Revisiting a Proposed Ban on Lead in Products
TO THE EDITOR: In the exchange of letters “Should AIHA Support a Ban on Any Hazardous Material?” published in the November 2016 Synergist, we feel that the AIHA Board mischaracterizes the position statement that it was asked to endorse. The request to the Board was to sign on to a “Call for Action for Global Control of Lead Exposure to Eliminate Lead Poisoning” published by the International Society for Environmental Epidemiology (ISEE) and published in the journal Epidemiology.
While the letter from the Board acknowledges that, according to the hierarchy of industrial hygiene controls, elimination is the best way to ensure that workers are protected from a specific hazard, it then goes on to reject this approach. The AIHA Board mischaracterizes the ISEE statement by describing it as a request to “ban a substance.” Rather the statement calls for a ban on the use of lead in specific products, namely paint, fuel, plumbing fixtures, and plastics.
It should be noted that the ISEE statement calls on “the governments of all nations” to take a range of actions to prevent lead poisoning among children and not just in occupational settings. In addition to calling for restrictions on the manufacture, import, and export of specific lead-containing products, it also contains at least 13 additional recommendations that are backed by a detailed review of the issues with 57 references.
In regards to the recommendation regarding specific lead-containing products, the ISEE statement is simply asking other governments to do what the U.S. Congress has, for the most part, already done in the 1970s and '80s. In the U.S. lead is banned in residential paint and most fuels (with exceptions for single-engine aircraft). Lead in plumbing fixtures (including plastic pipe) is banned by federal law (S3874) and lead in plastic toys is regulated by the Consumer Product Safety Commission. In 2009, a resolution by the U.N. International Conference on Chemicals Management that called for the elimination of lead paint was unanimously endorsed by over 120 countries.
Although a range of opinions on most issues can be found among AIHA members, the Board acknowledges that “most AIHA members would undoubtedly recommend substitution of a less hazardous substance.” Such substitutes are available for virtually all of the specific lead-containing products mentioned in the ISEE statement.
The AIHA Board position fails to recognize the important role that the U.S. and U.N. play in providing models and guiding environmental and occupational regulations in countries around the world. It also appears to stake a position against decades of Congressional action in the U.S.
In most low- and middle-income countries there is a lack of industrial hygiene expertise and resources to apply the “hierarchy of controls” even in the workplace. The idea that the application of industrial hygiene principles is going to avoid environmental contamination from lead paint on a bridge or prevent childhood lead poisoning from plumbing fixtures is pure fiction.
We cannot rely on consumer pressure in the global marketplace as suggested by the AIHA Board because there are no labels on products (including lead paint) indicating the lead content in most countries. The only practical approach to prevent global lead poisoning is to place the same or even tighter restrictions on the use of lead as we already have in the U.S.
Lead poisoning is a pervasive global health challenge that has been recognized for literally thousands of years, and continues to impact millions of lives. The knowledge and technology to substantially reduce this problem already exist. AIHA should be in the forefront of global efforts to address this problem. Frank S. Rosenthal, Bruce P. Lanphear, and Perry Gottesfeld Note: Frank S. Rosenthal, Bruce P. Lanphear, and Perry Gottesfeld were the principal authors of the ISEE statement.
Emphasizing use of the best control method to reduce or eliminate potential exposure can be applied universally.
The opinions expressed in letters to the editor are those of the authors and do not necessarily reflect the views of AIHA® or The Synergist®. Letters are published at the discretion of the editor and may be edited for clarity. Send letters to the Synergist editorial staff.

the Synergist
THE AIHA BOARD RESPONDS: At its January 2017 meeting, the Board at the request of the Social Concerns Committee reviewed again the ISEE Call for Action supporting “global control of lead exposure to eliminate lead poisoning.” This issue had been reviewed and deliberated by the AIHA Board in January 2016 with a position published in the November 2016 Synergist.
At its most recent meeting, the Board maintained the same position taken in 2016, which is not to endorse the ISEE Call for Action for governments to ban the manufacture, import, and export of lead-containing fuels, paints, plumbing fixtures, and plastics. Calling for a ban on lead or any other hazardous substance bears careful consideration beyond the health and safety hazards. There are industrial, economic, environmental, political, and social considerations that government agencies need to weigh when making these decisions. As an association, we do not have the bandwidth to fully examine these other issues. Supporting a government ban on specific applications of a particular substance can potentially place the association and our membership into conflicts of interest (given the wide membership diversity among government, private sector, research and academia). Furthermore, it can lead to unintended consequences when developing future positions on draft legislation or consensus guidance documents.
The AIHA Board, however, does support the other various provisions stated in the letter, encouraging governments and other organizations to:
  • promote replacement of lead-containing fuels, paints, plumbing fixtures, plastics, and other commercially available products
  • vigorously explore replacements for lead content, wherever possible in other consumer and commercial products
  • implement, to the greatest extent feasible, effective procedures to reduce occupational exposure to lead and its compounds, especially in mining, manufacturing, and construction
  • implement, to the greatest extent feasible, effective procedures to reduce emissions from smelters and lead battery manufacturing and recycling facilities
  • implement regulations for safely recycling used batteries containing lead and for preventing the illegal dumping of lead-containing materials and products
  • implement, to the greatest extent feasible, programs to identify and remediate lead contaminated public and residential areas, and surveillance programs to identify heavily exposed individuals, populations, new sources of lead exposure, and trends in lead exposure
  • investigate and reduce lead exposures from contamination of food and from hazardous waste sites
  • increase the training of health professionals in the identification and prevention of lead poisoning
In addition, the AIHA Board supports the ISEE call for:
  1. the governments of countries with high quality blood analytical capacity to provide assistance (expertise, material, resources and training) to other countries in developing this capacity
  2. the elimination of lead poisoning to be included in the United Nations Sustainable Development Goals, with indicators and targets set accordingly
  3. professional organizations to support the efforts of international organizations working for lead poisoning prevention
AIHA is a membership-based professional association with a mission to protect worker and community health using knowledge based on strong scientific principles. Emphasizing use of the best control method to reduce or eliminate potential exposure can be applied universally. AIHA can communicate with ISEE of our support to these various provisions, other than the call for a government ban, and provide our technical expertise if requested.

the Synergist