Lead Contamination

Lead is a naturally occurring metal used in many industries such as manufacturing and construction. Despite being natural, lead is hazardous to human health and there is no safe level of exposure. Even small amounts of lead can cause damage to the brain, nervous system, and kidneys, interfere with the formation of red blood cells, and result in lifelong learning disabilities and motor coordination impairment.

Lead is particularly harmful to children because their developing bodies absorb more lead than adults do, and their brains and nervous systems are more sensitive to damage. Pregnant women are also particularly susceptible to lead, and exposure can cause serious harms during pregnancy. More information about the harmful effects of lead can be found on the EPA’s website.

At this time, there is no known cure for lead poisoning and the harmful effects of exposure to lead are irreversible; therefore, it is important to identify common sources of lead and take steps to avoid exposure in the first place.[1] This can present a challenge because the health risks associated with lead can be difficult to detect as lead often cannot be seen, smelled, or tasted.

To determine whether a person has been exposed to lead, doctors analyze the concentration of lead absorbed into a person’s blood. While there is no safe level of lead in the blood, the Centers for Disease Control (CDC), as of 2022, consider a high blood lead level in children as being equal to or greater than 3.5 micrograms per deciliter (μg/dL).[2] The CDC reports that approximately half a million children ages 1-5 have blood lead levels above this level, making lead a major public health concern.[3]

 

Common Sources of Lead Contamination:

If you think any of these potential sources may be present in your household or community, you should be aware of potential lead exposure and take precautions.

 

Laws Regulating Lead

Lead is regulated under several different laws administered by the Environmental Protection Agency (EPA) including:

  • Toxic Substances Control Act
  • Clean Water Act
  • Safe Drinking Water Act
  • Comprehensive Environmental Response, Compensation, and Liability Act
  • Clean Air Act

This chapter focuses on lead contamination in paint, dust, and soil and provides some information about lead contaminated soil clean-up efforts. For more information on contaminated site cleanup generally, see Hazardous Waste, Toxic Substances, and Contaminated Land Cleanup. Although water can also be contaminated by lead, this section does not cover lead contaminated water. Lead contaminated drinking water is discussed in Protecting Your Drinking Water. This chapter does not cover lead pollution in air as it is not a significant problem in Georgia.

 

Lead in Paint, Soil, and Dust

Paint

Soil

Dust

 

Jobs that are more likely to result in lead exposure:[7]

  • Artists (materials may contain lead)
  • Auto repairers (some car parts may contain lead)
  • Battery manufacturers
  • Repair and reconstruction workers (old paint may contain lead)
  • Construction workers (materials used may include lead)
  • Firing range instructors and gunsmiths
  • Glass manufacturers (lead may be used in glass production)
  • Lead manufacturers, miners, and refiners
  • Lead smelters
  • Manufacturers of bullets, ceramics, and electrical components
  • Painters (old paint may contain lead)
  • Plastic manufacturers (materials made may contain lead)
  • Plumbers and pipe fitters (pipes may contain lead)
  • Police officers or soldiers (ammunition contains lead)
  • Radiator repair workers (radiators may contain lead)
  • Recyclers of metal, electronics, and batteries (may contain lead)
  • Rubber product manufacturers (process contains lead)
  • Shipbuilders (materials used may include lead)
  • Solid waste incinerator operators (waste may contain lead)
  • Steel welder (galvanized steel is coated in part with lead)

 

Soil Screening, Health, Outreach and Partnership (soilSHOP)

If you are aware of soil contamination within your community, there are resources available to help educate individuals and your community. For example, to reduce exposure to lead and other heavy metals in soil, the Agency for Toxic Substances and Disease Registry (ATSDR) promotes and supports soilSHOP events. These events are intended to educate communities about the harms associated with lead contamination and offer free soil testing. If you think your community would benefit from a soilSHOP or if you would like to have your soil tested, you should reach out to ATSDR to inquire about setting up an event.

 

How Lead is Regulated Under Different Laws

Toxic Substances Control Act

Lead is regulated under the Toxic Substances Control Act (TSCA, pronounced “toss-kah”) because of its harmful effects and the risk of injury associated with exposure. For more information on TSCA generally, refer to Hazardous Waste, Toxic Substances, and Contaminated Land Cleanup.

Title IV of TSCA, Lead Exposure Reduction, specifically covers lead-based paint hazards.[8] The goal of this law was to create a national program aimed at reducing the risks of lead-based paint exposure from housing. The EPA administers TSCA and the relevant regulations.

TSCA directs the EPA to do the following in regulating lead:
  • Establish definitions for lead-based paint hazards, lead-contaminated dust, and lead-contaminated soil
  • Make sure workers engaged in detection and handling of lead hazards are properly trained
  • Publish requirements for the accreditation of training programs for workers
  • Set standards to evaluate the effectiveness of products used to detect or reduce risks
  • Establish standards and protocols for lead analysis in paint, soil, and dust
  • Create a certification program for laboratories conducting testing
  • Publish a pamphlet on lead hazard risks and the resources available

The EPA also works with the CDC and the National Institute for Environmental Health Sciences to determine the sources of lead exposure leading to elevated blood levels in children.[9]

 

Residential Lead Disclosure Program (Title X, Section 1018)

The EPA and the U.S. Department of Housing and Urban Development (HUD) are responsible for protecting the public from any lead-based paint hazards.[10] The EPA and HUD created a Residential Lead Disclosure Program that applies to “Target Housing.”[11] Target Housing is defined as any housing, both for rent or for sale, constructed before 1978, except housing for the elderly or persons with disabilities (unless any child under age 6 resides or is expected to reside in such housing), or any 0-bedroom dwelling (e.g., lofts, efficiencies, and studios).[12] More information about what is not included in the definition of Target Housing can be found here.

Regardless of whether you are looking to rent or purchase property, there are several steps that you should take to ensure you are aware of the risks related to lead contamination.

Because lead is so hazardous to human health, and its effects are irreversible, it is important to be informed about the property. You should determine whether the property you plan to rent or purchase was built prior to 1978. If so, the landlord or seller is required under the Residential Lead Disclosure Program to make certain disclosures to you of the dangers associated with lead.

 

Renting
Purchasing

 

Federal Lead Hazard Standard Regulation

The EPA passed the Federal Lead Hazard Standard Regulation in 2001 (2001 Rule) to identify contamination levels that constitute lead-based paint, lead contaminated dust, or contaminated soil hazards under federal law.[16]

A paint-lead hazard typically refers to conditions that cause exposure to lead that is dangerous to human health. Federal agencies use these standards as a benchmark when passing laws and regulations to clean up lead contamination in target housing (as defined above) and “child-occupied facilities.”[17]

Child-occupied facilities include any building constructed prior to 1978, visited regularly by the same child, under six years of age, on at least two different days within any week for at least three hours and for a combined weekly visit of at least six hours. Additionally, annually the child must visit the facility for at least 60 hours. The 2001 Rule also established dust clearance levels, which are used to evaluate the effectiveness of a required cleaning following an abatement, a project designed to permanently eliminate existing lead-based paint hazards.

Paint-lead hazards, dust-lead hazards, soil-lead hazards, and dust clearance standards set by the 2001 Rule are listed below. Please note that the EPA is in the process of revising these standards and strengthening them. In July 2023, the EPA proposed new dust-lead hazard standards and  dust clearance standards that will provide more protection by imposing stricter limits. As these new standards have not been finalized, the standards below are the current standards in effect at the time of writing in 2023.

 

Lead Hazard Levels

 

Lead Repair and Renovation Programs

The EPA developed two separate programs to address lead abatement (cleanup) and lead renovation, repair, and painting activities. Renovation, repair, and painting activities include most home contracting work that disturbs paint.

These activities are typically unrelated to lead issues, but could include resolving a leak, replacing a window, removing a wall, or even applying a fresh coat of paint. However, precautionary measures are still required because of the potential to disturb existing lead paint.

Lead abatement differs because it includes construction and cleanup efforts that are specifically designed to target lead contamination.

 

(1) Lead Renovation, Repair, and Painting Program
(2) Lead Abatement Program: Training and Certification

 

Responding to Lead Exposure

What to do if you think your home is contaminated:

While the best way to avoid hazards is to avoid renting or buying property with lead-based paint and lead-based paint hazards, that is not always possible. This also may not be necessary as lead-based paint that is still intact is not harmful to human health.

To take proper precautions, it is helpful to know the source of contamination.

You can test your own home using at-home test kits. There are two commercially available at-home tests that the EPA recognizes as complying with the RRP Rule. These include the 3M™ LeadCheck™ and the ESCA Tech D-Lead®. Both tests can be used to determine that lead-based paint is not present on wood, ferrous metal (alloys that contain iron), or drywall and plaster surfaces.[23] You can purchase these at-home test kits at your local hardware store.

However, the Georgia Department of Public Health still cautions that at-home testing may not always be reliable.[24] If you have any doubts as to the results, or if an at-home test kit indicates lead is present, consider hiring a certified risk assessor or inspector to determine if your home has lead hazards. The risk assessor can also recommend actions to take to address existing hazards. However, hiring a certified risk assessor or inspector can be costly. For help finding a certified risk assessor or inspector, call the National Lead Information Center at 1-800-424-LEAD (5323).

Even avoiding renting or buying property with lead-based paint present and conducting at home testing is not a definite way to avoid exposure. Lead exposure is also commonly caused by contact with lead contaminated dust or soil outside of the home (i.e., at school, or in the workplace).

It is important to keep in mind EPA’s recommended steps to mitigate your risk. The following sections provide more information on some of the EPA’s recommended precautions  for minimizing lead exposure and what to do if you think your home is contaminated.

Steps to minimize lead exposure:

 

(1) Reduce potential lead exposure within your home
(2) Reduce potential lead exposure outside your home

 

Steps if you suspect you or your family have been exposed to lead:

(1) Contact your doctor
(2) Contact the Georgia Department of Public Health
(3) Eliminate the source
(4) Advocate and educate others

Additional Resources and Contacts

Success Story:

Protecting Children From Lead By Challenging Outdated Standards

 


[1] See https://www.epa.gov/lead/learn-about-lead#effects; https://www.cdc.gov/lead-prevention/symptoms-complications/ for more information about the harmful effects of lead.

[2] See https://www.cdc.gov/lead-prevention/php/news-features/updates-blood-lead-reference-value.html for information about the current blood lead reference value.

[3] CDC, Preventing Lead Exposure in Children, https://www.cdc.gov/lead-prevention/prevention/index.html

[4] See CDC, Lead in Foods, Cosmetics, and Medicines, https://www.cdc.gov/lead-prevention/prevention/foods-cosmetics-medicines.html

[5] See Healthy Homes and Lead Poisoning Prevention, Georgia Department of Public Health, https://dph.georgia.gov/environmental-health/healthy-homes-and-lead-poisoning-prevention (select “Lead Frequently Asked Questions”).

[6] 6 C.F.R. § 1303.

[7] Lead, The National Institute for Occupational Safety and Health, https://www.cdc.gov/niosh/lead/about/index.html.

[8] 42 U.S.C. §§ 2681- 2692.

[9] 40 C.F.R. § 745.

[10] 40 C.F.R. §§ 745.100 – 745.119.

[11] 40 C.F.R. §§ 745.100 – 745.119.

[12] 40 C.F.R. § 745.223.

[13] 42 U.S.C. § 4852d.

[14] Guidance on The Homebuyer’s Option to Test For Lead-Based Paint and Lead-Based Paint Hazards, HUD https://www.hud.gov/sites/documents/20264_OPTIONTOTEST.PDF.

[15] 24 C.F.R. § 30.65.

[16] Lead; Identification of Dangerous Levels of Lead, 66 Fed. Reg. 1206, 1207 (Jan. 5, 2001) (codified as 40 C.F.R. § 745, effective on Mar. 6, 2001).

[17] Residential Property Renovation, 63 Fed. Reg. 29919 (June 1, 1998) (codified as 40 C.F.R. § 745, effective on June 1, 1999).

[18] Review of Dust-Lead Post Abatement Clearance Levels, 86 Fed. Reg. 983 (Jan. 1, 2021) (codified as 40 C.F.R. §745, effective on March 8, 2021).

[19]  O.C.G.A. § 31-41-1 (1994).

[20] Ga. Comp. R. & Regs. 391-3-24 (2022); 40 C.F.R. § 745.

[21] O.C.G.A. 31-41-1 (1994).

[22] 40 C.F.R. §§ 745.220 – 745.239.

[23] EPA, Lead Test Kits, https://www.epa.gov/lead/lead-test-kits.

[24] Healthy Homes and Lead Poisoning Prevention, Georgia Department of Public Health, https://dph.georgia.gov/environmental-health/healthy-homes-and-lead-poisoning-prevention.

[25] For more information, see EPA, United States Consumer Product Safety Commission, and United States Department of Housing and Urban Development, Protect Your Family From Lead In Your Home 1 (March 2021), https://www.epa.gov/sites/default/files/2020-04/documents/lead-in-your-home-portrait-color-2020-508.pdf.

[26] Healthy Housing Solutions, Childhood Lead Poisoning in Georgia: A Needs Assessment at 10 (2004), https://dph.georgia.gov/document/document/childhood-lead-poisoning-georgia-needs-assessment/download.

[27] O.C.G.A. §31-41-14.

[28] Erin Fitzgerald, Court Directs EPA to Better Protect Children from Lead Hazards in Homes and School, Earthjustice (May 14, 2021), https://earthjustice.org/news/press/2021/court-directs-epa-to-better-protect-children-from-lead-hazards-in-homes-and-schools.

[29] Id.

[30] Agya K. Aning, For the Second Time in Four Years, the Ninth Circuit has Ordered the EPA to Set New Lead Paint and Dust Standards, Inside Climate News (May 25, 2021), https://insideclimatenews.org/news/25052021/lead-paint-dust-standards-epa-ninth-circuit/.

[31] Health Effects of Lead Exposure, Childhood Lead Poisoning Prevention, Centers for Disease Control and Prevention, https://www.cdc.gov/nceh/lead/prevention/health-effects.htm (last accessed Apr. 13, 2022).

[32] Id.

[33] Lead Exposure Symptoms and Complications, Childhood Lead Poisoning Prevention, Centers for Disease Control and Prevention https://www.cdc.gov/lead-prevention/symptoms-complications/index.html.

[34] People at Increased Risk for Childhood Lead Exposure, Childhood Lead Poisoning Prevention, Centers for Disease Control and Prevention, https://www.cdc.gov/lead-prevention/risk-factors/index.html.

[35] Id.

[36] Agya K. Aning, For the Second Time in Four Years, the Ninth Circuit has Ordered the EPA to Set New Lead Paint and Dust Standards, Inside Climate News (May 25, 2021), https://insideclimatenews.org/news/25052021/lead-paint-dust-standards-epa-ninth-circuit/.

[37] Michael Phillis, 9th Cir. says EPA Must Revisit Lead-Related Standards, Law360, (May 14, 2021), https://www.law360.com/articles/1384971/9th-circ-says-epa-must-revisit-lead-related-standards.

[38] Id.

[39] Id.