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[ZERI_Practitioners] Lead in gardening equipment

To: <ZERI_Practitioners@yahoogroups.com>
From: "bregenerative" <bregenerative@gmail.com>
Date: Tue, 22 Aug 2006 14:37:53 -0400
Subject: [ZERI_Practitioners] Re: Fwd: Lead in gardening equipment

Garden fixtures labeled with warnings such as those mentioned by Kathey Ferland, are likely to claim that they are not intended to convey water for human consumption, so that they can use the legal exception (loophole) that applies to any process where the water conveyed by a plumbing or distribution system is not used directly or indirectly for human consumption.  ?But who hasn?t taken a drink from a garden hose? ?and you and I could make a case for indirect consumption via food web, 5K transport?
The legal (US Safe Drinking Water Act) and misleading definition of "lead free" means that solders and flux may not contain more than 0.2 percent lead, and pipes, pipe fittings, and well pumps may not contain more than 8.0 percent lead.   However, significant lead can still leach into water with these ?lead free? water delivery systems. A Safe Drinking Water Act amendment has incorporated a voluntary performance standard that further limits the amount of lead leaching from public water system conveyance and plumbing fittings and fixtures intended to dispense water for human consumption. 
Refer to the link http://sfwater.org/detail.cfm/MC_ID/13/MSC_ID/166/MTO_ID/400/C_ID/303 for a pretty good overview of sources of lead in drinking water.
Standard recommendations for domestic water use:  Drink and cook with domestic water obtained from the cold tap after allowing the water run for at least 15 seconds to avoid consuming the static water with lead buildup.  Not great for water conservation, but better for your brain. 
Lead content in static water samples (water that has been sitting in the building plumbing, exposed to lead solder at pipe joints and lead in fixtures) are usually higher than dynamic water samples (collected after running the faucet long enough to flush the system).  In some cases, elevated lead concentrations in dynamic water samples are the result of leaching from debris caught in the faucet screens.  Laboratory results for water samples are given in milligrams lead per liter of water (mg/L), and are compared to the U.S. EPA?s action level for lead in drinking water of 15 micrograms lead per liter of water. 
The sale of paints containing greater than 600 ppm of lead to consumers was banned by the Consumer Products Safety Commission (CPSC) in 1978.  However, Lead-Based Paint (LBP) and primers are still applied to industrial equipment and building components such as structural steel (beams, columns, joists) that may be coated as part of the fabrication process, and not subject to the CPSC ban. 
Laboratory results for paint chip samples are given in percent lead by weight and are compared to the 0.5% threshold value established by the Housing and Urban Development (HUD) guidelines and the Environmental Protection Agency (EPA) Title X action level of 0.5 percent by weight (or 1.0 mg/cm2).
OSHA regulations relating to lead-containing paint include the OSHA Construction Standard for Occupational Exposure to Lead (29 CFR 1926.62), as well as several other hazard communication and worker protection standards.  OSHA requirements to prevent occupational exposure to lead apply regardless of percentage lead content.  The State of Georgia regulates lead-based paint activities when they relate to target housing or child-occupied facilities constructed before 1978.   Additional federal and state regulations control the packaging, labeling, transportation, and disposal of lead waste, when it is determined to be a hazardous waste.
After LBP abatement in regulated, child-occupied facilities, dust lead clearance standards have been lowered to 40 (ug/sq.ft. on floors and 250 (ug/sq.ft. on window sills pending issuance of EPA's final Section 403 standards).  Don?t you enjoy that combination of British and metric units?  OK, I?m easily amused.

(Since 1999) Home sellers and landlords who renovate or disturb painted surfaces on any house built before 1978, are required by the Environmental Protection Agency (EPA) to distribute the pamphlet, "Protect Your Family From Lead in Your Home" to residents before starting certain renovation projects. In addition to providing the pamphlet to residents, property owners must obtain written acknowledgment that is has been received.  You can download this pamphlet in six languages at    http://www.epa.gov/NE/enforcement/leadpaint/index.html
Other common lead hazards include: soils ? (historic lead accumulation from leaded gasoline exhaust), yellow dye used in some plastics, lead water pipes, solder, brass fixtures, leaded-glass, vinyl mini-blinds (the lead chalks out ? is not trapped by the vinyl matrix), candle wicks (the lead gets vaporized and easily absorbed, also settles as fine dust), pottery (if it gets hot in the microwave ? it likely has Pb or other metal in the glaze).
Less common, but serious sources include cheap jewelry.  A recent fatality from a Reebok tennis shoe charm: 
 Other jewelry consumption: http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5323a5.htm
Other links
CDC http://www.cdc.gov/lead/
HUD    http://www.hud.gov/offices/lead/
EPA     http://www.epa.gov/lead/
OSHA  http://www.osha.gov/SLTC/lead/index.html
?and of course you can google for your state environmental programs, that may have more strict requirements (especially Mass.).
Note: In my former life I was certified lead inspector, risk assessor, and abatement designer.  I have allowed those certifications to lapse, so it is possible that there are more recent regulatory changes.  So, please take this informal discussion as a general guide, and check current regs if needed.
Brenda Ames



Gary Liss       
Fax: 916-652-0485