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faces of older residential premises has proved to be a daunting task. In addition to sponsoring government programs that educate homeowners and parents of young children about the risks of lead-based paint hazards, government action to eliminate existing lead-based paint hazards addresses two separate issues. First, standards adopted either legislatively or by administrative agencies may impose requirements on the property owner to eliminate or at least substantially reduce the risk posed to a child by the presence of lead within the residential environment in which he lives. Second , legislation may determine which party bears the costs of implementing these measures. Should the costs be paid by the property owner, the former manufacturers of lead pigment or lead-based paint, the current manufacturers of paint (which, of course, does not contain lead), or the government? For the most part, the role of regulating housing containing lead-based paint and, thus, of preventing the harm caused in part by the presence of such paint has rested with states and municipalities.47 Federal statutes and regulations do require federally owned residential properties and housing paid for with federal housing assistance funds to comply with so-called interim control standards, as described in the following paragraphs.48 In addition , statutes and regulations enforced by the Environmental Protection Agency require safe work practices for contractors removing lead or otherwise working in residences containing lead-based paint.49 From a public health perspective, one of the critical decisions that must be made in deciding how best to eliminate or at least substantially reduce the incidence of children with elevated blood lead levels (EBLs) is the choice between requiring “total abatement” or mandating only interim controls. The federal government de‹nes “abatement” as the permanent elimination of lead-based paint or lead-based paint hazards.50 Abatement includes such measures as the removal of lead-based paint, the permanent enclosure or encapsulation of such paint, the replacement of windows or other ‹xtures painted with lead-based paint, and the removal or permanent covering of soil that has been contaminated with lead paint or leaded gasoline. In contrast, interim controls are measures designed to temporarily reduce the exposure of children to lead-based paint hazards.51 Examples include the removal of all chipping, peeling, or ›aking paint and repainting the surface and repairing problems, such as leaks, that may be causing paint to deteriorate. Several interim control standards address the creation of dust containing lead when “friction surfaces” rub against each other, such as when doors or windows that are improperly hung rub against their frames as they are opened. Interim control standards require that caps of Legislative Responses to the Public Health Problems 113 vinyl, aluminum, or a similar material be installed in window wells to make them smooth and cleanable and that windowsills be stripped and repainted or covered with vinyl. In addition, all ›oors must be smooth so that dust containing lead can be removed by routine cleaning. Relying on interim controls to eliminate the risks of childhood lead poisoning requires an ongoing maintenance program to assure that housing conditions do not deteriorate and once again pose health hazards. For this reason, from a public health perspective, total abatement would be preferred in a hypothetical world in which resources to address childhood lead poisoning were unlimited. In a world of limited resources, however, the cost differential between the two approaches probably tips the balance in favor of interim controls. A presidential task force in 2000 estimated that the mean cost of interim controls was one thousand dollars per unit and that the mean cost of abatement was nine thousand dollars per unit.52 On an aggregate nationwide basis, the Task Force reported that it would take $1.84 billion to implement interim controls and $16.6 billion for total abatement. Both sets of estimates are probably unrealistically conservative. Based on my own work with public health and housing of‹cials in several states between 2000 and 2008, I would estimate that while the costs of interim controls vary considerably depending on how poorly the residential property had been maintained, the average expenditure would probably considerably exceed one thousand dollars per unit (perhaps even coming to several times that amount), while total abatement costs would average somewhere between ‹fteen and twenty-‹ve thousand dollars per unit. Consistent with earlier studies, a recent study by the Battelle Institute and the National Center for Healthy Housing shows that interim controls are effective at controlling the risk...

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