systems are taking. These actions are consistent with public comments. EPA is
working on several efforts to ensure equitable distribution of BIL funds to support LSLR in
disadvantaged communities.

• Award funding for and support implementation of the Lead Testing in School and Child
Care Program Drinking Water Grant Program: EPA awards funding to participating states,
territories, and tribal consortia to support training and technical assistance for schools and
child care programs to train staff and test drinking water for lead. The funding also supports
technical assistance to schools and child care facilities on follow-up options.26 The BIL
expanded existing grant authority to include lead remediation and compliance monitoring
as eligible projects and activities. EPA relies on Congressional appropriations to fund these
drinking water grants.

EPA has awarded funds through the Voluntary School and Child Care Lead Testing and
Reduction Grant Program to seven tribal consortia,27 all 50 states, the District of Columbia,
Puerto Rico, U.S. Virgin Islands, and American Samoa to provide lead testing in drinking
water in schools and/or child care facilities. New eligibilities under this grant program that
allow for lead remediation activities as authorized by the BIL are available to all grantees.28
Further, EPA is working with the Centers for Disease Control and Prevention (CDC) to inform
nationwide surveillance of blood lead levels, provide education and outreach to
communities, and provide technical assistance. In addition, through its Reducing Lead in
Drinking Water Grant competition, EPA awarded millions in funding to two areas:

Reducing Children's Exposure to Lead in Drinking Water in Schools and Child Care
Facilities. This funding prioritizes projects aimed at the removal of potential sources of
lead in hundreds of schools and child care facilities across the United States. EPA
distributed approximately $25M in fiscal year 2020. In October 2022, EPA announced
$10.5M in grants for new projects; and

26	Follow-up options include activities such as turning off or removing the specific outlet that has tested high for
lead, posting signs to not use certain outlets for drinking or cooking, conducting follow-up sampling to identify
specific components that might be the source(s) of lead, instituting flushing programs, installing filters, and/or
replacing plumbing, fittings, and fixtures.

27	littpsi//www,epa,eov/dwcapacity/wiin-erant-volyntarv-scliool-and-cliild-care-lead-testine-and-redyction-erant-
prograrofftribal

28	Guide planned for publication by the end of 2022.

25


-------
Reduction of Lead Exposure in the Nation's Drinking Water Systems through
Infrastructure and Treatment Improvements. EPA awarded more than $15M in fiscal
year 2020 for thousands of LSL replacements and implementing treatment
improvement projects. In October 2022, EPA announced $20.5M in grants for new
projects in disadvantaged communities.

This more than $30M total in grant funding, and additional funding through the BIL, will
help make rapid progress on the goal of addressing lead and removing lead pipes across the
country in disadvantaged communities and schools.29

APPROACH 2: Reduce lead exposures nationally through protective standards, analytical

tools, and outreach

•	Lead and Copper Rule Improvements (LCRI): In January 2021, EPA issued the Lead and
Copper Rule Revisions (LCRR) (86 FR 4198) and subsequently reviewed those revisions to
further evaluate if the LCRR protected families and communities (86 FR 71574), particularly
those who have been disproportionately impacted by lead in drinking water.30 Through this
review, the Agency concluded that there are significant opportunities to improve the LCRR
(86 FR 71574).31 EPA is developing a new proposed National Primary Drinking Water
Regulation (NPDWR), the LCRI, to strengthen the regulatory framework and address lead in
drinking water. EPA identified the following priority areas for improvement: Proactive and
equitable LSLR; strengthening compliance tap sampling to better identify communities most
at risk of lead in drinking water and to compel lead reduction actions; and reducing the
complexity of the regulation through improvement of the action and trigger level construct.

•	Implement the LSL inventory requirements in the LCRR:32 In December 2021, EPA
published the findings of its review of the LCRR and announced that it does not expect to
propose changes to the requirements related to the information to be submitted in the
initial LSL inventory. EPA also urged continued progress to identify LSLs as integral to lead
reduction efforts regardless of potential revisions to the rule. EPA continues to provide
oversight of Lead and Copper Rule implementation.

EPA developed the following guidance to support public water systems and primacy
agencies, "Guidance for Developing and Maintaining Service Line Inventories," and plans to
develop the LCRR Small Entity Compliance Guidance to assist small water systems with

29	https://www.epa.gov/newsreleases/epa-announces-30-million-grants-proiects-reduce-jead-drinking-water-

disadvantaged

30	https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule

31	The Federal Register Notice. Review of the National Primary Drinking Water Regulation: Lead and Copper Rule
Revisions (LCRR), December 17, 2021: https://www.federalregister.gov/documents/2021/12/17/2021-

27457/review-of-the-national-priniarv-drinking-water-regulation-lead-and-copper-rule-revisions-lcrr.

32	EPA authorizes states and tribes to have primary enforcement responsibility (also called primacy) for public
water systems if they meet certain requirements.

26


-------
creation of their inventories. This work includes supporting LSL inventory development,
encouraging full LSLR programs, and discouraging partial replacement.

EPA is updating the Safe Drinking Water Information System (SDWIS) to support data on the
counts of lead, unknown, and non-LSLs at each water system. This data is required to be
reported to EPA by States under the LCRR and water systems must make their inventories
publicly accessible by the October 16, 2024, compliance deadline.33 EPA will consider how
to report on progress to identify and replace LSLs over time as the information is provided
to the Agency by its state and tribal partners.

Consistent with public comments to improve education, other planned work includes
improving guidance and templates to help states and public water systems communicate
lead risk to households and communities with LSLs; revising the Consumer Confidence
Report Rule to include more information about actions public water systems are taking to
control lead; and developing materials that describe the risks posed by partial LSLR and
measures to reduce lead concentrations following replacement (e.g., flushing plumbing, use
of filters, and follow-up testing).34

APPROACH 3: Reduce lead exposures with a "whole of EPA" and "whole of government"

approach

• Provide resources to schools, child care facilities, and states: EPA will continue to chair a
federal interagency and stakeholder group under the Memorandum of Understanding
(MOU) on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities. This
interagency group includes EPA; several offices within the Department of Health and
Human Services (HHS), including the CDC, Indian Health Service, and the Administration for
Children and Families' Office of Head Start and Office of Early Childhood Development; and
the Departments of Agriculture (USDA), Education, and Interior, as well as nine non-federal
associations.35

This interagency group works together to provide schools, child care facilities, and states
with education on health concerns associated with lead in drinking water; helps develop
lead testing programs using EPA's 37s (Training, Testing, and Taking Action) for Reducing
Lead in Drinking Water in School and Child Care Facilities; works with schools and child care
facilities to establish a sustainable and effective lead in drinking water testing program; and
connects schools and child care facilities that find lead in their drinking water with funding
resources for remediation, such as USDA's Community Facilities grant programs and HHS's
Head Start funds through its program improvement requests. EPA will continue to develop

33	https://www.epa.gov/ground-water-and-drinking-water/safe-drinking-water-information-system-sdvyjs-federal-

reporting

34	https://www.epa.gov/ccr/consumer-confidence-report-rule-and-rule-history-yyater-systems

35	https://www,epa,gov/sites/production/files/2019~

10/documents/mou reducing lead in drinking water in schools final.pdf

27


-------
tools and trainings through the 3Ts program and work with MOU partners to provide input
on and review of products and to help promote final products.

Consistent with the public comments requesting a holistic federal approach, EPA continues
to leverage federal and non-federal programs to protect children's health in schools and
child care facilities. EPA activities with partners of the MOU on Reducing Lead in Drinking
Water in Schools and Child Care facilities include:

Collaborating with HHS and USDA to identify opportunities to align funds, address data
gaps on lead contamination, and develop coordinated policies and guidance to leverage
respective agency authorities in schools and early childhood facilities; and

Providing technical assistance and training as USDA pursues actions through its Rural
Development mission area, including the Community Facilities program efforts to
prevent lead poisoning through renovation and repair work on child occupied facilities
and installation of water filter stations in schools and child care facilities.

• Collaborate on lead testing for drinking water: EPA is working with HHS to promote lead
testing best practices in drinking water at facilities funded by its Office of Head Start and the
Office of Child Care.

Consistent with public comments to provide education and technical assistance to schools
and child care facilities, EPA is collaborating with HHS to provide training at the local level
and to leverage authorities and policies to increase lead testing and remediation in early
childhood and child care communities.

REGIONAL COMMUNITY CASE STUDY: Elevated levels of lead were identified while evaluating
nitrate contamination in the drinking water at an affordable housing complex in Massachusetts
(MA), EPA Region 1. The complex is a 36-unit, elderly and disabled residential home. The
community is in rural central MA. The complex is a public water system and is subject to the
Lead and Copper Rule along with other NPDWRs as a Community Water System.

The Massachusetts Department of Environmental Protection (Mass Dep) issued a "Do Not Drink
Order" for the complex due to a nitrate contamination issue. During the evaluation period, the
complex's corrosion control water treatment system failed, causing highly acidic water to
corrode the building's pipes. As a result, the lead levels in the drinking water increased to above
the action limit set by Mass DEP. Also, the water had a blue/green tinge, which caused the
sinks, toilets and tubs to stain, and residents were advised not to wash light colored clothes as
they could also become stained. As a result, residents were provided bottled water dispensers
and free bottled water supplies in each apartment unit.

Using funding from EPA's Training and Technical Assistance Grant and HHS grants, a team of
technical specialists from Rural Community Assistance Partnership (RCAP) Solutions, with
extensive background in water and environmental issues, worked with the property

28


-------
management of the complex. The technical assistance team identified the nitrate
contamination source by fully evaluating the property's onsite wastewater treatment system.
They discovered the system was not installed as designed and was leaking into the source
water. The technical assistance team oversaw the re-construction of the on-site wastewater
system; since that repair, the nitrate levels have abated to levels acceptable under state
drinking water standards. Further, the RCAP team replaced many faucets and plumbing that
were potential sources of lead and assisted the complex to install a new pH control system
which abated the corrosion caused by the acidic water. Reducing the corrosion removed the
identified issues with the water's blue coloration and high lead levels. In addition, the technical
assistance team assisted the complex with a variety of compliance issues including previous
sanitary survey consent orders and developed a long-term plan for the complex's drinking
water system to ensure continued compliance and long-term sustainability. The community's
drinking water continues to meet compliance standards, including for lead.

Objective C: Reduce Exposure to Lead in Soils

Problem: Lead is a naturally occurring element generally found in soil at low levels. In many
locations across the United States, however, the concentrations of lead in soils can be much
higher because of human activities - especially in and around urban areas, in areas with lead
mining and smelting activities, and near older homes with lead-based paint. Today, this legacy
of lead overburdens communities impacted by the activities of lead producing and using
industries; often these are communities of color and low-income neighborhoods. Soil-lead
contamination can occur from past industrial operations that involved lead, from lead-based
paint cracking, flaking, and peeling off homes and buildings, and from past use of leaded
gasoline, especially in housing near highways or heavily travelled city streets. Lead
contamination from the past, often from multiple sources, can accumulate and remain an
ongoing threat.

Children and adults can be exposed to lead in soil and dust through incidental ingestion of
contaminated soils by touching their mouth with their hands (typically in young children), but
also by adults working in soils or gardening. Children may also ingest soil and dust by placing
non-food items in their mouths.36 Soil contaminated with lead can be tracked into homes or
other buildings, which can result in ingestion of contaminated house dust.37 In some cases,
eating fruits and vegetables grown in lead-contaminated soil is another route of exposure.

Public Input: A key message from the public comments on the draft strategy was that EPA
should address lead-contaminated soils regardless of the source of the pollution. Commenters
noted that higher blood lead levels are typically due to multiple sources of lead. Others urged

36	EPA Exposure Factors Handbook, chapter 5. https://www.epa.gov/sites/default/files/2018-01/documents/efh-

chapterOS 2017.pdf.

37	Clark S, et. al. "The Influence of Exterior Dust and Soil Lead on Interior Dust Lead Levels in Housing that had
Undergone Lead-Based Paint Hazard Control" Journal of Occupational and Environmental Hygiene (2004) 1:5, 273-
282. https://doi.org/10.1080/1545962049Q439036

29


-------
EPA to coordinate the use of its authorities to address all lead exposures in communities and to
collaborate with other federal, tribal, state, and municipal agencies so that sources of lead are
not left unaddressed. Another key message from the public comments was that EPA's
standards for lead in soil are out of date. Commenters mentioned the cleanup standards for
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) removal
and remedial sites and Resource Conservation and Recovery Act (RCRA) corrective action
facilities, as well as the Soil Lead Hazard Standard, and recommended that EPA align its
standards with the CDC's blood lead reference value, which is currently 3.5 |ag/dL.38 Public
comments also emphasized the need to focus efforts to address lead contamination in
communities with environmental justice concerns as these communities are typically exposed
to lead from multiple sources. Other commenters noted that there should be a mechanism to
clean up lead contaminated soils that do not qualify for a CERCLA response, that communities
need technical assistance from EPA to address lead, and that EPA should consider alternative
remedial technologies, such as capping, landscaping, and soil amendments. The actions below
reflect EPA's consideration of these comments.

Performance Measures and Milestones:

•	By September 30, 2026, complete 225 Superfund cleanup projects that address lead as a
contaminant (averaging 45 each year).

•	By June 30, 2023, evaluate and revise the Residential Soil Lead Guidance for Contaminated
Sites to protect communities by further reducing the potential for exposure to lead in soil.

•	By September 30, 2023, review results of the Superfund Lead Collaboration Pilot projects
and where appropriate, update Superfund guidance to reflect best practices.

•	Report annually the number of Brownfields cleanups that addressed lead contamination, as
reported by grant recipients.

EPA ACTIONS:

APPROACH 1: Reduce lead exposures locally with a focus on communities with disparities and
promote environmental justice

•	Clean up lead contaminated sites: EPA will prioritize cleaning up lead in communities
contaminated by lead from CERCLA (Superfund) or RCRA releases. Risk of potential adverse
health effects, level of exposure, promotion of environmental justice, and other factors will
guide EPA's efforts. EPA will work with states, tribes, communities, and other stakeholders
at Superfund removal and remedial sites and at RCRA corrective action facilities to address
lead contamination under applicable statutory authorities. Cleanup at lead-contaminated
sites impacting tribal nations will evaluate exposure pathways unique to tribal members, as
well as any Traditional Ecological Knowledge or Indigenous Knowledge provided by the

38 CDC Blood Lead Reference Value: littpsi//www,cdc,eo₯/nceli/lead/data/blood-lead-refereiice-₯alye,]itni,

30


-------
tribe.39 Furthermore, EPA will continue to update tools to characterize, assess, and address
sites with lead-contaminated soil.40

APPROACH 2: Reduce lead exposures nationally through protective standards, analytical

tools, and outreach

•	Revise the Residential Soil Lead Guidance for Contaminated Sites to further reduce the
potential for exposure to lead in soil: The soil lead guidance for assessing and remediating
contaminated sites, last updated in 1998, provides recommendations to help identify and
define areas that may require further investigation and to help prioritize sites with the most
immediate threats associated with lead contaminated soils at Superfund sites and RCRA
facilities.41 EPA is in the process of reviewing the 1998 guidance to determine if new
recommendations for screening sites and facilities with residential exposures are
appropriate. EPA will account for the multiple and complex lead exposures to children when
setting screening levels and cleanup goals to reduce lead exposure in communities

and protect human health and the environment.

•	Revisit the soil-lead hazard standards: In light of a May 2021 court decision by the Ninth
Circuit,42 EPA will reconsider the 2001 soil-lead hazard standards.43 The soil-lead hazard
standards, issued under Title IV of TSCA, identify lead-contaminated soils at target housing
(i.e., built before 1978) and pre-1978 child-occupied facilities that would result in adverse
human health effects. Soils that contain lead at levels determined to be hazardous to
human health are considered contaminated. Lead inspectors, risk assessors, and abatement
professionals use the soil-lead hazard standards in target housing and pre-1978 child-
occupied facilities to determine if soil-lead hazards are present and to inform options for
reducing risk of exposure.

APPROACH 3: Reduce lead exposures with a "whole of EPA" and "whole of government"

approach

•	Work with HUD to reduce lead exposure to protect families, particularly children, in
overburdened and underserved communities: EPA will work with HUD to reduce exposure
to lead to protect families, particularly children, in overburdened and underserved
communities. Where HUD authorities are used to address indoor or outdoor environmental

39	Considering Traditional Ecological Knowledge (TEK) During the Cleanup Process. EPA, OLEM, 2017,

httpsi//www,epa,gov/sites/default/files/2018-

02/documents/conside	ditional ecological knowledge tek during the cleanup process.pdf. In addition,

EPA may provide additional knowledge when government-wide guidance on TEK/IK in federal decision-making is
final.

40	Guidance, exposure models, tools, and technical support can be found on EPA's Technical Review Workgroup,
Lead Committee website: https://www.epa.gov/superfund/lead-superfund-sites.

41	https://www.epa.gov/superfund/jead-superfund-sites-gujdance

42	A Cmty. Voice v. U.S. EPA, 997 F.3d 983 (9th Cir. 2021),

https://cdn,ca9,uscourts,gov/datastore/opinions/2021/05/14/19-71930,pdf

43	https://www,govinfo,gov/content/pkg/FR-2001-01-05/pdf/01-84,pdf

31


-------
hazards in housing at or near sites and EPA is addressing Superfund lead cleanup projects,
EPA will coordinate Superfund efforts with HUD. In a separate effort, under a current
Memorandum of Understanding, EPA and HUD are identifying HUD-assisted housing
properties on and around Superfund sites to inform HUD and EPA staff of the sites to
facilitate faster and more effective sampling and clean up.

•	Use a collaborative approach to reduce lead at Superfund sites: EPA is working to promote
more effective collaboration at the local, state, territorial, tribal, and federal levels to
address multiple sources of lead in communities near Superfund sites where lead is a
contaminant of concern. EPA's Superfund program is conducting the Superfund Lead
Collaboration Pilot to gather best practices for enhancing collaboration to address multiple
sources of lead in communities near Superfund lead sites with the ultimate goal of
improved health outcomes for children who are being exposed to lead. EPA is working with
a broad range of stakeholders to leverage multiple authorities and tools to address lead
exposures at Superfund sites such as lead-based paint, lead from air sources, and lead in
drinking water. These collaborative stakeholders may include other EPA programs, other
federal agencies such as HUD and HHS, state and local environmental and health
departments, community groups/organizations, and other entities as appropriate.

•	Support community-driven Brownfields assessment, cleanup, and revitalization: When
site risks and contamination levels are not addressed under a Superfund-based cleanup
action, EPA will continue to respond to requests for technical assistance to help community-
driven cleanups to revitalize sites with lead and other contaminants. EPA will also organize
annual Brownfields grant competitions that allow tribes, states, and communities to seek
funds to assess, clean, and plan for the safe reuse of Brownfields, including the creation of
community lead-safe spaces. States and tribes determine actionable lead contaminant
levels at these Brownfields sites, and remediation of these sites are subject to those levels,
as established under risk-based cleanup programs. The Technical Assistance to Brownfield
Communities program can provide technical assistance to communities and stakeholders to
help address their Brownfield sites, and to increase their understanding and involvement in
Brownfields cleanup, revitalization and reuse.44 Organizations can contact EPA Regional
programs directly to seek free Targeted Brownfield Assessments, which can help with a
specific site to collect site-specific information or investigate environmental conditions that
may be beyond the scope of many community-based organizations.45

REGIONAL COMMUNITY CASE STUDY: EPA began cleanup of the U.S. Smelting and Lead
Refinery Inc. site (USS Lead Superfund) in East Chicago, Indiana in 2008 and listed the site on
the National Priorities List in April 2009. At that time, nearby residents were concerned about
the risks they faced from past and ongoing lead exposures and had limited information about
the EPA cleanup process. In response to the affected community's desire for better
communication and outreach, EPA employed numerous community engagement strategies

44	https://www.epa.gov/brownfields/brownfields-technical-assistance-training-and-research

45	https://www.epa,gov/brownfields/targeted-brownfields-assessments-tba

32


-------
including establishment of a local phone hotline, a local staffed office with drop-in visit time, an
online data viewer, and a regular newsletter. EPA also engaged in frequent public availability
sessions and meetings to engage with the community throughout the cleanup.

This large-scale residential yard cleanup began with an emergency response to lead
contamination in soil at several hundred homes, drawing media, community, and political
interest. Because of the intensive and comprehensive team effort, all 807 properties in Zones 2
and 3 (including non-residential) that required cleanup were safely cleaned up by the fall of
2021, nearly a year ahead of schedule. This extraordinary effort was the result of dedicated
coordination between all EPA Region 5 programs involved, the U.S. Department of Justice
(DOJ), the Agency for Toxic Substances and Disease Registry (ATSDR), HUD, and state and local
health departments.

EPA prioritized the USS Lead site after Region 5 recognized that more than 1,000 residential
properties could be contaminated with high levels of lead and arsenic in the soil. Initial plans
and actions involved requiring those responsible for the contamination to complete or pay for
all sampling and cleanup at these residential properties by late 2020 or early 2021, with
intensive EPA oversight. To engage with the impacted residents under this aggressive cleanup
schedule, Region 5 implemented innovative efforts, including the Superfund Jobs Training
Initiative program and a creative community event. The Jobs Training Initiative program for East
Chicago residents resulted in the hiring of 10 trainees by site cleanup contractors to help with
the lead cleanup in their own community. EPA also partnered with the ATSDR and local health
agencies to host a superhero-themed community event with free entertainment and food
trucks and a mobile blood testing unit to encourage families to have their children's blood lead
tested.

With these actions and more, the affected community at the USS Lead Site remained engaged
in their cleanup work and helped move the cleanup along expeditiously. EPA's efforts fostered a
positive relationship with the community and at the same time accelerated removal of
contaminated soils from the impacted residential properties in East Chicago. Going forward,
EPA, with the assistance of the DOJ, has finalized a Prospective Purchaser Agreement (PPA) with
a company that specializes in redevelopment of properties that contain or once contained
hazardous substances. Under the PPA, part of the USS Lead Site would be further cleaned up
and redeveloped as a commercial warehouse.

Objective D: Reduce Exposure to Lead Associated with Emissions to Ambient Air

Problem: Lead emitted into the air can contribute to multiple pathways of exposure that can
pose risks to human health and the environment. For example, lead from ambient air can
contribute to lead in soil and related pathways, as well as indoor air and dust. The extent of air-
related pathway contributions to exposures and risk depends largely on source and community
characteristics. On a national scale, the largest aggregated source of lead air emissions is
piston-engine aircraft operating on leaded aviation fuel, which can contribute to increased air
lead concentrations at some general aviation airports. Locally, however, areas of the U.S. with

33


-------
the highest concentrations are generally near metals industries, such as battery recycling
facilities and other metal processing facilities.

The U.S. has made enormous progress in reducing lead emissions and associated ambient air
concentrations. Between 1980 and 2018, concentrations of lead in ambient air at a set of
continuously monitored sites have decreased by 99 percent.46 Substantial progress has also
been made in addressing areas of the U.S. with lead concentrations exceeding the National
Ambient Air Quality Standards (NAAQS) for lead. All but two of the 22 areas that were initially
identified as not meeting the NAAQS are currently meeting the NAAQS.47 EPA will continue to
assess and reach conclusions on hazards, potential exposures, and risks; set and implement
standards to limit emissions and air concentrations; and work with state and local agencies to
monitor air quality near sources and ensure compliance with the standards. Further, EPA will
continue to track airborne lead concentrations through state-led ambient air monitoring and
emissions inventory reporting and will share the national status in future air trends reports.

Public Input: Public comments on the draft strategy included concerns regarding sources of
lead emissions to ambient air. Many commenters raised concerns regarding emissions from
piston-engine aircraft using leaded aviation gasoline (avgas), and comments were also received
regarding emissions from other types of sources, such as metals industries. The comments
urged the Agency to act promptly to restrict emissions from all of these sources. Additionally,
some comments emphasized the need to bring all areas of the country into attainment with the
existing NAAQS, and to ensure monitors are sited near sources. Further, comments emphasized
the importance of the ongoing review of the NAAQS to ensure the national standards reflect
the current scientific information. The actions identified below reflect consideration of these
comments.

Performance Measures and Milestones:

•	Lead NAAQS: Projected completion of the current lead NAAQS review in 2026.

•	Emissions Standards for Lead Sources: Anticipated completion of rulemakings for
important lead emissions sources over the next two years:

o In 2023, secondary lead smelters, lead acid battery manufacturing, and integrated iron

and steel manufacturing,
o In 2024, primary copper smelters and large municipal waste combustors.

•	Aircraft Lead Emissions Endangerment Finding Evaluation: In October 2022, EPA issued a
proposed finding that lead emissions from aircraft engines that operate on leaded fuel
cause or contribute to air pollution that may reasonably be anticipated to endanger public
health and welfare. After evaluating comments on the proposal, EPA plans to issue any final
endangerment determination in 2023.

46	The annual air quality trends report includes information on trends in lead emissions and ambient air
concentrations (https://www.epa.gov/air-trends/jead-trends).

47	This reflects designations made in the years after the NAAQS was most recently revised in 2008. The "Green
Book" describes areas designated attainment and nonattainment for the 2008 lead NAAQS

(https://www3,epa,gov/airquality/greenbook/mbtc,html).


-------
EPA ACTIONS:

APPROACH 1: Reduce lead exposures locally with a focus on communities with disparities and

promote environmental justice

•	Continue to implement the National Ambient Air Quality Standards for lead to reduce
emissions to ambient air in communities: Air emissions of lead have the greatest impact
near the pollution source. As a result, violations of the lead NAAQS can impact communities
that are close to lead-emitting sources. EPA will continue to work with state, local and tribal
air agencies in these communities to help reduce lead emissions and address such violations
to protect public health.

•	Continue to coordinate state, local, and tribal surveillance networks to ensure ambient air
monitoring near pollution sources. EPA will continue to review monitoring networks,
identify opportunities to improve monitoring near sources with the potential to violate the
NAAQS, and work with air monitoring agencies to ensure the ambient air monitoring
networks comply with requirements for lead NAAQS surveillance.

APPROACH 2: Reduce lead exposures nationally through protective standards, analytical

tools, and outreach

•	Review the National Ambient Air Quality Standards for lead: To inform the review of the
lead NAAQS that is currently underway and projected for completion in 2026, EPA will
develop a new Integrated Science Assessment (ISA) for lead. The new ISA will contain a
concise policy-relevant evaluation and synthesis of the current scientific information on
lead, including sources, environmental distribution, and exposures to ambient air lead (both
airborne and deposited), and EPA's conclusions on the health and welfare effects of lead.
Based on the new ISA and current information on air quality, exposure, and risk, the Office
of Air and Radiation will develop an assessment of the policy implications regarding the
adequacy of protection provided by the existing NAAQS and any potential alternative policy
options. EPA will rely on the findings in these documents, advice from the Clean Air
Scientific Advisory Committee, and public comments to inform the Agency's decision
whether to retain or revise the current NAAQS for lead.

•	Update emissions standards for lead-emitting sources: EPA is reviewing emissions
standards, including National Emissions Standards for Hazardous Air Pollutants and New
Source Performance Standards, for lead-emitting sources to incorporate developments in
technologies and/or address risk concerns. The Office of Air and Radiation intends to make
regulatory decisions over the next two years for important lead-emitting source categories,
including primary copper smelters, lead acid battery manufacturing, secondary lead
smelters, integrated iron and steel manufacturing, and large municipal waste combustors.
Updating these standards will strengthen regulatory tools for minimizing impacts of these
lead sources in nearby communities.

35


-------
•	Examine lead pollution from aircraft: EPA is evaluating, under the Clean Air Act, whether to
make a determination that emissions of lead from aircraft engines that operate on leaded
fuel cause or contribute to air pollution that may reasonably be anticipated to endanger
public health or welfare. For convenience, EPA sometimes refers to this determination
collectively as the "endangerment finding." Aircraft that use leaded aviation gas are
primarily piston-engine aircraft. In October 2022, EPA issued a proposed endangerment
finding for lead emissions from aircraft operating on leaded fuel, providing an opportunity
for public notice and comment.48 After evaluating comments on the proposal, EPA plans to
issue any final endangerment finding in 2023. If a final determination is issued, that
determination would not itself apply new requirements to entities other than EPA and the
Federal Aviation Administration (FAA). EPA is not at this time proposing aircraft engine lead
emission standards. However, if EPA makes a final determination that lead emissions from
aircraft engines cause or contribute to lead air pollution that may reasonably be anticipated
to endanger public health or welfare, EPA will subsequently propose regulatory standards
for lead emissions from aircraft engines. Such a finding also would trigger the FAA's
statutory mandate to prescribe standards for the composition or chemical or physical
properties of an aircraft fuel or fuel additive to control or eliminate aircraft emissions of
lead.

APPROACH 3: Reduce lead exposures with a "whole of EPA" and "whole of government"

approach

•	Nonregulatory approaches to address lead emissions from use of leaded fuel in aircraft
engines: The FAA has two integrated initiatives focused on transitioning safely away from
the use of leaded fuel: The Piston Aviation Fuels Initiative (PAFI), and the FAA-industry
partnership to Eliminate Aviation Gasoline Lead Emissions (EAGLE).49 PAFI provides the
testing and evaluation of unleaded avgas candidates and determines if they are qualified as
a replacement for leaded avgas. The EAGLE initiative focuses on transitioning the entire
industry sector to a lead-free fuel, including fuel production, distribution, and
infrastructure. In addition, the FAA has approved the safe use of an unleaded fuel that can
be used in a large number of piston-engine aircraft, along with other unleaded fuels for
specific aircraft. EPA collaborates and coordinates with the FAA and other agencies on lead
reduction opportunities from the use of leaded avgas while these fuel replacement
programs are in development. This collaborative work will include responding to National
Academy of Sciences recommendations regarding options for reducing lead emissions from
these aircraft.50

48 More information on EPA's proposed endangerment finding for lead emissions from aircraft operating on leaded
fuel is available at https://www.epa.gov/regulations-emjssions-vehicles-and-engines/regulations-jead-emissiqns-

aircraft.

49Recent activities at FAA (https://www.faa,gov/about/initiatives/avgas/env airports) focus on the PAFI
(https://www,faa,gov/about/initiatives/avgas/) and EAGLE (https://www.faa,gov/unleaded).

50 https://www.nap.edy/cataloe/26050/options-for-redycine-lead-emissions-from-pistoii-etigiiie-aircraft

36


-------
REGIONAL COMMUNITY CASE STUDY: In 2018, the State of Indiana issued a 10-year minor
source air permit renewal to Whiting Metals, Limited Liability Company (LLC), a lead metal
reclamation facility located in Hammond, Indiana. During the permit review, EPA identified an
incorrect emissions factor resulting in a large underestimate of potential lead emissions to the
air. EPA conducted air dispersion modeling, using the corrected emissions levels, and
discovered that there was potential for violations of the lead NAAQS. In addition to the
concerns about air emissions from the facility, EPA's Superfund and Emergency Management
Division was conducting remediation activity in the surrounding community to remove lead-
contaminated soil deposited by a former secondary smelter that operated on the Whiting
Metals, LLC property from 1937 to 1983. The soil surrounding multiple households and other
publicly accessible areas exceeded the removal management level for lead.

EPA worked with the state to deploy ambient lead monitors adjacent to the facility's property
in August 2018 and sampled daily. Within the first month of monitoring, recorded
concentrations exceeded the NAAQS. In November 2018, EPA and the state issued a joint notice
of violation to the facility.

Due to the remediation activities and an earlier incomplete RCRA cleanup on the Whiting
Metals, LLC property (2001-2005), re-entrainment - where past contamination deposited onto
the ground is resuspended into the air - was another potential source of ambient lead. To
further investigate the source of the lead, EPA deployed a continuous air monitoring
instrument, capable of assessing hourly ambient air concentrations of many metal elements
and corresponding meteorological information. This additional information provided hourly
rather than daily measurements, which can be used to better assess and identify the sources of
pollution. Over the next year, EPA collected hourly monitoring data and was able to accurately
attribute the primary source of ambient lead to Whiting Metals, LLC's operations, rather than to
any remediation activities or other deposited contamination from historical emissions. The
facility ceased operations in June 2020, and the state revoked its permit at the end of calendar
year 2020, eliminating an ongoing source of lead emissions to the community.

Objective E: Reduce Exposure to Lead Through Enforcement and Compliance Assurance

Problem: Americans continue to be exposed to lead in lead-based paint, soil, dust, sediment,
air, and drinking water. Some of these exposures result from noncompliance with laws
designed to reduce or eliminate exposure. In addition to working to prevent new lead
exposures and clean up legacy contamination, EPA will address exposures associated with
noncompliance and environmental liability. EPA will continue to implement its wide range of
authorities to address noncompliance, obtain cleanups, deter future violations, and mitigate
harm using available resources.

Public Input: EPA received comments from the public concerning enforcement and compliance
related to lead in soil, air, drinking water, and paint. The comments cited the range of legal
authorities that the Agency is authorized to use to address noncompliance and reduce lead
exposures, while acknowledging the need for sufficient resources to utilize those authorities

37


-------
fully. Commenters also noted that the elimination of certain gaps in EPA's legal authorities
would help optimize the Agency's efforts to address lead.

Numerous public comments urged EPA to take more enforcement actions to address lead-
based paint and lead in drinking water, and multiple comments focused on enforcement
related to lead in soil and air emissions. In addition, many commenters suggested approaches
for enhanced targeting, and collaborations with state, local, and tribal authorities.

EPA has modified this final strategy to highlight planned collaborations with co-regulators, and
the Agency's interest in using new tools that our partners may have to help support or enhance
our enforcement and compliance activities.

Performance Measures and Milestones:

•	Each year, direct enforcement resources to at least one community with environmental
justice concerns in each Region, to help address the exposures to lead in that community
and take appropriate enforcement action.

•	Each year, publicly report on national statistics related to lead cleanups and inspections,
including whether the inspections occurred in communities with environmental justice
concerns.

EPA ACTIONS:

APPROACH 1: Reduce lead exposures locally with a focus on communities with disparities and
promote environmental justice

•	Enhance enforcement and compliance assurance in overburdened communities: EPA will
prioritize high-impact cases that address the needs of communities experiencing adverse
disproportionate environmental and health risks and harms from lead.

•	Increase impact of lead exposure reduction projects: EPA will identify and support
opportunities to implement lead exposure reduction projects that are obtained through
enforcement actions, including through voluntary Supplemental Environmental Projects
(SEPs) agreed to as part of a settlement agreement.

•	Promote geographic initiatives and activities to address lead in multiple media: The

Agency will promote geographic initiatives in its ten Regions, focusing efforts on a specific
area or community with more than one source of lead exposure. EPA will use mapping,
predictive screening, and other tools to identify areas of concern and prioritize enforcement
and compliance assurance activities. EPA will continue implementing lead-based paint
geographic initiatives, particularly in areas with significant lead exposures, and will
collaborate across EPA programs and with interested external stakeholders to identify

38


-------
opportunities to use enforcement and compliance assurance to reduce lead exposures from
other media, such as in drinking water, air emissions, or soils.

APPROACH 2: Reduce lead exposures nationally through protective standards, analytical

tools, and outreach

•	Improve compliance monitoring and enforcement to reduce lead exposure: EPA will
develop tools to improve compliance monitoring and enforcement and address lead
exposures from all media sources, including exploring tools and approaches suggested by
the public and co-regulators.

o To ensure proper evaluation of sampling and treatment to support Lead and Copper
Rule (LCR) enforcement, EPA will issue a national LCR Inspection Protocol for federal,
tribal, and state drinking water inspectors,
o EPA will collaborate with Customs and Border Protection on compliance activities to
support the "lead free" plumbing requirements of the Safe Drinking Water Act
section 1417.

o EPA will develop guidance, protocols and/or compliance information to improve
enforcement including in communities with significant lead exposures and will
support approaches to address lead contamination in these communities,
o EPA will optimize use of existing and newly acquired tools and authorities to provide
more effective enforcement and to ensure compliance with lead-safe work practice
standards and other requirements by property management companies that
perform renovations using outside contractors.

Actions will focus on high-impact cases using EPA's various compliance assurance
authorities and tools to address violations related to lead in all environmental media and
paint, particularly violations affecting overburdened communities.

•	Increase enforcement for lead site and facility cleanups: EPA will use all appropriate
enforcement authorities to clean up lead contaminated sites and facilities and continue to
pursue responsible entities for cleanup of lead released into the environment, including in
residential yards, play areas, and other locations where children are commonly exposed to
lead. EPA will increase internal collaboration to identify situations, consistent with current
law and policy, where the Agency will seek to have responsible entities or others as
appropriate perform or pay for cleanup to address lead contamination inside residential
housing or other structures where children and other sensitive subpopulations may face
exposure to lead.

APPROACH 3: Reduce lead exposures with a "whole of EPA" and "whole of government"

approach

•	Identify sources of potential lead exposure to improve targeting: EPA will work across the
Agency, with other federal agencies, and with state, tribal and local co-regulators to enable

39


-------
national enforcement programs to identify locations where people may be exposed to lead
in drinking water, paint, soils and/or air emissions, and what authorities EPA may apply to
address those exposures. This includes continuing to work within EPA and with external
partners to incorporate and share data and to map locations of significant potential lead
exposure at national, state, tribal, and local scales. As resources allow and in partnership
with others, EPA will further refine the Agency's analytical lead mapping capabilities
(currently the Lead Occurrence and Source Tool) to assist in identifying these locations.

• Enhance collaborative relationships with key federal agencies, states, tribes, and local
partners: EPA will identify opportunities to share information and pursue partnerships with
federal, state, tribal and local authorities that leverage our respective authorities and
resources to address lead exposures. These include:

o EPA will engage with the Department of Defense to address lead exposures at

privatized military housing,
o EPA will partner with health agencies to obtain blood lead level data for purposes of

enforcement and compliance assurance,
o EPA will partner with states and tribes to support local drinking water systems in
developing LSL information and to enforce the prohibition on use of non-lead-free
plumbing materials.

o EPA will partner with HUD to explore collaboration opportunities and to acquire and
analyze data on pre-1978 housing.

EPA will use such engagement and data to further refine EPA's mapping capabilities and
ability to identify disproportionately impacted communities. These partnerships will also
support EPA's goal of exploring suggested tools and approaches that help co-regulators
build their capacity to address lead exposures in local communities under their respective
authorities.

MULTI-REGIONAL COMMUNITY CASE STUDY: When large renovation firms such as Home
Depot U.S.A. Inc.,51 do not comply with the law, the noncompliance may disproportionately
affect communities with environmental justice concerns. EPA targeted compliance monitoring
in communities overburdened by exposure to lead-based paint and found that Home Depot
was in violation of the Agency's lead-based paint RRP Rule, and of EPA-approved federally
equivalent state renovation rules. As a result, Home Depot is implementing the provisions of a
settlement reached in 2020, including payment of a penalty of $20.75 million, to resolve an
enforcement action brought by EPA and the Department of Justice, joined by the States of
Utah, Massachusetts, and Rhode Island. The civil penalty is the highest to date for any
settlement under the Toxic Substances Control Act.

Under the settlement, Home Depot is implementing a company-wide program to ensure that
its contractors comply with the RRP Rule that applies to renovations of homes built before

51 Mention of this company name does not imply endorsement.


-------
1978. The settlement also requires Home Depot to conduct thousands of on-site inspections of
work performed by its contractors to ensure they comply with lead-safe work practices. The
Home Depot must also investigate and respond to customer complaints, and EPA is monitoring
Home Depot's response. Where the contractor has not complied with lead-safe work practices,
Home Depot must perform an inspection for dust-lead hazards and, if found, provide a
specialized cleaning. Also, Home Depot is providing important information concerning following
lead-safe work practices to its professional and do-it-yourself customers in its stores, on its
website, on YouTube, and in workshops.

GOAL 2: IDENTIFY COMMUNITIES WITH HIGH LEAD EXPOSURES AND
IMPROVE THEIR HEALTH OUTCOMES

Problem: Exposure to lead across the country is inequitable, with communities of color and
lower socioeconomic status neighborhoods often facing the greatest exposure and risks of
health impacts that can exacerbate existing health inequities.

In many instances, locations with high lead exposures are identified only after the exposures
have taken place and higher levels of lead are detected in children's blood. This often impacts
children from underserved communities due to living conditions in unsafe housing, occupations
of family members, and living within proximity to industrial facilities that release lead. Blood
lead testing programs and practices vary widely state to state, ranging from several states with
mandatory testing requirements to others without any requirements. States also differ in how
and to what extent they report available blood lead level data to the CDC. With variations in
testing and reporting, whatever data are available nationwide very likely represent an
underreporting of children who have higher blood lead levels and are exposed to lead hazards.
Recent research has shown that spatial, analytical, and statistical methods can identify lead
exposure hotspots that have not been identified by other means and that may benefit from
increased blood lead level surveillance.52,53

Public Input: A key theme repeated in the comments concerned the challenge of adequate data
availability, the quality of available data, and whether data are provided at a scale that allows
for community-scale analysis. To address these challenges, commenters suggested that EPA
work with states to create and enhance blood lead testing and surveillance programs, and work
with all its partners to develop consistent and transparent community identification methods.

52	Xue, Jianping, et al. "A generalizable evaluated approach, applying advanced geospatial statistical methods, to
identify high lead exposure locations at census tract scale: Michigan case study" Environmental Health
Perspectives (2022) 130.7: 077004. https://pubmed.ncbi.nlm.nih.gov/35894594/

53	Zartarian, Valerie, et al. "Lead Data Mapping to Prioritize US Locations for Whole-of-Government Exposure
Prevention Efforts: State of the Science, Federal Collaborations, and Remaining Challenges." American Journal of
Public Health 112.S7 (2022): S658-S669. https://pubmed.ncbi.nlm.nih.gov/36179290/

41


-------
Commenters suggested that a national organization of state and local lead health agencies
could also help to address these challenges.

Commenters suggested that EPA account for a broad range of data when identifying hot spots,
including (but not limited to) environmental indicators, socioeconomic and demographic
indicators, housing data, and health data. It was recommended that EPA make community
identification data easily available to the public and that the Agency should work with
community-based organizations and institutions to exchange information about hot spot
identification.

Finally, commenters recommended that EPA support the pediatric clinical care community
through increased funding and support to increase blood testing and surveillance as well to
provide health services and information to children and their families.

The actions identified below reflect the Agency's ongoing consideration of these comments.

Performance Measures and Milestones:

•	By September 30, 2024, develop an interim blueprint for identifying high lead exposure risk
locations based on research identifying lead exposure hotspots in Michigan, to be shared
with internal and external public health partners for broader applicability and capacity
building in the U.S.

EPA ACTIONS:

APPROACH 1: Reduce lead exposures locally with a focus on communities with disparities and
promote environmental justice

•	Identify lead 'hot spots': EPA, in collaboration with HHS and HUD, will implement science-
based approaches for identifying communities and subsections of communities at the
census tract or other local geographies with high lead exposure potential and probable
sources of exposure in those communities.54 This information can inform where to provide
enhanced community outreach and EPA actions. These approaches will use available data,
statistical models, and geospatial analysis including blood lead level surveillance data
collected by states, tribes, territories, federal agencies, and local governments; and
environmental, socioeconomic, and demographic data, including indices from the EJSCREEN
environmental justice screening and mapping tool,55 as surrogates for potential exposures.

•	Ascertain local dominant lead exposure pathways: Subject to the availability of data and
resources, EPA will identify and evaluate local-scale information (e.g., presence of lead-

54	Zartarian, Valerie, et. al." Lead Data Mapping to Prioritize US Locations for Whole-of-Government Exposure
Prevention Efforts: State of the Science, Federal Collaborations, and Remaining Challenges"

American Journal of Public Health 112, (2022) S658_S669, https://doi.org/10.2105/AJPH.2022307Q51

55	https://www.epa.gov/eiscreen

42


-------
based paint and lead-based paint hazards, lead in drinking water, and other exposure
pathways) to supplement known mapping and scientific information with local knowledge;
and use 'on the ground' efforts, typically facilitated by government entities and, as
appropriate, incorporate community science approaches.

•	Focus EPA lead reduction actions on overburdened communities where lead exposures
and blood lead levels are among the highest: Targeting technical and financial resources to
address documented priorities will generally provide the largest public health protection
and the most efficient use of resources. In partnership with communities, EPA will develop
and implement action plans for interventions in these areas. Interventions may include
collaboration on funding (e.g., grants, technical assistance); partnerships with community
organizations, faith-based institutions, foundations; and coordinated actions to achieve
compliance. EPA's Regional Children's Health Coordinators will support regional actions to
reduce and address children's exposure to lead in all media and enhance caretaker
knowledge to better protect children from exposures to lead.

•	Provide more job training for reducing or removing lead hazards: Identifying and
addressing lead hazards requires training, skills building, work experience, and certification.
For lead-based paint, EPA supports job training for contractors/renovators who disturb
lead-based paint in homes. Individual contractors and their firms are both required to be
trained and certified in RRP activities (See Goal 1, Objective A for more details). EPA will also
educate communities about the Brownfields Job Training Grants and the Superfund Job
Training Initiative workforce-development partnerships with local training organizations and
employers, and local markets that seek certified staff in remediation of contaminated sites
and for lead-based paint abatement.56

APPROACH 2: Reduce lead exposures nationally through protective standards, analytical

tools, and outreach

•	Increase cross-agency coordination on lead policies and regulations, and invest in
community science and monitoring: EPA staff will engage in a range of intra- and inter-
agency activities to help focus risk management actions to address lead exposures in
overburdened communities. Efforts will include working with the Lead Subcommittee of the
Presidents Task Force on Environmental Health Risks and Safety Risks to Children, and its
seventeen White House office and federal agency members, which serves as a forum to
foster interagency collaborations.

•	Enhance participatory science on lead: EPA will support the use of community-based
participatory science through the development of easy-to-use, reliable, and accurate data
monitoring tools, systems for facilitating data sharing with communities, and systems and

56 Brownfields Job Training Grants: https://www.epa.gov/brownfjejds/broyynfields-jqb-training-it-grants.

Superfund Job Training Initiative: https://www.epa,gov/superfund/superfund-job-training-initiative.

Lead-based paint abatement: http$://www.epa.gov/lead/lead-abatenient~in$pection~and-ri$k~a$$e$$roent.

43


-------
platforms to make data analysis and interpretation readily accessible to community
stakeholders and decision makers at all levels of government.

•	Increase cross-agency coordination of analytical tools: EPA offices will continue to
coordinate on the application of "fit-for-purpose" lead exposure and blood lead models to
inform policy decisions to address lead contamination in multiple environmental media, and
provide support to interagency partners (e.g., HUD) exploring options to further reduce
exposure to environmental lead.

APPROACH 3: Reduce lead exposures with a "whole of EPA" and "whole of government"
approach

•	Collaborate across agencies and departments to identify and address lead hotspots in the
U.S.: The CDC, EPA, and HUD will coordinate their efforts to identify lead hot spots by
sharing information and collaborating on mapping and other tools.57 These agencies will
also collaborate to identify measures that can be taken to address lead exposure for other
at-risk groups including seniors and individuals with disabilities.

•	Support the pediatric clinical care community to protect children from exposures to lead:

EPA will continue to work with the ATSDR to support the Pediatric Environmental Health
Specialty Units (PEHSUs). The PEHSUs, located in each of EPA's ten Regions, are a group of
experts in the prevention, diagnosis, management, and treatment of health issues that arise
from environmental exposures from preconception through adolescence.58 Their focus on
clinical care and public health from an environmental health perspective is vital to
supporting communities and addressing historical and ongoing environmental justice
concerns. Support of PEHSUs not only allows capacity for community outreach, medical
consultations, and guidance for care of children exposed to high levels of lead, but also
important programs such as the Pediatric and Reproductive Environmental Health Scholars
(PREHS) program, which helps foster a pipeline of healthcare professionals who possess the
skills and knowledge to address the complexities of pediatric and reproductive
environmental health.59

REGIONAL COMMUNITY CASE STUDY: Starting in 2001, EPA worked with many local partners
to identify remaining areas and sources of lead risk in Boston, Massachusetts communities and
invested resources with a goal to "Virtually End Childhood Lead Poisoning in Boston by 2010."
At the time of this effort, children with blood lead levels > 10 micrograms per deciliter were top
priority and this case study includes data at that level. EPA used Geographic Information System
mapping with data from census layers including housing built before 1950 and areas with

57	Zartarian, Valerie, et. al. "Lead Data Mapping to Prioritize US Locations for Whole-of-Government Exposure
Prevention Efforts: State of the Science, Federal Collaborations, and Remaining Challenges" American Journal of
Public Health 112, (2022) S658_S669, https://doi.org/10.2105/AJPH.2022307Q51

58	Pediatric Environmental Health Specialty Units, https://www.pehsu.net.

59	Pediatric and Reproductive Environmental Health Scholars program, https://grants.nih.gov/grants/guide/rfa-
files/RFA-ES-20-007.html

44


-------
children under the age of six to identify focus areas. Additional information from the local
health department illustrated that about 70 percent of the childhood elevated blood lead cases
were in only a handful of Boston neighborhoods. Dorchester and Roxbury had the highest
number of children with elevated blood lead levels. Recognizing that lead risk was not spread
equally across neighborhoods, Region 1 and its partners focused on neighborhoods that needed
the most help. Region 1 worked with local nonprofit organizations including the Lead Action
Collaborative to create a visual exterior assessment checklist deployed by EPA staff and
volunteers to over 15,000 houses in high-risk areas to assess housing conditions for items that
may indicate presence of lead risk including peeling paint, presence of bare soil and/or paint
chips, and other factors.

Region 1 brought the full power of available Agency resources, including inspections, technical
assistance, soil sampling, and grants, and its partners' resources including abatement funds,
LSLR, and outreach, directly to the neighborhoods to help across programs. Region 1 conducted
over 60 lead inspections forTSCA Lead Disclosure Rule and Pre-Renovation Education Rule
compliance and followed with appropriate enforcement actions. Cases were settled for over $1
million in penalties and more than $5.7 million in SEPs, including one of the largest
enforcement actions of its kind, which removed lead hazards from 10,400 apartments in the
state. Region l's soil sampling identified hot spots for action. LSLR was prioritized in target
areas along with education, outreach, and assistance to regulated entities, schools, and families
on how to minimize lead exposure from paint, dust, drinking water, and soil.

Since launching joint targeting efforts with state, local government, and many community
partners in 2001, the number of elevated blood lead levels in Boston children dropped from
1,123 cases in 2001 to 163 cases in 2010. Although Region l's initiative ended in 2010, progress
continued. Reported data available from 2019 indicated 46 confirmed cases at the 10
micrograms per deciliter or higher benchmark. This case study demonstrates that sustained EPA
and partner investment in a geographic area across media can achieve impressive and
sustainable results. Because a safe level of lead in children's blood has not been identified,
Region 1 is working on new strategies with communities in New England to focus on reducing
or preventing childhood lead exposure from these sources in the future.

GOAL 3: COMMUNICATE MORE EFFECTIVELY WITH STAKEHOLDERS

Problem: In many communities, parents, families, and child care providers are often not aware
of lead until it is measured in the blood of children or adults. Under federal, state, and tribal
authorities, the education of primary caregivers on potential lead risks and exposure pathways
is often insufficient. Community stakeholders need additional support to give parents, families,
and other caregivers, including those with limited English proficiency and those with disabilities,
the right information at the right time in multiple languages. Often, information to prevent lead
exposure is not provided in plain language, nor does it use accessible electronic and

45


-------
information technology. Improved education and outreach efforts can help better inform
communities about minimizing lead exposure from all key sources including lead-based paint,
lead dust, drinking water, soil, air, and other sources of lead, such as religious or cultural
products, that may be particularly relevant for certain communities.

Public Input: Many of the public comments the Agency received were supportive of efforts to
reach out to communities with training, brochures, websites, and other outreach tools.
Commenters asked for more direct outreach to communities, including local health officials,
community organizations, and others to further inform the community of lead risks.
Commenters also asked that the Agency support development of interagency work groups and
advisory committees to identify communities with increased risks of lead exposure and develop
plans to reduce disparities in exposure.

Other public comments suggested EPA work with its federal partners to create clear, consistent
communications materials that clarify how the agencies regulate lead, describe how the
agencies work together to prevent exposures, and clarify where lead-related policies overlap
and where gaps exist.

Commenters recognized that digital literacy and availability are not equal across communities
and recommended that EPA take this into account when developing communications materials
to inform communities about lead exposures, health risks, and steps the Agency is taking to
reduce those risks. Similarly, commenters also requested that EPA adopt, and make standard,
best practices for engagement with communities, including the use of plain language,
appropriate context for statistics and measures, the use of visual aids, and the use of inclusive
language.

EPA appreciates the public comments and will continue to provide outreach to communities,
both from headquarters outreach programs and associated regional coordinators. Examples of
outreach include multimedia outreach for the National Lead Poisoning and Prevention Week,60
guidance on Do-lt-Yourself renovations, and lead-awareness training for the community such as
EPA's Lead Awareness in Indian Country: Keeping our Children Healthy! The amount, types of
training, and communities to which the Agency can provide outreach is contingent on the
resources available. The actions identified below reflect the Agency's ongoing consideration of
these comments.

Performance Measures and Milestones:

• EPA's Lead-Based Paint Program is a co-author of the Protect Your Family pamphlet, with
HUD and CPSC. The pamphlet explains the dangers of lead in the home and how to protect
families from lead-based paint hazards. To ensure this critical information is meaningfully
accessible to persons with limited English proficiency, the brochure is available in 12
languages: English, Arabic, Chinese Simplified and Traditional, French, Korean, Polish,

60 l1ttps://www.epa.gov/lead/national-lead-pqisoning-prevention-week

46


-------
Russian, Somali, Spanish, Tagalog, and Vietnamese. This key document is required by law to
be provided in pre-1978 house purchase and rentals to consumers. EPA commits to
reviewing the information annually for possible updating as new requirements are
developed.

•	By September 30, 2023, publish online a Spanish-language version of the Lead Awareness in
Indian Country: Keeping our Children Healthy! Curriculum. Additionally, work with partners
to determine if there is a need for the development of additional examples and materials.

•	By September 30, 2023, solicit advice from the Children's Health Protection Advisory
Committee (CHPAC) on how to better protect children from exposure to lead and enhance
the "whole of EPA" and "whole of government" approach.

EPA ACTIONS:

APPROACH 1: Reduce lead exposures locally with a focus on communities with disparities and

promote environmental justice

•	Create targeted plain language multi-media education, training, and outreach materials:

EPA will raise public awareness in communities with the highest number of children with
blood lead levels above the CDC blood lead reference value to give parents, families, and
other stakeholders information on how to prevent lead exposure from lead-based paint
dust, drinking water, soil, and air (if applicable). Efforts will also include outreach to the
lead-based paint renovation and repair stakeholders (discussed in greater detail in Goal 1,
Objective A). Materials will be translated for and made available to persons with limited
English proficiency and made accessible for persons with disabilities to reach all populations
at risk in targeted geographic areas as well as local businesses, including contractors,
plumbers, and realtors.

•	Support development of community-based tools: EPA will work with other federal
agencies, state, tribal, and local governments to support community-based tools. For
example, the Flint Registry61 is a tool built by the community to connect people to services
to promote health and wellness. This tool was developed with a grant from HHS and has
been recognized for its value in addressing the communities' needs for data and
collaboration.62

APPROACH 2: Reduce lead exposures nationally through protective standards, analytical

tools, and outreach

•	Develop and deploy coordinated educational and prevention messages at a national scale:

EPA will work with the other federal agencies to develop a national repository of materials
on lead and make it available to the public. EPA will use evidence-based strategies to

61	httpsi//www,flintregistry,org

62	Indiana Advisory Committee to the U.S. Commission on Civil Rights (2020}

47


-------
develop community-scale interventions to assess which approaches are most effective in
achieving the goals of reducing lead exposures and adverse health effects.

•	Develop and improve guidance, templates, and risk communication materials to support
training, outreach, and community engagement: EPA will improve guidance and templates
to help states and communities communicate lead risk to households with higher risks for
lead exposure (e.g., from lead-based paint, LSLs) and measures to reduce lead exposures.
Efforts will also include revisions of drinking water regulations and guidance (discussed in
greater detail in Goal 1 Objective B). Materials will be translated for and made available to
persons with limited English proficiency and made accessible for persons with disabilities as
needed to reach all populations at risk in targeted geographic areas. EPA will use a wide
range of approaches to distribute new guidance and communication material, including in-
person and virtual events, social media messaging, videos, press releases, and web
publications, as well as outreach through partner agencies and stakeholders.

APPROACH 3: Reduce lead exposures with a "whole of EPA" and "whole of government"

approach

•	Promote National Lead Poisoning Prevention Week (NLPPW): Each October, EPA partners
with CDC, HUD, and other interested federal agencies and stakeholders, to heighten
awareness of lead exposure and lead poisoning by providing resources for the public to use
to encourage preventive actions to reduce childhood lead exposure during NLPPW and
throughout the year. These efforts will aim to bring together individuals, organizations,
industry, and tribal, state, and local governments to reduce childhood exposure to lead by
increasing lead poisoning prevention awareness with a focus on children's health and
communities with greatest exposures to lead. Objectives include highlighting the many
ways parents, caregivers, and communities can prevent the serious health effects of lead by
reducing children's exposure to lead, with a focus on the hazards of lead-based paint in pre-
1978 housing, schools, and child care facilities; and increasing awareness of the Lead RRP
rule.

•	Support use of the Tribal Lead Curriculum/Lead Awareness Curriculum: Using the Lead
Awareness in Indian Country: Keeping our Children Healthy! Curriculum, EPA is preparing
tribes and community leaders to teach the robust set of educational tools that provide
practical, on-the-ground, community-based resources to reduce childhood lead exposure
within their own communities. The Curriculum, also referred to as the Tribal Lead
Curriculum or Lead Awareness Curriculum, was developed with tribes and designed with
the idea that it would be used and modified by all communities across the U.S. and its
territories. The Curriculum creates a starting point to hold informed conversations within
communities to teach parents and caregivers about lead. This Curriculum empowers
individuals to act within their own homes to protect their children and communities from
potential lead exposure. By the Fall of 2023, EPA plans to publish on its website a Spanish-
language version of the over 200 pages of materials included in this training.


-------
• Consult with children's environmental health experts through the CHPAC federal advisory
committee: EPA will seek advice from the CHPAC to better focus and improve the Agency's
efforts to protect and provide protective remedies for children from exposure to lead and
to enhance our "whole of EPA" and "whole of government" approach. CHPAC is a body of
external researchers, academicians, health care providers, environmentalists, state and
tribal government employees, and members of the public who advise EPA on regulations,
research, and communications related to children's health. CHPAC provides advice on topics
such as air and water pollution regulations, chemical safety programs, risk assessment
policies, risk communication materials/strategies, and research, which reflect the wide-
ranging environmental issues which affect the health of children.63 Charge questions
submitted to CHPAC could include a request for review of the Lead Strategy, review of the
strategy's performance measures and milestones, and advice on the Agency's actions to
protect children from exposures to lead.

REGIONAL COMMUNITY CASE STUDY: Clemson University Extension worked with EPA to
provide outreach and education to schools and child care centers in two low-income school
districts. EPA's Children's Environmental Health Program provided Clemson's College of
Agriculture, Forestry and Life Sciences a $25,000 grant to educate the public in hazards of lead
exposure in drinking water. This work was completed in partnership with South Carolina
Department of Health and Environmental Control (SC DHEC) to support the EPA's WIIN Act
Grant 2107: Lead Testing in Schools and Child Care Facilities. This grant is managed by SC DHEC
and allows for public schools and licensed child care centers to voluntarily participate in testing
their facilities for lead in drinking water at no cost. Clemson's goal was to provide targeted
outreach and education in support of WIIN Grant 2107 to 25 schools/child care centers that
were serving younger children in underserved and low-income communities.

Clemson University staff and students exceeded their goal and provided outreach and
education to 32 schools located in Pickens and Lexington counties. They also developed a
stand-alone webpage that showcased videos, written content, and resources. The students
created a series of 8 short videos that included: identifying sources of lead, flushing drinking
water lines and lead management in school facilities. They also developed five written
documents that consisted of rack cards, factsheets, and infographics. Both staff and students
made valuable connections with SC DHEC and Charleston County Schools District throughout
the project.

63 U.S. Environmental Protection Agency. Children's Health Protection Advisory Committee.

httpsi//www,epa,gov/children/chpac.

49


-------
GOAL 4: SUPPORT AND CONDUCT CRITICAL RESEARCH TO INFORM
EFFORTS TO REDUCE LEAD EXPOSURES AND RELATED HEALTH RISKS

Problem: Scientific approaches to support EPA and community actions are needed to inform
Goals 1, 2, and 3 - including in the areas of lead integrated exposure and health science
assessment, blood lead level modeling, lead hotspot mapping, analysis of environmental
information, development of methods to measure and reduce bioavailability and
bioaccessibility, and use of drinking water science to inform corrosion control and identification
of LSL and treatment strategies. EPA has prioritized research on source identification and
mitigation, understanding exposure routes, and identifying high lead exposure locations for
targeting actions. EPA also acknowledges the need to better understand what predicts health
and developmental outcomes (and the variability/disparities in those outcomes) among
children who have already been exposed to lead. EPA will work in collaboration with Federal
partners in the President's Task Force on Environmental Health Risks and Safety Risks to
Children (for example, National Institutes of Health and CDC/ATSDR) who have prioritized this
issue. This collaboration will inform efforts by other agencies to mitigate the health and
developmental effects following exposure to lead.

Public Input: Public comments related to EPA's research to inform efforts to reduce lead
exposures fell into several categories. Multiple commenters asked that expanded categories of
lead-related human health benefits be considered. EPA is currently developing methods to
quantify cardiovascular mortality benefits in regulatory analysis and will continue to develop
methodologies for additional endpoints affected by current lead exposures.

Commenters noted the need for coordinated approaches and better definition of a blood lead
level or modeling strategy. Commenters also provided very specific recommendations for
modeling and modeling parameters. EPA will consider these comments in several ways. EPA will
continue development of the All-Ages Lead Model for estimation of blood lead levels for
children, adolescents, and adults of all ages under both chronic and episodic lead exposure
scenarios. EPA will also continue its support of the Integrated Exposure Uptake Biokinetic
(IEUBK) 2.0 model64 to estimate risks of children's blood lead levels for site specific assessments
and the Stochastic Human Exposure and Dose Simulation Model for multimedia chemicals65
coupled with IEUBK 2.0 for national scale probabilistic modeling. Finally, EPA will continue to
coordinate on the application of "fit-for-purpose" lead exposure and blood lead models to
make informed policy decisions to address lead contamination.

Public commenters recognized the importance of identifying and replacing LSLs while
maintaining optimized corrosion control to mitigate the release of lead from sources within

64https://www. epa.gov/superfund/lead-superfund-sites-software-and-users-manuals

65https://www. epa.gov/chemical-research/stochastic-human-exposure-and-dose-simulation-sheds-estimate-
human-exposure

50


-------
plumbing systems. In response to these comments, EPA has both added and revised actions
associated with LSL research, including LSL identification, quantifying lead in drinking water,
and evaluating filter effectiveness. EPA also updated text that clarifies multiple areas of
research to understand and reduce lead in drinking water including LSL identification strategies,
corrosion control strategies, point-of-use filter effectiveness, and particulate lead. EPA intends
to continue providing state-of-the-science small water system training to tribes and state,
municipal, and utility water operators.

In response to comments related to lead in soil and dust, EPA added a description of intramural
and extramural research designed to better understand soil and dust ingestion. This is a critical
parameter in estimating lead exposure from sources of lead such as deteriorating house paint
and contaminated soil.

EPA appreciates the wide-ranging public comments it received in response to EPA's Draft Lead
Strategy, Goal 4. The actions identified below reflect the Agency's ongoing consideration of
public comments. Comments the Agency did not respond to generally applied to policy issues
outside the purview of research or detailed research issues that were not appropriate for
inclusion in a broad strategy document.

Performance Measures and Milestones:

•	Over a 5-year period, develop tools and informational resources for LSL identification
technologies to assist small and underserved water systems to efficiently complete LSL
inventories.

•	Each year, updates to these LSL identification technology resources will be shared at the
EPA Drinking Water Workshop: Small Systems Challenges and Solutions.

EPA ACTIONS:

APPROACH 1: Reduce lead exposures locally with a focus on communities with disparities and
promote environmental justice

•	Extend mapping methods to identify lead hotspots in the U.S. for informing targeted
actions in disproportionately impacted communities: EPA will apply a science-based
approach, based on available data and local knowledge, for characterizing areas of the
U.S. regarding lead exposure potential. EPA will extend and apply mapping efforts focusing
on identifying high potential exposure areas with co-occurrence of risk factors (e.g., higher
blood lead levels, older housing stock, socio-demographic factors, and environmental lead
sources).

•	Identify LSLs and collect drinking water samples: EPA will work with municipalities and
utilities on solutions-based research designed to implement and evaluate water sampling
strategies and approaches for LSL identification.

51


-------
• Quantify and monitor lead and copper in drinking water and assess filter effectiveness:

EPA will continue to develop sampling strategies and methods to quantify lead in drinking
water and enhance the ability of community participatory scientists to contribute useful
data to regulators' decision-making. EPA will also assess the efficacy of point-of-use filters
for removing lead nanoparticles from drinking water.

APPROACH 2: Reduce lead exposures nationally through protective standards, analytical

tools, and outreach

•	Quantify additional benefits from reducing exposures to lead for regulatory impact
assessments: EPA is developing new analyses to estimate the social benefits of reducing
lead exposures. Current practice is to include only effects on children's cognitive function in
economic analyses of EPA policies and programs. However, lead can have a variety of other
adverse health effects on children and adults, such as attention disorders and
cardiovascular morbidity and mortality. EPA has developed an approach to quantify
potential reductions in cardiovascular mortality related to lead exposure reductions. EPA
will continue to develop methodologies to estimate the benefits of reducing lead
exposures.

•	Conduct multimedia lead modeling and related research to inform regulatory decisions
and site assessments: EPA will update the software, user guide, and technical support
documentation for the All-Ages Lead Model to incorporate recommendations of the EPA
Science Advisory Board. Support will continue for the IEUBK Model 2.0 to use
environmental lead exposures to estimate risks of children's elevated blood lead for site
specific assessments. National-scale probabilistic modeling will be applied with the SHEDS-
IEUBK model (Stochastic Human Exposure and Dose Simulation Model for multimedia
chemicals coupled with IEUBK) to inform regulatory decisions and guidance by EPA and
HUD.

EPA has awarded grants for "Estimating Children's Soil and Dust Ingestion Rates for
Exposure Science" that will support research to address critical life stage-specific exposure
factors for exposure modeling.66 A series of peer-reviewed publications on soil and dust
ingestion will be completed to inform model input parameters for estimating blood lead
levels from environmental exposures. With new data available in the literature, EPA will
work to update soil and dust ingestion estimates presented in the EPA's Exposure Factors
Handbook.67

•	Conduct lead bioavailability and isotope research to inform Agency actions: EPA will work
with HUD to continue the analysis of lead content and bioavailability in water, soil, and dust

66	l1ttPs://www.epa.gov/research-grants/estimating-children^soil-and-dust-ingestion-rates-expqsure-scjence

67	https://cfpub. epa.gov/ncea/risk/recordisplay. cfm?deid=236252


-------
samples from the American Healthy Homes Survey II.68 EPA is working on lead isotope
analysis that will help inform identification of environmental lead sources to support risk
management and other potential Agency activities. EPA is developing an in vitro cell line
assay for bioavailability for determining site specific cleanup levels. The Agency will advance
research methods to immobilize or reduce the bioavailability of lead in soil.

•	Evaluate soil-lead and dust-lead relationship for target housing: EPA will review the
relationship between soil-lead and dust-lead in pre-1978 homes, considering data from
HUD's American Healthy Homes Survey II and the Lead ISA.69 EPA will use this information
to support regulatory actions to reduce and prevent lead exposures.

•	Address lead-based paint definition data needs: EPA may address some of the data gaps
related to the definition of lead-based paint under TSCA by sponsoring a technical
conference. The objectives of the workshop may include characterizing the capabilities of
field portable XRF and other technologies at lower levels of lead in paint and identifying
opportunities, limitations, and constraints for measurement and detection of low levels of
lead in paint.

•	Conduct research to better understand and reduce lead in drinking water; EPA will
conduct research related to strategies to identify LSLs including research on innovative
detection methods. EPA will also conduct laboratory and field research, with a focus on
mitigation methods to reduce exposure to lead from drinking water.

EPA will conduct research on corrosion control treatment and control strategies to reduce
soluble lead in drinking water. EPA will evaluate point-of-use treatment device effectiveness
under a variety of field and lab conditions considering soluble and particulate lead under a
range of concentrations. Research will also focus on understanding how changes in water
treatment practices affect the release of particulate lead into water.

Other lead reduction research will include the refinement of plumbing modeling to predict
concentrations of lead in single-family and multifamily homes with different plumbing
materials, pipe layouts, and usage patterns. EPA will also conduct research on lead source
characterization and assessment to better understand lead release mechanisms and
corrosion control effectiveness.

•	Small water system workshops and training: To support the efforts of state and local
officials to assist small systems, EPA's Office of Research and Development (ORD) and Office
of Water (OW), in cooperation with Association of State Drinking Water Administrators
(ASDWA), has held an annual workshop for the past 19 years to provide timely information
on a variety of drinking water topics relevant to small systems. These provide a forum for
EPA scientists and water experts from across the U.S. to present state of the science

68	https://www.epa.gov/americaschildrenenvironment/american-healthv-homes-survev-ahhs

69	https://www.epa.gov/isa/integrated-scjence-assessment-isa-lead

53


-------
training and progress updates to state, tribal, and municipal officials, and utility water
operators. Corrosion control technology, LSL identification and replacement, and regulatory
updates affecting lead in drinking water are perennial topics. EPA will continue to hold
these workshops.

APPROACH 3: Reduce lead exposures with a "whole of EPA" and "whole of government"
approach

•	Collaborate on science-based mapping efforts to identify lead hotspot locations for
informing targeted risk reduction actions: EPA will engage with HUD and CDC to improve
data mapping for identifying and addressing multimedia lead exposures in underserved
communities.70

•	Increase cross-agency coordination on data collection and analytical tools: EPA offices will
continue to coordinate on the application of "fit-for-purpose" lead exposure and blood lead
models to inform policy decisions to address lead contamination in multiple environmental
media, and provide support to interagency partners (e.g., HUD) exploring options to further
reduce exposure to environmental lead. Improved data collection will enhance the ability of
EPA and its federal partners to design and evaluate lead reduction programs.

•	Collaborate with HUD and other federal agencies on lead-based paint issues: EPA will
collaborate with HUD and potentially the CPSC, National Institute of Standards and
Technology, and the CDC on a virtual public meeting and technical conference regarding
lead-based paint definition data needs.

REGIONAL COMMUNITY CASE STUDY: EPA's research on particulate and soluble lead in
drinking water was used to help address elevated lead levels found in the drinking water of
University Park, Illinois. The village had changed the source of its drinking water from
groundwater to surface water, and the treated surface water had a different water quality (i.e.,
lower alkalinity and hardness) than did the previously used groundwater. Not long after this
change in source water, during compliance sampling for the EPA's Lead and Copper Rule, the
system was found to have exceeded the lead action level. Although there are no known LSLs in
the village, there were other sources of lead in the household plumbing, such as leaded solder
and brass fixtures.

The community and the state of Illinois reacted rapidly and issued a "Do Not Drink" order for
the community; they also reached out to EPA to ask for assistance in understanding why this
exceedance occurred when no LSLs were present. The Agency conducted a field sampling study
in University Park to help identify the cause and mechanisms of elevated lead release. The
objective of the sampling was to characterize the form, size, and composition of lead particles

70 Valerie Zartarian, Antonios Poulakos, Veronica Helms Garrison, Nicholas Spalt, Rogelio Tornero-Velez, Jianping
Xue, Kathryn Egan, and Joseph Courtney, 2022: Lead Data Mapping to Prioritize US Locations for Whole-of-
Government Exposure Prevention Efforts: State of the Science, Federal Collaborations, and Remaining Challenges
American Journal of Public Health 112, S658_S669, https://doi.org/10.2105/AJPH.2022307Q51


-------
in University Park's drinking water. Samples were sent to the EPA's analytical laboratory to
conduct multiple analyses including lead in water concentrations, particle size fractionation,
electron microscopy, and x-ray diffraction techniques. These analyses showed the types of
particles that were being formed in their water and provided insight into the mechanism of lead
release which was an important piece of the decisions on how to improve corrosion control
treatment for their specific water quality parameters. EPA's experts also participated in
meetings with the community to help explain the scientific data they had collected. This
research and technical support helped to inform guidance to the state and village on lead
solder corrosion, which has not received the same amount of research as LSL corrosion. The
complicated situation at University Park has seen improvements in drinking water lead levels
with additional monitoring needed.


-------
CONCLUSION AND IMPLEMENTATION OF EPA's LEAD STRATEGY

Implementation of EPA's Lead Strategy will result in the Agency taking more effective and
efficient actions to minimize lead exposures with an emphasis on overburdened communities
and promoting environmental justice and equity. EPA's enhanced actions described in this
strategy will further reduce exposures from lead-based paint, dust, drinking water, soils, and air
to all Americans with focused attention on significant near-term reductions in exposures for life
stages and population groups currently burdened with disproportionately higher lead
exposures. EPA is committed to applying a whole of government approach to its efforts to
reduce exposures to lead, using best available science and technology and all available
resources and regulatory authorities to achieve that goal.

EPA's Lead Strategy is closely aligned with the priorities set forth in the EPA's Fiscal Year 2022 -
2026 Strategic Plan. Specifically, Goal 2 of the Strategic Plan is to Take Decisive Action to
Advance Environmental Justice and Civil Rights. This goal is designed to achieve tangible
progress for historically overburdened and underserved communities and to ensure the fair
treatment and meaningful involvement of all people regardless of race, color, national origin,
income, disability, age or sex in developing and implementing environmental laws, regulations,
and policies.

EPA is currently developing several indicators of disparity that will assess the Agency's
performance under Goal 2 of the Strategic Plan. The indicators are meant to characterize health
disparities and disparities in environmental conditions, and, where applicable, highlight
progress in eliminating the disparities. EPA will measure progress against these indicators each
year. We expect that at least one of the Goal 2 Strategic Plan indicators will be associated with
lead exposures and health outcomes. The actions to minimize lead exposures described in the
Lead Strategy will be integral to the demonstration of progress against lead-related indicators
of disparity. EPA is targeting the Fall of 2023 for the finalization and public release of these
indicators.

This strategy is an important step forward for EPA as we work to strengthen public health
protections and address legacy lead contamination in communities, especially those with the
greatest exposures. Many of the actions described in this strategy have only recently been
initiated and funded. As these programs mature, EPA expects to continue to review the
effectiveness of its actions to reduce lead exposures and to revise or set new targets for
measuring performance. We anticipate that in the future, the Lead Strategy will be updated to
reflect new initiatives, address newly identified gaps, and add new performance measures and
milestones to meaningfully track EPA's progress to reduce the health burdens associated with
exposures to lead pollution. We also plan to incorporate the relevant lead-related Goal 2
Strategic Plan indicators of disparity described above. Future updates, plans, and progress will
be made available at EPA's lead website, www.epa.gov/lead.

56


-------
APPENDIX: PERFORMANCE MEASURES AND MILESTONES

Performance Measures and Milestones

GOAL 1: REDUCE COMMUNITY EXPOSURES TO LEAD SOURCES

Objective A:

Reduce Exposure to Lead
in Homes and Child-
Occupied Facilities with
Lead-Based Paint and
Other Hazards

Measures

•	By September 30, 2023, provide free or low-cost training
to 500 contractors that are located in and around
communities with environmental justice concerns spread
throughout the U.S. over fiscal years 2022 and 2023.

•	By September 30, 2023, host national and community-
based Lead Awareness Curriculum sessions for 515
community leaders and Understanding Lead sessions for
340 community members, which reflects a 10% increase
in participation from fiscal year 2022 to fiscal year 2023.

Milestones

•	By March 2023, publish the Heavy Metals
in Cultural Products: Outreach and
Educational Resources Toolkit on the EPA
website.

•	By February 2023, propose, and by June
2024, finalize the Dust-lead Hazard
Standards (DLHS) and Dust-lead Clearance
Levels (DLCL) Rule.

Objective B:

Reduce Exposure to Lead
from Drinking Water

Measures

•	Track and report total funds to disadvantaged
communities for projects that support reduction of lead
in drinking water.

•	By the end of 2022, partner with four states to establish
LSLR Accelerators, which will provide targeted technical
assistance and develop best practices to help address the
barriers disadvantaged communities face in replacing
LSLs.

•	By the end of 2022, conduct outreach on the new
"Guidance for Developing and Maintaining a Service Line
Inventory" to help water systems develop LSL inventories
as soon as possible to begin replacement programs and
no later than the Lead and Copper Rule Revisions
compliance deadline of October 2024.

Milestone

• By the end of 2023, propose, and by

October 2024, take final action on the Lead
and Copper Rule Improvements to
strengthen the regulatory framework and
address lead in drinking water.


-------
GOAL 1: REDUCE COMMUNITY EXPOSURES TO LEAD SOURCES

Objective C:

Reduce Exposure to Lead in
Soils

Measures

•	By September 30, 2026, complete 225 Superfund
cleanup projects that address lead as a contaminant
(averaging 45 each year).

•	By September 30, 2023, review results of the Superfund
Lead Collaboration Pilot projects and where appropriate,
update Superfund guidance to reflect best practices.

•	Report annually the number of Brownfields cleanups
that addressed lead contamination, as reported by grant
recipients.

Milestone

• By June 30, 2023, evaluate and revise the
Residential Soil Lead Guidance for
Contaminated Sites to protect communities
by further reducing the potential for
exposure to lead in soil.

Objective D:

Reduce Exposure to Lead
Associated with Emissions
to Ambient Air

Milestones

•	Projected completion of the current lead NAAQS review in 2026.

•	Anticipated completion of rulemakings for important lead emissions sources over the next two years:
o In 2023, secondary lead smelters, lead acid battery manufacturing, and integrated iron and steel

manufacturing.

o In 2024, primary copper smelters and large municipal waste combustors.

•	In October 2022, EPA issued a proposed finding that lead emissions from aircraft engines that operate on
leaded fuel cause or contribute to air pollution that may reasonably be anticipated to endanger public
health and welfare. After evaluating comments on the proposal, EPA plans to issue any final endangerment
determination in 2023.

Objective E:

Reduce Exposure to Lead
Through Enforcement and
Compliance Assurance

Measures

•	Each year, direct enforcement resources to at least one community with environmental justice concerns in
each Region, to help address the exposures to lead in that community and take appropriate enforcement
action.

•	Each year, publicly report on national statistics related to lead cleanups and inspections, including whether
the inspections occurred in communities with environmental justice concerns.

	GOAL 2: IDENTIFY COMMUNITIES WITH HIGH LEAD EXPOSURES AND IMPROVE THEIR HEALTH OUTCOMES	

Milestone

• By September 30, 2024, develop an interim blueprint for identifying high lead exposure risk locations based on research identifying lead
exposure hotspots in Michigan, to be shared with internal and external public health partners for broader applicability and capacity
building in the U.S.	

58


-------
GOAL 3: COMMUNICATE MORE EFFECTIVELY WITH STAKEHOLDERS

Measure

• EPA's Lead-Based Paint Program is a co-author of the Protect
Your Family pamphlet, with HUD and CPSC. The pamphlet
explains the dangers of lead in the home and how to protect
families from lead-based paint hazards. To ensure this critical
information is meaningfully accessible to persons with limited
English proficiency, the brochure is available in 12 languages:
English, Arabic, Chinese Simplified and Traditional, French,
Korean, Polish, Russian, Somali, Spanish, Tagalog, and
Vietnamese. This key document is required by law to be provided
in pre-1978 house purchase and rentals to consumers. EPA
commits to reviewing the information annually for possible
updating as new requirements are developed.

Milestones

•	By September 30, 2023, publish online a Spanish-language
version of the Lead Awareness in Indian Country: Keeping our
Children Healthy! Curriculum. Additionally, work with partners to
determine if there is a need for the development of additional
examples and materials.

•	By September 30, 2023, solicit advice from the Children's Health
Protection Advisory Committee (CHPAC) on how to better protect
children from exposure to lead and enhance the "whole of EPA"
and "whole of government" approach.

GOAL 4: SUPPORT AND CONDUCT CRITICAL RESEARCH TO INFORM EFFORTS TO REDUCE LEAD EXPOSURES AND RELATED HEALTH RISKS
Measures

•	Over a 5-year period, develop tools and informational resources for LSL identification technologies to assist small and underserved water
systems to efficiently complete LSL inventories.

•	Each year, updates to these LSL identification technology resources will be shared at the EPA Drinking Water Workshop: Small Systems
Challenges and Solutions.	

59


-------

-------