Efficacy of the Community Reinvestment Act in promoting lead abatement.

Introduction

Lead exposure is one of the most important environmental health issues affecting children in the United States (Agency for Toxic Substances and Disease Registry [ATSDR], 1988). Although it has diminished in recent years, lead exposure remains a concern, especially in urban areas (Centers for Disease Control and Prevention [CDC], 1997). Lead exposure in children causes serious and persistent harmful effects, with severe exposures resulting in mental retardation, seizures, coma, and, in rare cases, death. Long-term studies have shown that in early childhood, even low-level lead exposure is associated with reductions in IQ, attention and behavior problems, learning problems, aggressive behavior, increased school absenteeism, delinquency, poor school performance, and increased dropout rates (Needleman et al., 1979; Needleman, Schell, Bellinger, Leviton, & Allred, 1990; Yule, Lansdown, Milar, & Urbanowitz, 1981). The neurological effects of lead exposure are thought to be irreversible (Needleman, 2004).

Lead exposure is also a key environmental-justice issue, disproportionately affecting minority and low-income communities. The primary source of lead exposure to children is lead-contaminated house dust, lead-based paint, and chips found mainly in the older, deteriorating housing conditions that are prevalent in inner-city, minority communities. Because of its devastating effects, lead exposure may contribute to the cycle of poverty in minority and low-income communities.

In response to the lead problem, most urban health departments have focused on inspection and abatement of homes of affected children. Home abatement has been reported to significantly reduce the blood lead levels of poisoned children (Amitai, Brown, Graef, & Cosgrove, 1991; Farfel, Chisolm, & Rhode, 1994; Staes, Matte, Copley, Flanders, & Binder, 1994). Unfortunately, in many cities abatement of homes is seldom completed in a timely and effective manner. For instance, the White Lung Association, a nonprofit group that trains workers for certification in lead abatement in northern New Jersey, estimates that only 10 percent of lead-poisoning cases are followed up by timely abatement of the home lead hazard. Anecdotal stories recount how, over a span of years, multiple children suffer lead poisoning from the same building or apartment without a proper abatement being done.

The barriers to getting homeowners to abate their properties are numerous, including lack of law enforcement, poor communication between homeowners and health departments, delays in the legal system, and plain reluctance by certain landlords. Funding for abatement is always a major issue. The Community Reinvestment Act (CRA), which is intended to encourage depository institutions to help meet the credit needs of the communities where they operate (CRA, 1977), in combination with other incentives for banks to make loans in the most affected neighborhoods, may help ameliorate this problem and encourage a portion of homeowners and landlords to abate lead hazards. The authors used CRA to facilitate the loan process for lead abatement in urban areas of New Jersey by working with banks and homeowners or landlords who were required to abate their properties. This paper reports on a study that analyzed the effectiveness of this financing intervention (CRA loans), as well as the effectiveness of abatements in reducing childhood lead exposure.

[FIGURE 1 OMITTED]

Methods

The study was conducted through collaboration between the University of Medicine and Dentistry of New Jersey (UMDNJ) and the Citizen Policy and Education Fund of New Jersey (CPEF), a nonprofit organization in the state. CPEF and its partner organization, New Jersey Citizen Action, worked and negotiated with local banks to ensure their compliance with CRA and to set up a below-market-rate loan (CRA loan) program for lead abatement. They also worked with municipalities, state agencies, and community groups to facilitate financing of lead abatement in the Newark/Irvington and other urban areas of New Jersey. Working closely with CPEF and the other parties, UMDNJ evaluated the efficacy of the resulting abatements with environmental sampling to determine the extent to which they reduced lead exposure. The study was conducted between October 1998 and September 2001.

Recruitment

CPEF first developed brochures and materials for attracting interested parties. One was designed to interest tenants in having their landlords involved, and the other was targeted toward homeowners and landlords directly. Brochures were distributed to eligible subjects through many recruiting approaches. Free public forums on the nature of lead abatement and financing were the primary method of attracting and informing people. These forums were conducted in cooperation with local health departments, churches of the community groups, or both. Local health departments assisted in sending invitations to these forums to owners of properties being cited for lead hazards. At each of the forums, city officials emphasized the need for compliance and answered questions regarding lead abatement. CPEF staff discussed homeowner responsibilities, while Summit Bank personnel explained what the CRA loan program provided. A total of seven forums were held throughout the span of the study.

In addition to the forums, CPEF used certified lead abatement contractors to refer property owners to the loan program. All certified contractors in the state were contacted, given a supply of the project brochures, and encouraged to hand the brochures to potential customers after estimating abatement costs. The third and final way was through lead inspectors of local health departments, who distributed the brochures to residents during their inspections of the homes.

Loan Counseling

Interested landlords or homeowners were instructed to call CPEF for further information on the loan program. During each phone conversation, information on the owner and property (e.g., name, address, phone number) was collected and then entered into a Microsoft Access[R] database, which was used for follow-up on the loan process. Additional details regarding the property and the lead-exposed child(ren) living in it also were recorded in a notebook as reference. CPEF staff not only explained about the loans, but also informed the caller of the requirement that abatement be performed by a certified contractor. The property owner was advised to call a designated contact at Summit Bank (now Fleet Bank), where CPEF had arranged for the discount loans for lead abatement. The purpose was to avoid having applicants walk into local Summit branches where the bank employees might not be aware of the lead loans.

Having informed interested subjects of the bank information, CPEF staff referred the research component to the property owner and asked for participation. If the response was positive, a referral sheet was filled out and sent to UMDNJ. When the field team at UMDNJ conducted its initial pre-abatement sampling, it was noted in the database.

Environmental Evaluation

After receiving referrals from CPEF, the UMDNJ field team contacted the subjects and scheduled appointments for baseline measurements of environmental-dust lead. At the baseline visit, the field staff first obtained consent and then collected dust wipe samples from several windowsills and floor surfaces. The sampling was conducted with the Lioy-Weisel-Wainman (LWW) wipe sampler and methodology (Lioy, Wainman, & Weisel, 1993).

One year after the baseline sampling, the UMDNJ staff contacted the subjects to schedule the second (follow-up) dust-sampling visits. The one-year period between baseline and follow-up samplings was intended to avoid seasonal variation in dust lead distribution (Yiin, Rhoads, & Lioy, 2000) and to allow abatement to be completed. Homes where abatements had not been initiated at follow-up were used as controls, as compared with abated homes. Follow-up samples were collected adjacent to the first sampling locations, which were sketched for identification at the first samplings, to be compared with the baseline levels.

Sample and Data Analysis

Samples were microwave-digested (MDS-2000, CEM Corporation, Matthews, NC) in 19 percent volume-per-volume (v/v) spectrograde nitric acid according to a protocol of the U.S. Environmental Protection Agency (U.S. EPA) (U.S. EPA, 1991) and were analyzed with a graphite-furnace atomic absorption spectrophotometer (Perkin Elmer, Norwalk, Connecticut) at the wavelength of 283.3 nanometers (nm). Other details of sample analysis have been described previously (Lioy, Yiin, Adgate, Weisel, & Rhoads, 1998). Lead loading (in [micro]g/[ft.sup.2]), which is the most commonly utilized measure of lead contamination, was derived for each wipe sample. To compare with the federal lead clearance standards, the authors standardized all LWW wipe results using a modification equation that was previously developed from a comparison of the LWW and the common wet-towelette methods (Rich et al., 1999). All data were log normally transformed prior to statistical analysis, because of the skewed distribution. A paired t-test was used to compare floor or windowsill sample data collected at the baseline and at the follow-up.

Results

CRA Loan Program

People who called to inquire about the CRA loans and were sufficiently interested to take the phone number of the bank were counted as subjects. There were 113 people who called to inquire about the loans, and over half of them completed loan applications (Figure 1). Of these 58 applicants, 18 were approved initially, and three applicants who were initially denied were later approved. All of these 21 loan recipients completed lead abatement in the properties. Of the 37 people whose loan applications were denied, 18 found other resources with which to complete the abatements (48.6 percent). Among those who decided not to apply, the abatement completion rate was lower (38.2 percent) than among those who did (67.2 percent). Overall, 54 (48 percent) of the 113 subjects completed lead abatements.

Environmental Evaluation

A total of 36 homes were assessed for baseline dust lead levels, and the sampling team was able to return to 19 of them for follow-up sampling. The major reason that there was no follow-up sampling in the other 17 homes was that the participants declined or withdrew from the study. Of the 19 homes for which baseline and follow-up sample collections were completed, five homes had not finished lead abatement before the follow-up visits. These homes served as controls that were compared with the 14 abated homes. The descriptive statistics for all LWW wipe sample data collected at baseline are given in Table 1. Geometric mean lead loading on floor surfaces and mean lead loading on windowsills were both higher than the latest lead dust clearance standards (floor: 40 [micro]g/[ft.sup.2], windowsill: 250 [micro]g/[ft.sup.2]) (Lead-Based Paint Poisoning Prevention in Certain Residential Structures Rule, 2002), indicating that these houses were contaminated with lead dust.

Among the 14 abated homes that were available for baseline and follow-up sampling, four were financed through the CRA loan program. The other 10 homes were abated with other funding. For the 14 abated homes, floor data did not show any significant difference between the baseline and follow-up visits, whereas the mean lead loading on windowsills was reduced by 58.4 percent (p < .001) (Table 2). For the five unabated homes (controls), the mean floor lead loading was significantly higher at follow-up than at baseline (p = .028). Although the mean windowsill lead loading was decreased even without any abatement work, the decrease was not statistically significant (p = .191).

Discussion

Of 113 landlords and homeowners who were referred to the program, 59 (52 percent) completed lead abatement. This proportion substantially exceeds the 10 percent estimate provided by the White Lung Association as well as the experience of one of the authors with subjects enrolled in a randomized trial of chelation (Rogan et al., 2001). The relatively high proportion of abatements seen here probably reflects some self-selection (i.e., participants with a strong desire to resolve the lead problems), but the fact that more than half of the individuals applied for the lead loans and that more than one-third of abatements were financed with this mechanism suggests a substantial impact from the CRA loan intervention.

CRA Loan Program

Despite this overall success, a number of factors limited the utility of the CRA Loan Program for lead abatement. Almost half of the people who inquired about the loan did not take the next step to apply (48 percent). Owners with good credit ratings may not have found the rate of 1 percent below market interest rate very attractive. For instance, some of those who received loan approvals decided to use other financing methods. Others may have known that their credit ratings would not sustain such loans. Those without good credit, unfortunately, found that the options were severely limited. One of those homeowners sold the furniture to pay for the lead abatement.

In some instances, homeowners with little or no ability to pay for abatement worked closely with municipal officials to get the work completed. The law in New Jersey allows homeowners in owner-occupied units to do their own abatement, although it is not encouraged. In this situation, lead inspectors/risk assessors worked with the homeowners and instructed them in exactly what to do step by step in a lead-safe manner (e.g., wearing protection clothes, using appropriate tools to reduce lead dust generation). This practice seemed to work best in towns that were large enough to have frequent lead exposure cases, but small enough to give attention to the homeowners individually.

Of the 58 applicants, 40 initially were denied; of those, three were later approved. The main reason that loans were denied was a poor credit rating resulting from a late mortgage payment within the last 12 months. These denied applicants were offered CPEF's free credit-counseling service to improve their credit ratings. The simplest approach was to make 12 on-time payments, but some of them may have been pressured by the local government officials to finish abatement before making 12 on-time monthly payments. Of the 11 owners who enrolled in the credit-counseling service, it is worth noting that one went on to get the loan and complete abatement in the project period.

CPEF's Other Efforts and Assistance

Because of the difficulties identified above, CPEF staff made other efforts to assist homeowners with lead abatement, as outlined below.

1. Grant Assistance

CPEF staff negotiated once with the officials of the township of Irvington, which was awarded a grant, titled the Community Development Block Grant, from the U.S. Department of Housing and Urban Development (HUD), to provide monetary assistance with the loans. The township utilized a portion of the grant, in compliance with the HUD rules of grant use, to supplement the loans. This combination of loans and grants proved successful in Irvington and has been used as a model in other areas. The New Jersey Legislature recently has passed a law to assist homeowners and landlords with the cost of lead abatement, based on the success of the combination of loans and grants for lead abatement.

The study reported here exposed the fact that there was very little financial aid or government money available to help with lead abatement. CPEF consistently reported on the progress of the lead loan program at the New Jersey Interagency Task Force on Lead. After years of no public money being available to helping with lead abatement, the New Jersey Department of Community Affairs has begun a pilot program in Irvington, East Orange, and Paterson. This program aims to give homeowners the money needed to complete lead abatement. In recent years, HUD has offered more funding (i.e., Healthy Homes Initiatives) to state and local governments for reducing household lead hazards. The state of New Jersey and other local governments (e.g., Hudson County, City of Newark) have benefited from the HUD funding.

2. Other Educational Efforts

As a result of the public forums, CPEF staff found that very few landlords were aware of the Real Estate Disclosure Rule. CPEF staff explained the rule to every person who called for loan inquiry and sent a free package in the mail with the proper disclosure forms and brochures in English and Spanish in photocopyable form. The communication and rapport established between CPEF staff and homeowners/landlords was very much appreciated by the property owners. For many it was the first time the laws and regulations affecting them were explained. It became apparent that occasional phone calls to check the status of abatement, made by CPEF staff, were very helpful to the property owners. The phone calls presented them with an opportunity to ask questions and obtain advice at a time when information was critical. The authors suggest that every lead abatement job should be case-managed until completed, just as a lead-poisoned child is case-managed until the blood lead level is lowered.

CPEF also reached out to loan applicants who were denied to advise them of a HUD-approved one-day lead course, which permitted homeowners to perform lead-safe work practices in their own properties in accordance with New Jersey law. The course gave homeowners flexibility in dealing with the lead problems.

Environmental Evaluation of Abatement

The dust-sampling results confirmed that these home environments were contaminated with lead, showing that accessible dust lead on the floor surfaces and windowsills was higher than the new lead clearance standards (floor: 40 [micro]g/[ft.sup.2], windowsill: 250 [micro]g/[ft.sup.2]) (Table 1). All of the abatements conducted in the 14 abated homes appeared to be beneficial in removing substantial amounts of lead paint. Dust lead levels went down substantially on the windowsills (p < .001) (Table 2), probably reflecting window replacements in some of the homes. For the five unabated homes, the mean windowsill lead loading was also decreased one year later, but the decrease was not significant (p = .191), and the follow-up lead loading was still higher than the lead clearance standard. The windowsill results for abated and unabated homes indicate the effectiveness of lead abatement in reducing lead dust on windows.

On the other hand, floor lead loading was not decreased but increased in both abated and unabated homes, indicating that lead abatement was not effective in floor lead reduction. This result may have been a reason that lead abatement in New Jersey had limited efficacy in childhood blood lead reduction, according to a retrospective analysis of lead abatement using the state data (Rich, Rhoads, Wartenberg, & Sweatlock, 2001). Floor lead loading was found to be the measure most closely associated with childhood blood lead levels in a previous lead study conducted in New Jersey (Yiin et. al., 2000), and the same study showed that approximately 50 percent of lead on floor surfaces was from outdoor sources and lead-based paint accounted for only 33 percent (Adgate et al., 1998). Thus, it is likely that lead abatement in New Jersey was able to reduce a portion of lead dust from lead paint but not contamination from other sources on the floor surfaces, which were the most accessible to young children.

In summary, lead abatement was proven to be successful in removing large amounts of lead-based paint from the residential environment, especially in old and deteriorated housing units. It could not, however, resolve all aspects of childhood lead exposure, because outdoor sources of lead, usually being tracked in and left on floor surfaces, were beyond the control of lead abatement. To better control childhood lead exposure and poisoning, at least in New Jersey homes, environmental intervention (e.g., interim dust control), which has been confirmed effective when applied frequently (Lioy et al., 1998; Rhoads et al., 1999), is needed before and even after the completion of lead abatement.

Conclusions

The cost of lead abatement is the main barrier to removing lead hazards from housing. This project demonstrates and concludes the following:

* The one-on-one counseling and follow-up that the CRA loan program provided were very helpful in persuading homeowners to proceed with and complete needed abatements.

* Reduced-interest-rate financing was utilized by a minority of those ordered to do lead abatement.

Lead abatement, which targeted lead paint removal, significantly reduced lead loading on windowsills, but not on floor surfaces.

TABLE 1 Baseline Lead Levels of LWW Wipe Samples on Floors and
Windowsills in All Homes

                             Pb Loading ([micro]g/[ft.sup.2])
Location         N           GM (a)                 95% CI (b)

Floor            82           70.7                  (54.6, 91.8)
Windowsill       90          412                   (337, 505)

(a) GM = geometric mean.
(b) CI = confidence interval.

TABLE 2 Lead Levels of Homes with Both Baseline and Post-abatement
Sampling

                               Number     Sampled      Baseline
                              of Samples   Homes    GM (a) (GSD (b))

Homes with abatement done
Floor Pb loading                25         12 (c)        58.1
  ([micro]g/[ft.sup.2])                                  (4.6)
Windowsill Pb Loading           37         13 (d)       389
  ([micro]g/[ft.sup.2])                                  (2.8)

Homes without abatement done
Floor Pb loading                17          5            68.2
  ([micro]g/[ft.sup.2])                                  (2.3)
Windowsill Pb loading           12          5           511
  ([micro]g/[ft.sup.2])                                  (3.0)

                                 Follow-up GM (a)     Paired
                                    (GSD (b))        t-Test p

Homes with abatement done
Floor Pb loading                     64.7              .718
  ([micro]g/[ft.sup.2])              (2.0)
Windowsill Pb Loading               162               <.001
  ([micro]g/[ft.sup.2])              (2.7)

Homes without abatement done
Floor Pb loading                    111                .028
  ([micro]g/[ft.sup.2])              (2.0)
Windowsill Pb loading               311                .191
  ([micro]g/[ft.sup.2])              (2.3)

(a) GM = geometric mean.
(b) GSD = geometric standard deviation.
(c) Two houses without floor sampling.
(d) One house without windowsill sampling.

Acknowledgements: The study was funded by a grant agreement (H42/CCH216210) with the Centers for Disease Control and Prevention, and by a National Institute of Environmental Health Sciences Center grant (ES-05022). Views expressed in this article are those of the authors and do not necessarily reflect the views of the funding agencies or the institutions with which the authors are affiliated.

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Lih-Ming Yiin, Ph.D.

John Weber

Sulaiman Sannoh, M.D., M.P.H.

George Rhoads, M.D., M.P.H.

Corresponding Author: Lih-Ming Yiin, Associate Professor, Department of Public Health, Tzu Chi University, 701 Chung Yang Rd., Sec. 3, Hualien, Taiwan, 970 R.O.C. E-mail: [e-mail].