Comments on IDPH Proposed Rule for Lead Poisoning Prevention Code

News (Friday, October 19, 2018)

On October 1st, Legal Council and Housing Action Illinois led an effort to comment on the proposed amendments to the Lead Poisoning Prevention Code put forward by the Illinois Department of Public Health (IDPH). We were joined by seven other organizations.

As of August 2018, the Illinois reference value for elevated blood lead level (EBL) is 5 mcg/dL (previously 10 mcg/dL). We strongly support IDPH’s proposed rules that adopt the federal Centers for Disease Control and Prevention (CDC) reference value for elevated blood lead level. This change will afford more opportunities for lead-exposed children to receive nurse home visits to provide lead and nutrition education, promote developmental screenings and follow-up. The proposed rules will also allow for proactive inspection and lead mitigation in regulated facilities that previously fell outside of the State of Illinois’ lead poisoning prevention enforcement mandates. As a result, we know that fewer children will suffer the debilitating consequences of an entirely preventable disease.

We also made comments to both improve and clarify the proposed rules, such as initiating environmental inspections at EBLs of 5 mcg/dL, instead of 10 mcg/dL, allowing primary care providers to request environmental inspections, calling for more complete information to be reported with lead test results, and providing additional data in IDPH’s Annual Lead Surveillance Report, among many other suggested changes. Our section-by-section recommendations with rationales can be viewed here.

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