Support urgent amendments to the U.S. HUD lead poisoning regulations.
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Support urgent amendments to the U.S. HUD lead poisoning regulations.
Every step of the way, from failing to identify lead hazards to using outdated standards for testing to inaction once a child is lead poisoned Department of Housing and Urban Development (HUD) lead poisoning regulations undermine the safety of families. Insufficient inspection methods, outdated regulatory policies, and poorly implemented support systems are the hallmark of HUD’s current system of lead poisoning prevention in the homes it funds with taxpayer dollars.
And when federal agencies forego responsibility, so too do state- and local Public Housing Authorities (PHAs). The majority of PHAs do not offer assistance or options that properly address lead exposure until a child’s lead level has reached crippling levels.
Lead poisoning disproportionately impacts communities of color, leaving them increasingly vulnerable to housing instability and health risks. We cannot ignore the health and safety of these families.
Flint has demonstrated the ramifications of allowing legislative inertia and fiscal austerity to outweigh proactive, pragmatic, and principled policy. Changes to the status quo must go beyond restoring funding for essential lead poisoning prevention programs, and ensure that proper standards are implemented. Amending the lead-poisoning prevention regulations will empower HUD to fulfill it’s mission, protect American families from the devastating consequences of lead poisoning, and provide support for those already afflicted.
Here's the letter we'll send to HUD Secretary Julian Castro, along with the official amendment petition and related research basis:
February 11, 2016
Julian Castro, Secretary
Department of Housing and Urban Development
451 Seventh Street, S.W.
Washington, DC 20410-0001
RE: Petition for Rulemaking Under U.S. Department of Housing and Urban Development “Lead Based Paint Poisoning Prevention in Certain Residential Structures” Regulations to Prevent Lead Poisoning Among Program Participant Children
Dear Secretary Castro,
Under your stewardship, the U.S. Department of Housing and Urban Development (“HUD”) has been a leader in the effort to eliminate lead poisoning in housing. The Office of Lead Hazard Control and Healthy Homes (“OLHCHH”) provides funds to states and local governments to reduce lead-based paint hazards. In addition it enforces HUD’s lead-based paint regulations. However, HUD’s and OLHCHH’s efforts to protect children from lead poisoning and its deleterious effects are thwarted by regulations that are outdated and in contravention to prevailing science and the standards set by the Centers for Disease Control and Prevention (“CDC”). In the wake of a major public health crisis caused by persistent lead hazards, the undersigned call upon HUD to set the standard in protecting children and their families from lead hazards in the home.
According to the CDC and lead researchers, there is no safe level of lead poisoning. Even at blood lead levels as low as 1 µg/dL, there is a negative and permanent effect on IQ. Lead poisoning has extreme negative health effects for children, leading to academic failure, juvenile delinquency, high blood pressure, brain damage, learning disabilities, behavioral problems, heart disease, diabetes, developmental delay, and even death. It ensures that a child will never reach his or her fullest potential.
To protect our children and their futures, we submit the enclosed petition for rulemaking to amend the “Lead Based Paint Poisoning Prevention in Certain Residential Structures” regulations, 24 C.F.R. § 35 et. seq. In furtherance of HUD’s duty to protect children participating in federally assisted housing, we implore you to adopt the proposed amendments in order to prevent lead poisoning among participants in federally assisted housing.
We the undersigned support the petition for rulemaking filed by a coalition of scientists, medical providers, public health experts, law school clinics, and civil legal aid groups urging amendments to the “Lead Based Paint Poisoning Prevention in Certain Residential Structures.” We urge the U.S. Department of Housing and Urban Development (HUD) to take swift action and adopt the requested amendments.