A Very Stupid Idea
Sometimes an idea comes along that is so stupid that it is hard not to think that it is a parody in the Onion instead of a straight news report in the Los Angeles Times (link via Cookie Jill at skippy’s):
The Environmental Protection Agency has quietly delayed work on completing required rules to protect children and construction workers from exposure to lead-based paint, exploring instead the possibility of using voluntary standards to govern building renovations and remodeling.
Is it possible to come with a worse public policy than that? It is not like EPA does not know the risk of lead poisoning. In 2003, the New England Journal of Medicine ran a study suggesting that even low-levels lead exposure is harmful to the brains of children. The conclusion of that study, taken from the abstract, is:
Blood lead concentrations, even those below 10 µg per deciliter, are inversely associated with children's IQ scores at three and five years of age, and associated declines in IQ are greater at these concentrations than at higher concentrations. These findings suggest that more U.S. children may be adversely affected by environmental lead than previously estimated.
In fact, as Kevin Drum, among others, pointed out at the time:
The researchers found that levels as low as 1 m/d cause most of the IQ drop, and that 10% of all children in the U.S. have levels above 5 m/d. There are about 60 million children in the United States today, so if these findings are correct it means that correcting this problem has the potential to result in an increase of 7.4 IQ points in over 6 million kids.
Why would the EPA consider weakening the protections against lead poisoning? They are worried about the cost of the mandatory regulation to business, of course.
EPA officials emphasize that they are concerned about lead exposure and its effect on children. They also point to an internal study showing that the cost of the regulations — $1.7 billion to $3.1 billion annually — could be an overwhelming burden for the mostly small businesses that renovate buildings. However, an agency estimate showed that such rules would provide health benefits of greater value, from $2.7 billion to $4.2 billion annually.
In other words, we can save money by having mandatory standards and we can save children by having mandatory standards, but the administration is balking at doing so because mandatory standards cost contractors some money. Please note that the voluntary standards are just as expensive for any contractor who abides by them. The only purpose in making the standards voluntary is to permit some workers and some kids to continue to be exposed to a known neurotoxin.
Is it really too difficult to find a way to take some of the $2.7 billion to $4.2 billion in savings and use it to ameliorate the burden on the smallest contractors?
I wonder what the EPA counted as a benefit when it arrived at those figures. The article says “health benefits” but there are many other economic benefits from preventing brain damage in 10% of our kids. Did the EPA consider the additional special ed costs associated with lead poisoning? Did it consider the lifetime loss of productivity associated with a loss of IQ? I spent a couple of hours today at an IEP meeting about my autistic son. Did the EPA count that sort of lost productivity?
I suspect that the total of all economic benefits of eliminating lead from our housing stock before another generation of kids suffers brain damage exceed the cost of the mandatory regulations by at least an order of magnitude.
Some of the costs of brain damaged children are not easily susceptible to cost/benefit calculations. The three of us here at Wampum know all too well how difficult it is to quantify those costs. Eric and MB, and their entire family, pay the full price of having a lead-poisoned child each and every day. No scale exists on which it is possible to place the neurological health of our kids on one side, money on the other side, and reach a balance.
The non-economic benefits of preventing brain damage in 10% of our kids are beyond calculation. The Environmental Protection Agency should be looking for ways to prevent children from being poisoned, not looking for ways to allow contractors and landlords to leave the poison around to harm another generation of kids.
By all means, find the money to help the contractors comply with mandatory regulations with minimal economic harm but, please, do not make protecting our kid’s from brain damage a voluntary activity that can be dispensed whenever it is inconvenient.
Comments
Sorry. Can't read your whole post. I get too damned mad at this insanity. It is so stupid, so very very stupid.
BTW, for FY 2005 Bush proposed large cuts in the tiny federal programs which EPA and HUD use to promote lead abatement in housing. I'm not sure what ended up passing, or what is proposed for 06.
Damn those ideologues.
Posted by: BoulderDuck | May 12, 2005 01:00 AM
I read about this the other day. I'd say I was surprised but at this point I'd be surprised if it was otherwise.
Posted by: Idyllopus | May 12, 2005 07:28 AM
What the hell is wrong with these people that we have to actually argue the economics of preventing brain damage in children??
Posted by: desi | May 12, 2005 07:36 AM
You overlook the other benefit. Cheap, easily led labor, lacking the wherewithal to comprehend the magnitude of th crime bushco is inflicting on the world, and willing to vote against their own self interests, thus maintaining the ever so useful fiction of demcoracy.
I think Voinovich may have been licking the paint walls:
"John Bolton is the poster child of what someone in the diplomatic corps should not be," Voinovich said. He said Bolton would be fired if he was in private business.
"That being said, Mr. Chairman, I am not so arrogant to think that I should impose my judgment and perspective of the U.S. position in the world community on the rest of my colleagues," he added. "We owe it to the president to give Mr. Bolton an up or down vote on the floor."
So the President deserves a guy who should be fired because of his duplicity and utter lack of integrity? Makes sense to me, or it would, if I had been eating lead invested paint as a child.
Posted by: Duckman GR | May 12, 2005 11:44 AM
This is the regime that has been imposed on EPA and other regulatory agencies by industry flack John Graham, who got his job in regulatory oversight at OMB by taking millions in industry money to fund his far-right regulatory policy institute at the JFK School. OMB has long been trying to get the agencies whose regulations they have to approve to race to the bottom in getting the weakest "alternatives" included they can dream up -- i.e., as here, doing essentially nothing.
I don't know what the regulatory development process was in this case -- as to whether the do-nothing alternative was included by EPA or simply insisted on by OMB. Some parts of EPA not directly taken over by robber baron ideologues (as the air program has been) have gotten a case of Stockholm Syndrome and given OMB what they want before they formally ask for it. While it makes no difference to the final outcome -- OMB gets what it wants almost every time nowadays -- this is degrading to the culture of the agencies that will survive this Administration, if our electoral system survives to allow a day of recommitment to the law to return. It does matter to the sense of institutional integrity to insist that OMB do the gutting of statutes rather than doing their dirty work for them.
Posted by: Steady Eddie | May 12, 2005 11:47 AM
Stupid; Webster "given to unintelligent decistions or actions". As a small time landlord trying to earn a little for retirement I have recent experience with HUD and lead abatement. It is just getting started and the costs associated will encrease, by many times, as soon as the gold plated requirements are in place and fully impemented. I have no choice, the rent goes up as my costs go up. HUD will not pay more rent. Where do the people go that I can no longer help with reasonably low cost housing that I cannot provide due to lead abatement costs?
Save these poor children from the evil Lead, emotionally it feels good to have this view. Price them out of a home and then what? Throwing money at problems, real or perceived, may feel good but it does not resolve the issue financially or emotionally.
If you do not understand the issuse how can you call the situation supid? Gold plated, computer operated, committee steered solutions are very expensive and usulally have lots of pretty graphics to help us feel good about spending someone elses money. They just do not solve problems.
Posted by: Merlin Egan | May 12, 2005 02:39 PM
"Save these poor children from the evil Lead, emotionally it feels good to have this view..."
Silly me. I didn't realize that keeping dangerous neurotoxins out of the mouths of our nation's children was simply a "feel-good" issue. If your having an abatement issue, simply tell your *own* kids it's Laffy Taffy. After a few days, they might just believe it.
Posted by: Ian Bruce | May 12, 2005 04:39 PM
Silly? No, uninformed, perhaps. A comprehensive cleaning regimen will accomplish all that is needed. It can be done by parents and is not expensive or difficult.
Who do you trust with the health of your children? If we cannot trust parents to take care of their own children, what government agency can we trust?
Posted by: Merlin Egan | May 13, 2005 09:58 AM
Merlin Egan:
It seems that if the EPA makes the regulations voluntary, you will choose not to comply. That is why voluntary regulations are stupid.
Posted by: dwight Meredith | May 13, 2005 11:08 AM
Wampum had a great post, with a fantastic insight. We could have the regulation and reimburse the contractors that suffer the cost, and still be better off as a society, because the regulations save more money than they cost.
This dovetails nicely with Richard Epstein's regulatory takings theory, that says the government should reimburse people who suffer losses from regulation.
Now so many liberals consider Epstein's idea so bad and evil, but they haven't stopped to consider the following point: If Epstein's idea were in place, the businesses wouldn't oppose socially beneficial regulation, because the businesses wouldn't lose from such regulation. This would change the political pressures on regulatory agencies accordingly, and we'd have more good regulation (regulation that generates more benefit than cost) and less bad regulation (regulation that generates more costs than benefits).
Specifically, if we adopted Epstein's regulatory takings view, we'd still have this good regulation.
Discuss.
Posted by: Keith Brown | May 13, 2005 05:05 PM
Regulations are necessary to protect our children from harm. As much as we claim to be "pro-life," it seems that we are quite willing to allow a certain amount of damage to children if it does not cost too much (and as long as it does not involve OUR children). Expecting parents to carry the entire burden of protecting their children is hardly consistent with "pro-family" policies. It's just another example of our glorious leaders selling out to the highest bidders at the expense of the most vulnerable.
Posted by: Carolyn | May 25, 2005 12:20 PM