Get the Lead Out

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Courtesy of Bergeson & Campbell, P.C.

EPA rethinks air quality standards, seeks comments.  By any independent standard, the federal government has made significant progress in reducing lead concentrations in ambient air. Average lead concentrations have dropped 96% since the 1980s, primarily due to the ban on lead in motor vehicle gasoline. Since the late 1970s, bloodlead concentrations for children ages 1 to 5 have decreased dramatically, from about 15 micrograms per deciliter (μg/dL) to less than 2 μg/dL. The success has been so dramatic, then U.S. Environmental Protection Agency (EPA) is now considering whether to maintain, revise, or eliminate current lead National Ambient Air Quality Standards (NAAQS). EPA, in late December, issued an advance notice of proposed rulemaking (ANPR) and invited comment on all issues. This is the chemical industry’s opportunity to provide input.

How revisions are made

Two sections of the Clean Air Act (CAA) govern establishment and revision of the NAAQS. Section 108 directs EPA to identify and list air pollutants and periodically revise the list. CAA Section 109 directs EPA to propose and promulgate “primary” and “secondary” NAAQS for pollutants listed under Section 108.

EPA, in 1978, issued the primary and secondary NAAQS for lead under CAA Section 109. Both standards were set at 1.5 micrograms per cubic meter (μg/m3), measured as lead in total suspended particulate matter, not to be exceeded by the maximum arithmetic mean concentration averaged over a calendar quarter. A review of the standards was initiated in the mid-1980s. EPA didn’t propose any revisions to the 1978 lead NAAQS.

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