An Analysis of the EPA's Proposed Lead Hazard Standards For Homes

Abstract

Exposure to lead in homes poses such large risks to children's health that reducing it is a major public health priority. To limit these risks, the Environmental Protection Agency (EPA) recently proposed national standards to identify hazardous levels of lead dust and lead in soil, as well as hazardous conditions for lead-based paint. Meeting those standards would require controls that would cost an average of thousands of dollars per home in 21 million homes where lead-based paint is present, according to the EPA. Although the EPA believes its proposed standards reflect an appropriate balancing of benefits and costs, a proper assessment of its proposal suggests otherwise. Each of the EPA's proposed standards for paint, soil and dust would result in measures to control lead that have costs in excess of benefits. Together those costs, less the associated benefits, are likely to exceed $20 billion. Estimates of net costs would be still greater if based on an analysis that corrects remaining deficiencies in the EPA's work. The EPA's proposal would likely increase unnecessarily the premature abandonment of housing in instances where control costs are large relative to the market value of homes. Such abandonment is especially undesirable because it will occur mostly in low-income neighborhoods of older homes. Standards with lower costs would result in less abandonment. The EPA's media-specific, national standards would have other undesirable consequences. Perversely, about half of all the homes that do not meet the standards have risks of elevated blood-lead less than at other homes in full compliance with the standards. In addition, all homes built before 1978 would be subject to the same national standards, although exposure, risk and the cost of controls vary substantially among different households. As a consequence, the EPA's standards would result in controls in homes of more than one million middle-income families whose children face risks lower than the risks for children of poor families living in homes that meet the standards. Controls to reduce low risks are not likely to be cost-effective and are unfair to families facing lower risks who would bear the brunt of the control costs. The EPA can set standards that would offer greater net benefits and avoid controls in lower-risk homes. To provide greater net benefits, the EPA should set less stringent standards based on a more careful reappraisal of the benefits and costs of controlling residential lead hazards. To avoid control measures in lower-risk homes, the EPA should set standards based on lead levels in all media and establish a range of lead levels where recommendations to control lead depend on risk factors specific to individual homes