Working to Keep Lead Clearances Strong in Detroit

This week, LDA of Michigan’s Healthy Children Project Coordinator, Amy Barto, had the opportunity to join lead advocacy partners in presenting public comment to the Detroit City Council Public Health and Safety Committee regarding proposed changes to the Property Maintenance Codes related to rental properties and lead-based contaminants. 

Testimony Against Proposed BSEED Amendments to the Property Maintenance Code Rental Ordinance impacting sections of the Ordinance around Certificate of Compliance/Lead Clearances

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Dear Members of the Detroit City Council Public Health and Safety Committee,

My name is Amy Barto and I am a board member and Healthy Children Project Coordinator for the Learning Disabilities Association of Michigan.

The Learning Disabilities Association of Michigan (LDA MI) is a statewide, non-profit organization of individuals with specific learning disabilities and attention disabilities, and the families and the professionals who support them. LDA MI’s mission is to enhance the quality of life for all individuals with learning disabilities and their families through advocacy, education, training, service, and support of research. Our Healthy Children Project advocates for policies and actions that will reduce children’s and pregnant women’s exposure to chemicals including lead that harm brain health.

One in 5 American children have a learning or attention disability. The autism rate continues to rise now affecting 1 in 54 children, which nearly tripled since 2000. Approximately 17.8% of children in the United States have a developmental disability. 

In Michigan, over 58,000 children were identified as having a specific learning disability in 2019. Thousands more have Attention Deficit Hyperactivity Disorder (ADHD). A little over 12% of students receive special education services in Michigan. 

The etiology of learning and developmental disabilities may include one or more of a complex variety of factors, including genetics, substance abuse, social environment, and environmental exposure to toxic chemicals.  According to the National Academy of Sciences Committee on Developmental Toxicology, environmental factors, including toxic chemicals, cause about 3 percent of all developmental defects, and contribute to another 25 percent. This means that 360,000 U.S. children (1 in every 200 U.S. children) suffer from developmental or neurological deficits caused by exposure to known toxic substances. The good news is that these causes are preventable.

When it comes to chemicals, lead has one of the strongest links to neurological harm. In fact, everyone agrees that there is NO SAFE LEVEL of lead exposure for children. LDA MI shares the distress of parents, professionals, and schools over the continued lead crisis. 

In 2019 in Wayne County, there were close to 10,000 children in special education identified as having a specific learning disability and over 4,000 with autism. In the state of Michigan, of all students receiving special education services, 27.5% were identified as having specific learning disabilities and 10.7% were students identified with autism.  In  Wayne County, the percentage of students identified with specific learning disabilities was in line with the state data. The percentage of students with autism was  12.2%, higher than around the state.

We know that there are more than just the emotional and social costs to learning and developmental disabilities. It costs the school system about twice as much to educate a child with special needs as it does other students. And the burden on the caretakers and parents with children with special needs is greater. 

Despite the reduction in population blood lead concentrations, the estimated yearly cost of childhood lead exposure in the United States is $50 billion. Reducing blood lead levels result in significant savings. For example, every $1 invested to reduce lead hazards in housing units, the economic benefit would be $17 to $221.  Another analysis looking at the reduction in children’s blood lead concentrations between the 1970s and 1990s estimated an economic benefit of $110 to $319 billion for each year’s cohort of 3.8 million children aged 2 years (primarily attributed to improvements in worker productivity as a result of increased IQ scores). Imagine the savings to both families, schools, and the state, when we reduce lead exposures from housing. 

We have known for years it is not enough to test children for lead, we need to eliminate the source of the exposure. This is good for children as well as our state. Reducing the healthcare, special education, and other costs resulting from lead exposure is a win for everyone. 

This is why LDA MI supports the proposal offered by Detroit-based lead advocates that ordinance language should require property owners to conduct Risk Assessments of rental units for lead every two years for projects using interim controls and every four years for projects that use encapsulation/enclosure methods to remediate any sources of lead found. We also support the current renewal for Certificate of Compliance to be every three years.

LDA-MI strongly encourages BSEED and the City of Detroit to keep this ordinance strong so it continues to protect families in rental housing.