The creativity of our government regulators never ceases to amaze me. I’ve seen a lot of incredibly stupid and callous decisions in my time, but this one is right up at the top. The US environmental Protection Agency (EPA) Region 10 and the Idaho Department of Environmental Quality somehow thought it was a good idea to use Blood Lead Levels in children to establish a remedial action objective (RAO) at the Bunker Hill Superfund site in Kellogg, ID. According to a recent peer reviewed paper published in the American Journal of Public Health, this decision is codified in EPA’s 1991 Record of Decision for the Bunker Hill site (1).
According to the authors, “the 1991 ROD for the Bunker Hill mine defined the EPA RAOs for child blood lead levels and stipulated the following criteria measures: (1) less than 5% of tested children should have blood lead levels greater than 10 micrograms per deciliter and (2) less than 1% of tested children should have blood lead levels greater than 15 micrograms per deciliter.” You got that. As long as no more than 5% of the children in Kellogg have blood lead levels greater than 10 micrograms per deciliter (ug/dl) and no more than 1% had levels great than 15 ug/dl, then the site cleanup efforts could be considered “successful” (1).
What was EPA thinking when they decided to use lead levels in children to define the effectiveness of a cleanup? And then, to accept that some children will have blood lead levels that exceed the recommended criteria is unconscionable. Even if this factor was not the sole criterion used to make decisions about the effectiveness of the cleanup, it is still unethical to use the children of Kellogg in this way.
The adverse health outcomes of exposure to lead are well understood. Earlier this year the Centers for Disease Control (CDC) revised its guidelines for lead lowering the blood lead level for protecting children’s health from 10 to 5 ug/dl. At the time CDC’s Advisory Committee for Childhood Lead Poisoning Prevention whose recommendations led to this change made it clear that no safe blood lead level in children has been identified.
Lead was mined at the Bunker Hill site for more than 100 years and at one time this was the home of the largest lead smelter in the United States. When the mine shut down in 1981, it left behind a toxic legacy of huge waste piles and residual contamination everywhere. Blood lead testing in children as earlier as 1976 found that 99% of Kellogg children living within 1 mile of the smelter who were tested had blood lead levels greater than 40 ug/dl (2). Today it is much less clear what the blood lead levels are because so few children are tested.
It is an injustice for EPA to treat the residents of Kellogg in this way. The residents In Kellogg have suffered disproportionately not only from lead exposure which continues to this day, but also from social disparities that include unemployment, poverty, and limited educational opportunity. Although there has been substantial cleanup at the site, it remains unclear whether there has been a corresponding improvement in community health and wellbeing. So much more needs to be done. This of course will never be achieved in communities like Kellogg, so long as decision makers think there’s nothing wrong with using the children as canaries in the mine fields.
1. Moodie, SM and Evans, EL. Ethical Issues in Using Children’s Blood Lead levels as a Remedial Action Objective. American J Public Health 2011 101(S1): S156-S160.
2. Landrigan PJ, Baker EL Jr, Feldman RG, et al. Increased lead absorption with anemia and slowed nerve conduction in children near a lead smelter. J Pediatrics 1976 89(6):904-910.