The Center for American Progress submitted a comment letter to the U.S. Environmental Protection Agency in response to the agency’s proposed lower lead dust hazard standards and clearance levels for child-occupied homes and child care facilities.
Jill Rosenthal, Hailey Gibbs, and Allie Schneider (October 4, 2023)
On October 2, 2023, the Center for American Progress submitted a comment letter to the U.S. Environmental Protection Agency (EPA) in response to the agency’s proposed lower limits on lead dust hazard standards and clearance levels in child-occupied facilities. CAP commends the EPA’s recognition that any level of lead exposure during early childhood is harmful for health and development, and expresses support for the proposed lower lead dust levels as part of broader efforts to reduce early childhood exposure to environmental toxins. However, CAP urges the EPA to consider several factors to improve the implementation and clarity of the final rule, including the provision of clear education, information, and support to property owners; explicit centering of racial justice; and proactive testing to reduce lead dust hazards before children experience the adverse effects of exposure. CAP also highlights the rule’s potential economic impact on child care providers and owners of child care facilities who operate on very slim profit margins—emphasizing the need for funding to support the lead abatement activities mandated by the rule.