Impact of Lead Poisoning on Minority and Low-Income Communities in Toledo, Ohio

Advocates for Basic Legal Equality, Inc.

Robert Cole, Esq. | Vanshika Vij

July 2014

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 1

I. CITY OF TOLEDO PROPOSED CERTIFICATE OF REGISTRATION

OF LEAD SAFE RESIDENTIAL RENTAL PROPERTY

The city of Toledo has the opportunity to enact an ordinance, that if adopted would require that residential

rental property be lead safe before a family with young children moves in. The goal of this proposed

ordinance is to address the dangers of lead for families who are residential rental property tenants.

Minorities and low-income residents are at a much greater risk for lead poisoning than other

demographics. The minority and low income populations of city of Toledo are concentrated in the high

risk zip codes for lead poisoning. The dangers posed by lead poisoning of children falls disproportionately

on Toledo’s on low-income and African American populations.

The Ordinance would require that every owner of residential rental property constructed prior to 1978

must have the property inspected for lead hazards and maintain such property free from Lead Hazards. If

an inspection of the residential rental property shows the existence of lead hazards, the owner must have

the lead hazard corrected, before the property can be rented.

The Ordinance would further require that every owner of residential rental property constructed prior to

1978 within the City of Toledo, obtain a Certificate of Registration of Lead Safe Residential Rental

Property from the Toledo Lucas County Health Department before letting or otherwise permitting the

occupancy of such residential rental property.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 2

II. BACKGROUND ON LEAD POISONING

Lead poisoning is defined as a confirmed blood lead level of 5 micrograms per deciliter (μg/dL) or

greater.1 The CDC adopted this standard in May 2012, changing the level of concern from 10μg/dL to

address the lasting effects that even a small amount of lead exposure can have on small children.2 Once

the blood-lead level reaches 45μg/dL, medical attention is necessary in the form of chelatin therapy.3

Lead poisoning can cause permanent damage to the brain and many other organs and causes reduced

intelligence and behavioral problems. These problems can start in vitro if a woman is exposed to lead

paint or dust while pregnant, and can also result in fetal abnormalities.

A. Historical Use of Lead Paint and its Health Effects

Lead in its pure form or added to paint has been used to paint houses for over half of the twentieth century

in the United States. As early as 1907, lead was not added to paint, instead, homeowners painted with lead

itself.4 Linseed oil was added to pure lead and sold in kegs so it could be applied to the walls. Later, the

wooden kegs were replaced by 25 and 50 pound metal buckets of lead for house-painting – literally

hundreds of pounds of lead were painted on houses from the walls to the gutters. Between 1900 and 1950,

many houses in the U.S. were painted with lead. Lead was also added to paint, and individuals were

encouraged to use to paint their homes as well as their children’s cribs and toys.

Lead paint use began to decline significantly in the early 1970s, but it was not until 1978 that the

Consumer Product Safety Commission banned using lead in paint.5 However, this law did nothing to

address the thousands of housing structures that were still painted with lead, and as this paint deteriorates,

many houses pose a significant health hazard to children and families living in them. In 2008, the U.S.

Department of Housing and Urban Development (HUD) reported that there are an estimated 38 million

homes that contain lead paint; accounting for approximately forty percent of all housing in the United

States.6 Furthermore, children who suffer lead poisoning are most often poisoned in their homes through

ingesting lead-contaminated dust or lead paint.7 The CDC reported that over 4 million homes in the U.S.

have exposed children to high levels of lead.8 Many families are not aware that their homes could contain

lead hazards and thousands of children are at risk to suffer lead poisoning.

Young children are particularly vulnerable to lead poisoning, the effects of which can last throughout their

lives. Lead poisoning often occurs with no obvious symptoms, but its effects are serious and can affect

nearly every system in the body, even when ingested in small amounts.9 Children who ingest lead can

suffer damage to their nervous system, behavior and learning problems, and delayed physical growth and

1 “Blood Lead Levels in Children,” Center for Disease Control and Prevention, accessed June 18, 2014,

http://www.cdc.gov/nceh/lead/ACCLPP/Lead_Levels_in_Children_Fact_Sheet.pdf. 2 Ibid.

3 Ibid.

4 “Ignoring Minority Children: New York State’s Failure to Respond to Lead Paint Poisoning – A Matter of Racial Justice.”

Powerpoint Presentation. The Empire Justice Center. 5 “CPSC Announces Final Ban on Lead-Containing Paint,” Consumer Product Safety Commission, Release # 77-096

(September 2, 1977): accessed on June 18, 2014, http://www.cpsc.gov/en/recalls/1977/cpsc-announces-final-ban-on-lead-

containing-paint/. 6 “Lead Poisoning,” National Safety Council, accessed June 19, 2014,

http://www.nsc.org/news_resources/Resources/Documents/Lead_Poisoning.pdf. 7 “Lead,” Center for Disease Control and Prevention, last modified June 19, 2014, http://www.cdc.gov/nceh/lead/.

8 Ibid.

9 Ibid.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 3

development (including damage to their hearing), and experience other health problems.10

The CDC

estimates that half a million children in the U.S. have blood lead levels higher than 5 μg/dL.11

Lead

poisoning is largely preventable if the contamination is identified early, but it often goes untreated and

many children continue to suffer its negative effects.

Source: Edinburg Texas Property12

B. Lead Poisoning in Ohio

All of the data available about lead poisoning from the Ohio Department of Health is from 2012 or earlier,

so it does not take into account the new CDC guidelines for elevated blood levels. Since the threshold

blood-level went from 10μg/dL to 5μg/dL, the number of lead poisoning cases going forward is expected

to be higher.

10

“Lead in Paint, Dust, and Soil – Basic Information,” Environmental Protection Agency, accessed June 27, 2014,

http://www.epa.gov/lead/pubs/leadinfo.htm. 11

“Lead,” Center for Disease Control. 12

http://edinburgtexasproperty.com/images/2010/lead-poisoning-effects-in-adults-6310.gif

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 4

Many children in Ohio are at risk to suffer from lead poisoning. More than half of the housing units in

Ohio were built prior to 1970, the time period for which housing is most likely to contain lead paint

hazards.13

Additionally, 42% of the housing in Ohio was constructed before 1950.14

As reported by the

Ohio Health Department, the state has up to 3.7 million housing units that contain some lead-based paint

on the interior and/or exterior surfaces. 15

Across Ohio, about 150,000 children from birth to 6 years of

age are screened for lead poisoning and approximately 2 percent are found to have elevated blood lead

levels.16

In recent years, Ohio has seen a slight decline in confirmed child lead poisoning cases, but Lucas County

remains higher than the state average. The Ohio Department of Health estimates that approximately

19,000 children in Ohio have lead poisoning.17

In 2012, only 1% of Ohio children tested positive for

elevated blood-lead levels.18

Lucas County was higher than the state-wide average, with 1.79% of

children testing positive.19

The city of Toledo was even higher, with 2.06% of tested children testing

positive for lead poisoning.20

Result

Category

Total

Children

Screened

< 5

μg/dL

5 - 9

μg/dL

10 - 14

μg/dL

15 -

19

μg/dL

20 - 24

μg/dL

≥25

μg/d

L

Total

Confirmed

EBLs

%

EBLs

Lucas

County

5658 5160 368 52 22 13 14 101 1.79

State

Total

154,440 145,07

4

7,482 900 327 165 165 1,557 1.01

Source: Ohio Dept. of Health21

Adults do not only pick up lead from their homes, but also from their work environments. Ohio tested

15,000 adults in 2010 for lead poisoning, and approximately 20% of these adults had elevated blood

levels.22

In 2011, the average blood lead level for adults in Ohio was5.08μg/dL.23

While this level was not

considered lead poisoning at the time, under the current CDC standards, this level is a cause for concern.

13

“Selected Housing Characteristics: 2008-2012 American Community Survey 5-Year Estimates,” United States Census

Bureau, accessed June 20, 2014,

http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_12_5YR_DP04. 14

“Data and Statistics on Lead Poisoning – Children,” Ohio Department of Health, last modified January 13, 2014,

http://www.odh.ohio.gov/odhprograms/cfhs/lead_ch/lead_data.aspx. 15

“Data and Statistics on Lead Poisoning – Children.” 16

Ibid. 17

“Lead Prevention,” Toledo – Lucas County Health Department, accessed June 26, 2014,

http://www.lucascountyhealth.com/#/environmental/lead-prevention. 18

“Data and Statistics on Lead Poisoning – Children.” 19

Ibid. 20

Ibid. 21

“Childhood Lead Poisoning Fact Sheet for the Toledo-Lucas County Health Department,” Ohio Department of Health,

accessed June 20, 2014, http://www.odh.ohio.gov/~/media/ODH/ASSETS/Files/cfhs/lead%20poisoning%20-

%20children/2014/countyprofiles/lucas%20county%202014.pdf. 22

“Data and Statistics on Lead Poisoning – Adults,” Ohio Department of Health, last modified May 22, 2013,

http://www.odh.ohio.gov/odhprograms/hprr/l_adult/pbdatastats.aspx. 23

Ibid.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 5

Source: CDC Healthy Homes and Lead Poisoning Prevention24

Lead poisoning is not just dangerous, it is costly. Researchers did a study in Mahoning County, Ohio to

find out how much money lead poisoning was costing their county each year. In 2002, 279 children in

Mahoning County were diagnosed with lead poisoning.25

Between treatment costs, special education

services, and juvenile justice systems costs, the study found that childhood lead poisoning cost the county

half a million dollars in 2002, not even including the indirect costs of having an intellectually stunted

workforce.26

That study estimated that lead poisoning costs the U.S. nearly $43.4 billion per year.27

As a

result of the Mahoning County study, the city appointed a special landlord tenant prosecutor and reduced

the number of lead hazard properties by 14%.28

24

“Data and Statistics on Lead Poisoning – Children.” 25

Matthew Stefanak, Joe Diorio, and Larry Frisch, “Cost of Child Lead Poisoning to Taxpayers in Mahoning County, Ohio,”

Public Health Reports 120 (2005): 311, accessed June 19, 2014,

http://www.publichealthreports.org/issueopen.cfm?articleID=1476. 26

Ibid., 311. 27

Ibid., 312. 28

Ibid., 315.

Percent of Children with Elevated Blood Lead Levels* by County, Ohio 2007

*Percent of children with Elevated Blood Lead Levels: The number of

Children less than 72 months of age with a confirmed elevated blood

lead level ≥10μg/dL divided by the number of children less than 72 months

of age tested for blood lead, multiplied by 100.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 6

Source: Ohio Department of Health, Data and Statistics on Lead Poisoning Prevention29

29

“Average Blood Lead Levels, by County.” Ohio Department of Health – no longer available on ODH website, but was used

in ABLE’s initial blood lead levels report.

Average Blood Lead Level By County, 2009

The map depicts the average blood lead level of children ages 0‐ 72 months for each county. Data from 147,977 Ohio children that were reported to the

Systematic Tracking of Elevated Lead Levels And Remediation (STELLAR) database in 2009 were used to create this map. Cuyahoga (3.59 ųg/dl),

Lucas(3.44 ųg/dl), Stark 3.41 ųg/dl), Wyandot (3.35 ųg/dl), and Crawford (3.16 ųg/dl) counties had the highest average blood lead levels.

*Note: Only the highest blood lead level for each child was used.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 7

III. EXISTING LAWS AND REGULATIONS

Lead poisoning is addressed in laws and regulations from the Ohio Administrative Code, the EPA,

OSHA, HUD, and the Consumer Product Safety Consumer Act.

A. Lead Paint Poisoning

In Ohio, state law mandates blood lead screening for all “high risk” children below 72 months of age. A

“high risk” child is defined as any child enrolled in Medicaid, any sibling of a child with an elevated

blood lead level, or any child residing in one of the following zip codes in the Lucas County area:30

43402 43606 43612

43460 43607 43613

43551 43608 43614

43602 43609 43615

43604 43610 43620

43605 43611 43624

The numbers of children who are considered to be “high risk” are as follows:

Age # of Children in Lucas County

Under 1 5,804

1 year 5,944

2 years 6,073

3 years 5,966

4 years 5,945

5 years 5,691

Total Under 6 35,423

Source: Ohio Dept. of Health31

When a child is found to have a confirmed blood lead level of 5 μg/dL, this triggers several state and local

level actions. According to the Ohio Administrative Code, when an individual under six years of age has

lead poisoning a public health lead investigation is ordered to determine the source of lead poisoning.

When an individual between six years and sixteen years of age has lead poisoning, a public health lead

investigation to determine the source of the lead poisoning may be conducted. For children with a blood

lead level of ten micrograms per deciliter or greater but less than fifteen micrograms per deciliter the

Health Department shall cause the completion of a comprehensive questionnaire, and the completed

comprehensive questionnaire shall be reviewed by a public health lead investigator. The public health

lead investigator shall be responsible for any follow up actions deemed necessary (e.g., provide

educational materials to the family, conduct a public health lead risk assessment). For children with a

blood lead level of fifteen micrograms per deciliter or greater the director shall conduct an on-site

30

“Lead Testing Requirements and Medical Management Recommendations for Children Under the Age of Six Years,” Ohio

Healthy Homes and Lead Poisoning Prevention Program, last modified August 2010,

http://www.odh.ohio.gov/~/media/ODH/ASSETS/Files/cfhs/lead%20poisoning%20-

%20children/Lead%20Testing%20Requirements%20and%20Medical%20Management%20Recommendations.ashx. 31

“Childhood Lead Poisoning Fact Sheet for the Toledo-Lucas County Health Department.”

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 8

investigation of a residential unit, child care facility or school. The investigation shall be performed by a

public health lead investigator.32 33

In Ohio, these guidelines require that children ages 6 months to 36 months of age, living in designated

high-risk zip code areas, should be tested for blood lead content twice, with at least 12 months between

tests. Those who test at confirmed elevated levels should receive case management services. Additionally,

their residence should receive a public health lead investigation.34

B. Housing Structure Abatement

In 1992, Congress passed the Residential Lead-Based Paint Hazard Reduction Act, also known as Title X,

to protect families from exposure to lead from paint, dust, and soil. Section 1018 of this law directed

HUD and EPA to require the disclosure of known information on lead-based paint and lead-based paint

hazards before the sale or lease of most housing built before 1978.35

According to national law, before ratification of a contract for housing sale or lease, sellers and landlords

must:

Disclose any known information concerning lead-based paint or lead-based paint hazards. The

seller or landlord must also disclose information such as the location of the lead-based paint and/or

lead-based paint hazards, and the condition of the painted surfaces.

Provide any records and reports on lead-based paint and/or lead-based paint hazards which are

available to the seller or landlord (for multi-unit buildings, this requirement includes records and

reports concerning common areas and other units, when such information was obtained as a result

of a building-wide evaluation).

Include an attachment to the contract or lease (or language inserted in the lease itself) which

includes a Lead Warning Statement and confirms that the seller or landlord has complied with all

notification requirements. This attachment is to be provided in the same language used in the rest

of the contract. Sellers or landlords, and agents, as well as homebuyers or tenants, must sign and

date the attachment.

Sellers must provide homebuyers a 10-day period to conduct a paint inspection or risk assessment

for lead-based paint or lead-based paint hazards. Parties may mutually agree, in writing, to

lengthen or shorten the time period for inspection. Homebuyers may waive this inspection

opportunity.36

32

Ohio Administrative Code 3701-30-07, “Public Health Lead Investigations,”LawWriter, accessed June 27, 2014,

http://codes.ohio.gov/oac/3701-30-07. 33

To read the complete law regarding Childhood Lead Poisoning, see: “Chapter 3701-30

Childhood Lead Poisoning Prevention Investigation and Reporting.” Ohio Department of Health, last accessed June 27, 2014,

http://www.odh.ohio.gov/rules/final/3701-30-39/f3701-30.aspx. 34

“Lead Poisoning Prevention - Children,” Ohio Department of Health, accessed June 27, 2014,

http://www.odh.ohio.gov/odhPrograms/cfhs/lead_ch/leadch1.aspx. 35

“The Lead Disclosure Rule,” U.S. Department of Housing and Urban Development, accessed June 26, 2014,

http://portal.hud.gov/hudportal/HUD?src=/program_offices/healthy_homes/enforcement/disclosure. 36

Ibid.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 9

However, there are no regulations in the Northwest Ohio area that require a housing structure to be tested

for lead.37

Disclosure of lead hazards only applies if the owner or seller knows there is a lead hazard in the

structure. Furthermore, a public health lead investigation does not necessarily trigger abatement – the

family may be advised to use a HEPA Vac or do wet dusting as a means of preventing more damage to

the child. Ohio received a grant that allows families to borrow HEPA vacuums for lead clean up at no

charge.38

If abatement is desired, an abatement grant can be applied for through the City of Toledo or

Lucas County offices, but those grants are not always awarded.

In August 2013, HUD awarded a $2.3 million grant to the Ohio Healthy Homes and Lead Poisoning

Prevention Program to eradicate lead hazards in houses where small children live.39

This grant only

applied to 16 counties, and did not include Lucas County.40

According to Chapter 12 of HUD’s guidelines, abatement can take place in three different ways. The

person can remove the building component, remove the paint, or enclose the paint for 20 years or more.41

HUD outlines these specific methods of abatement to follow to ensure that the abatement is completely

safely and legally. The Ohio Administrative Code extensively describes the appropriate parties and

methods to neutralize lead hazards.42

The EPA has a Renovation, Repair, and Painting Rule (RRP Rule) that requires firms who undertake lead

abatement in homes and childcare facilities to get a special certification from the EPA. 43

This

certification involves special training for the contractors in safely working with lead.44

37

For a complete list of the rules and regulations regarding lead abatement, see the Ohio Administrative Code

Chapter 3701-32: Lead Hazard Abatement and Inspection Activities, http://www.odh.ohio.gov/en/rules/final/3701-30-

39/f3701-32.aspx. 38

“Vacuum Loaner Program,” Ohio Department of Health, last modified March 5, 2014,

http://www.odh.ohio.gov/en/odhprograms/dspc/lp_prev/hepa.aspx. 39

“Lead Hazard Control Grant Program,” Ohio Department of Health, last modified October 29, 2013,

http://www.odh.ohio.gov/odhprograms/cfhs/lead_ch/lhcgp.aspx. 40

Ibid. 41

“Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (2012 Edition)” U.S. Department of

Housing and Urban Development: 12-11, accessed June 20, 2014,

http://portal.hud.gov/hudportal/documents/huddoc?id=ch12_abatement_121212.pdf. 42

Ohio Administrative Code 3701-32, “Lead Hazard Abatement,” LawWriter, accessed June 26, 2014,

http://codes.ohio.gov/oac/3701-32. 43

Renoviation, Repair, and Painting Program,” U.S. Environmental Protection Agency, last modified May 19, 2014,

http://www2.epa.gov/lead/renovation-repair-and-painting-program. 44

Ibid.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 10

IV. IMPACT ON MINORITY AND LOW-INCOME COMMUNITIES

Nationally, lead poisoning cases have declined dramatically over the past thirty years, however, lead

poisoning disproportionately affects low-income and minority communities, often in urban centers.

Children not only absorb lead more readily, but also are more likely to ingest lead dust or paint chips.45

Children from low-income communities tend to suffer more often from lead poisoning because the

housing they live in is less likely to undergo renovations.46

Nationally, African Americans are affected by lead poisoning at a much higher rate than Caucasian

children. According to the CDC, minorities are more likely to test positive for lead, particular non-

Hispanic African Americans.47

On average, 3% of African American children test positive for lead, as

opposed to only 1.3% of white children.48

Toledo’s African American population is 27.2% of the total

population, which is twice the state average.49

The majority of the land contained within the boundaries of the city of Toledo is considered high risk

areas for lead poisoning. The homes in these high risk zip codes are older and possess a high risk for the

presence of lead paint.

The homes in Lucas County’s high risk zip codes are more likely to be inhabited by minorities and low

income residents. A large number of the older, pre-1950s housing stock is located within the central area

of the city of Toledo, while the newer, but not necessarily lead-free, housing is more common closer to

the boundaries of the city.

There are no regulations in Toledo compelling the inspection of all at-risk homes for lead paint, unless a

child has been lead poisoned in that home. The number of houses built before lead paint was banned in

1978 far outweighs the number of public health lead investigations performed each year.

Lucas County has a relatively low compliance with state mandated requirements to test children living in

high risk zip codes for elevated blood lead levels. In 2010, only 28% of children living in Lucas County

under the age of 5 were tested.

45

“Lead Poisoning: Risk Factors,” Mayo Clinic, last modified June 10, 2014, http://www.mayoclinic.org/diseases-

conditions/lead-poisoning/basics/risk-factors/con-20035487. 46

Ibid. 47

“Childhood Lead Poisoning: Exposure and Risk,” Center for Disease Control and Prevention, last modified on September 5,

2013, http://ephtracking.cdc.gov/showChildhoodLeadRisk.action. 48

Ibid. 49

“State and County QuickFacts: Toledo (city), Ohio,” United States Census Bureau, last modified June 11, 2014,

http://quickfacts.census.gov/qfd/states/39/3977000.html.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 11

A. Environment Justice and Lead Poisoning in Toledo

50

50

Potential environmental justice population as defined by percent minority population (all minority groups) per census tract

compared to the county total population.

Federal Highway Administration (FHWA) guidance sets a threshold of 10 percentage points above the minority population

percentage in the county, in accordance with NEPA “meaning fully greater” guidance.

The areas in red are census tracts that exceed 39.0% total minority population (Lucas County minority population = 29.0%).

Sources: Lucas County Department of Health;

US Census Bureau;

US Department of Transportation FHWA Guidance;

Council on Environmental Quality Guidance under the National Environmental Policy Act.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 12

Environmental Justices, as defined by federal law, requires an agency receiving federal funds to ensure

that no one be excluded from participation in, be denied the benefits of, or be subjected to discrimination

under any program or activity receiving federal financial assistance based on race, color, or national

origin.51

The National Environmental Policy Act of 1969 (NEPA)52

stressed the importance of providing for "all

Americans safe, healthful, productive, and esthetically pleasing surroundings", and provided a

requirement for taking a "systematic, interdisciplinary approach" to aid in considering environmental and

community factors in decision making.

The enactment of the proposed Lead Ordinance is a matter of environmental and racial justice. The

conclusions that can be drawn, from the data regarding which children continue to be exposed to lead

hazards, be lead poisoned and where they live, is clear. Minorities and low-income residents are at a much

greater risk for lead poisoning than other demographics. The minority and low income populations of city

of Toledo are concentrated in the high risk zip codes for lead poisoning. The dangers posed by lead

poisoning of children falls disproportionately on Toledo’s on low-income and African American

populations.

B. Age of Housing in Toledo

It is clear that lead paint exposure and poisoning is a risk in housing built prior to 1970 that does not

undergo safe renovations.

Source: Ohio Dept. of Health53

51

Title VI of the Civil Rights Act of 1964 52

The National Environmental Policy Act of 1969, as amended 42 USC § 4321 53

“Childhood Lead Poisoning Fact Sheet for the Toledo-Lucas County Health Department.”

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 13

Source: City of Toledo Consolidated Plan FY2010-201554

C. Demographics of Lucas County

The 2010 Census estimates that the population of Lucas County in 2013 was approximately 436,393

people.55

However, for the purposes of this report, we will use the Lucas County 2010 population of

441,815 people since many data items are collected only during the decennial census.56

In Lucas County, Caucasians are the majority racial group and African Americans make up the largest

minority group. Other minority groups, including those individuals who identify as Hispanic make up

approximately 6.4 percent of the Lucas County population.

Racial Breakdown of Lucas County, Ohio

Race Percent of Total Population

White 75.7%

Black or African-American 19.5%

American Indian and Alaska Native 0.4%

Asian 1.6%

Two or More Races 2.7%

Hispanic or Latino 6.4%

White alone, not Hispanic or Latino 70.5%

Source: U.S. Census Bureau57

54

“Housing Market Analysis and Housing Needs for Special Populations.” City of Toledo: Consolidated Plan FY2010-2015,

http://www.ci.toledo.oh.us/ and http://www.ci.toledo.oh.us/LinkClick.aspx?fileticket=jup1CpUKdjs%3D&tabid=393. 55

“State and County QuickFacts: Lucas County, Ohio,” U.S. Census Bureau, last modified June 11, 2014,

http://quickfacts.census.gov/qfd/states/39/39095.html. 56

Ibid. 57

Ibid.

Age of Housing Units in the City of Toledo

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 14

In Lucas County, 6.4% of the total population is younger than 5 years old.58

When discussing the

demographics of children in Lucas County, it is important to note that while lead testing occurs for

children up to six years of age, Census data is reported for children under age five. This means that our

determination of at-risk populations actually underestimates the number of at-risk children. Despite this

underestimation, it is highly likely that the trends for children up to age five also apply to the children

who undergo testing, but for whom we are not able to specify demographic data.

D. High Risk Zip Codes

Across Ohio’s 88 counties, 513 zip codes have been designated as “high risk” by the Ohio Health

Department.59

High risk zip codes are designated as such based on previous lead testing results,

characteristics of the housing, population demographics, and the proportion of individuals receiving

public assistance. Eighteen zip codes that overlap or are contained within Lucas County have been

determined to be “high risk.”60

Residents of these zip codes are at a significantly higher risk for lead

poisoning.

Source: Lucas County Department of Health61

Within Lucas County, Toledo residents are at a higher risk for lead poisoning than those who live in other

cities in the county. Of the eighteen high-risk zip codes in Lucas County, fifteen of those zip codes are

contained within or overlap the boundaries of Toledo.62

These fifteen zip codes encompass the majority of

the geographical area of the city.

58

Ibid. 59

“Map of Zip Codes.” Ohio Department of Health , www.co.lucas.oh.us/DocumentView.asp?DID=1755. 60

Ibid. 61

“Lead Prevention.” 62

“Housing Market Analysis and Housing Needs for Special Populations,” City of Toledo: Consolidated Plan FY2010-2015,

City of Toledo, http://www.ci.toledo.oh.us/ and

http://www.ci.toledo.oh.us/LinkClick.aspx?fileticket=jup1CpUKdjs%3D&tabid=393.

High Risk Zip Codes, Lucas County

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 15

High Risk Zip Codes in Lucas County

43402 43606 43612

43460 43607 43613

43551 43608 43614

43602 43609 43615

43604 43610 43620

43605 43611 43624

Source: Ohio Healthy Homes and Lead Poisoning Prevention Program63

Source: City of Toledo Consolidated Plan FY2010-201564

These zip codes contain approximately 99.4 percent of Toledo’s total population and 68.5 percent of

Lucas County’s total population.65

Nearly all of Toledo’s population and a majority of Lucas County

residents are at risk for lead exposure.

The city of Toledo has one of the highest rates of childhood lead poisoning in Ohio. Toledo ranks second

highest in Ohio for the percentage of children with confirmed elevated blood lead levels in 2012. Further,

based on the individual blood lead levels Toledo has some of the highest blood lead levels in the state.

Within the past 3 years, children in Toledo have tested as high as 65 micrograms per deciliter.

63

“Lead Testing Requirements and Medical Management Recommendations for Children Under the Age of Six Years,” Ohio

Healthy Homes and Lead Poisoning Prevention Program, last modified August 2010,

http://www.odh.ohio.gov/~/media/ODH/ASSETS/Files/cfhs/lead%20poisoning%20-

%20children/Lead%20Testing%20Requirements%20and%20Medical%20Management%20Recommendations.ashx. 64

Ibid. 65

“American FactFinder,” U.S. Census Bureau, accessed June 27, 2014,

http://factfinder2.census.gov/faces/nav/jsf/pages/community_facts.xhtml.

High-Risk Zip Codes, City of Toledo Based on 2000 Census

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 16

In 2012, only 1% of Ohio children were diagnosed with lead poisoning. That same year, 2.06% of

children in Toledo were diagnosed with lead poisoning – over twice the state average.66

Further, this

number would conservatively double if 100% of all children under the age of 5 were being tested in

Toledo, rather than only the 28% who actually are being tested.

Childhood Lead Poisoning in Major Ohio Cities City # of Cases % of Cases

Cleveland 652 4.20%

Cincinnati 134 0.89%

Toledo 102 2.06%

Columbus 45 0.31%

Dayton 40 0.82%

Akron 33 0.99%

Source: Ohio Health Department67

African Americans are at a much higher risk of lead poisoning than Caucasians in Lucas County. Lucas

County’s total African American population is 83,926.68

Over 80,000 of these African American residents

live within high risk zip codes.69

This means that over 96% of Lucas County’s African American

population is at a significant risk for lead poisoning.70

Lucas County’s total white population is 326,868.71

Approximately 256,000 of these residents live in high risk zip codes.72

Thus, only 78% of the white

population in Lucas County lives within high risk zip codes.73

66

“Data and Statistics on Lead Poisoning – Children.” 67

Ibid. 68

Ibid. 69

Data from the 2010 Census American Factfinder using ODH list of high-risk zip codes. 70

Ibid. 71

“American FactFinder.” 72

Data from the 2010 Census American Factfinder using ODH list of high-risk zip codes. 73

Ibid.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 17

E. Lead Poisoning in Lucas County 2000-2009

The number of children being tested for lead poisoning has declined in recent years, according to the Ohio

Department of Health. While at least 26,760 children under the age of five lived in high risk zip codes in

2010, less than 8,000 kids were tested, or roughly 28% of the children mandated by state law.74

Note: Chart refers to the total number of children age 0-72 months who had a blood lead level test

Data provided by the Ohio Department of Health.75

74

“American FactFinder.” 75

“Data and Statistics on Lead Poisoning – Children.”

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 18

Note: Chart refers to the total number of children age 0-72 months who had a reported BLL greater than 10 ųg/dL; if multiple tests occurred for one child, only the highest BLL was used in reporting.

Data provided by the Ohio Department of Health.76

The number of confirmed cases of lead poisoning reported to the state and local health departments has

been declining over the past decade.

Data provided by the Ohio Department of Health, graphs created using the ODH list of high-risk zip codes.

76

“Data and Statistics on Lead Poisoning – Children.”

Confirmed Cases of Lead Poisoning, Lucas County

288

242

541

419367

323 331 339

208202

238

331

531

409

361319 324

279

0

100

200

300

400

500

600

2000 2001 2002 2003 2004 2005 2006 2008 2009

Year

Nu

mb

er

of

Cases

Total Confirmed Cases Confirmed Cases, High-Risk Zip Codes

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 19

Over the past decade, approximately 97 percent of all confirmed cases of lead poisoning consistently

occur in high risk zip codes.77

For every reported case of childhood lead poisoning, a public health lead

investigation is required to take place. It is worth noting that the number of investigations for a given year

does not equal the number of lead poisoning cases for that year. This could be the result of multiple

children per household testing positive for elevated blood lead levels or the result of an investigation not

occurring when it should have. It is not possible to determine the exact cause of the difference.

Note: Chart refers to the total number of children age 0-36 months who live in high risk zip codes and received the state-mandated blood lead testing.

Data provided by Ohio Department of Medicaid78

While most Medicaid enrolled one and two year olds live in high risk zip codes for lead poisoning, few

actually receive a blood lead test. These populations are mandated by state law to receive blood lead level

tests at the ages of one year and two years.

77

Data from Ohio Department of Health, calculated using list of Lucas County high-risk zip codes. 78

“Medicaid Eligible and Recipient Information for Calendar Year 2007,” Ohio Department of Medicaid, accessed June 27,

2014, http://medicaid.test.ohio.gov/Portals/0/For%20Ohioans/Programs/Lead/CntyTestRates2007.pdf.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 20

The city of Toledo, in cooperation with the Department of Neighborhoods, recently launched a Lead

Remediation Program funded by HUD.79

The Department of Neighborhoods is providing interim control

lead abatement and clearance of 165 housing units through June 2015.80

The money is awarded in the

form of a grant, with priority given to households that have children under the age of six or at least one

pregnant female.81

By June of 2013, the Department of Neighborhoods had processed 56 intakes; Only 17

of those intakes had completed the enrollment eligibility at the time of the Evaluation Report.82

In 2013,

the city remediated lead from 9 homes.83

Note: Data may refer to residences where more than one child had a reported BLL greater than 10 ųg/dl

Data provided by the Ohio Department of Health.

Lead abatement grants are available through local government agencies to defray the costs of abating

housing structures; however, grants are not always awarded.

79

“Consolidated Annual Performance and Evaluation Report 2012-2013,” Department of Neighborhoods, City of Toledo, at

page 44, accessed June 27, 2014, http://toledo.oh.gov/media/36650/2012_-_2013_Final_CAPER_Part_2.pdf. 80

Ibid. 81

Ibid. 82

Ibid. 83

“Department of Neighborhoods 2013 Annual Report,” Department of Neighborhoods, City of Toledo, accessed June 27,

2014, http://toledo.oh.gov/media/72395/2013-Annual-Report.pdf.

Public Health Lead Investigations in Lucas County

255 255

204 209

143137

217

316

230

180

0

50

100

150

200

250

300

350

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Year

Nu

mb

er o

f In

vest

igat

ion

s

Public Health Investigations in Lucas County

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 21

Note: In 2008, there were 2 housing structures processed for intake, but for which a completed application was not received. In 2009, there were 47 intake housing structures with no application and there are 8 active applications. These structures, for which there was no completed

application or the application is still active, are not included in the totals above.

Data provided by the City of Toledo Department of Neighborhoods.

The number of housing structures that are being abated has been increasing in recent years, however, a

larger percentage of the total applications are being turned down. In fact, from 2003-2006, the number of

cancelled applications was almost double the number of structures that were abated. In 2007-2009, while

more structures are being abated than having applications cancelled, a significant number of applications

are being denied or cancelled.

It is evident that the number of structures abated is not coming close to reaching the number of structures

where there is public health investigation, or even where there is an abatement application.

Housing Strucures Abated, City of Toledo

63

3

202

106

6659

115

79

4234

115

0

110

29

0

50

100

150

200

250

2003 2004 2005 2006 2007 2008 2009

Year

Nu

mb

er

of

Ho

usin

g S

tru

ctu

res

Abatement Complete Abatement Cancelled

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 22

Data for public health investigations provided by the Ohio Department of Health, data for abatements provided by the City of Toledo Department of

Neighborhoods.

Furthermore, when comparing the number of housing structures that are being investigated and abated to

the number of housing structures that is potentially affect by lead paint, it is clear that there are a large

number of unabated housing structures, primarily in African American neighborhoods, in which children

are still being exposed to lead.

204 3 0

217

317

115

230

169

63

137

100

34

180

71

42

209

138

79

143

233

115

0

200

400

600

800

1000

1200

1400

Public HealthInvestigations

Abatement Requests Housing Abated

Nu

mb

er

of

Str

uc

ture

s

Lead Investigations and Abatement, 2003-2009, City of Toledo

2009

2008

2007

2006

2005

2004

2003

Total: 1031 Total: 448 Total: 1320

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 23

Data on housing from the 2000 Census for the City of Toledo84, for a detailed breakdown of housing age in Toledo, see Appendix B. Data for public health investigations from the Ohio Department of Health, data for abatement from the City of Toledo Department of

Neighborhoods.

84

“American FactFinder.”

Lead-Affected Housing in the City of Toledo, 2003-2009

108,689

1320 1031 4480

20,000

40,000

60,000

80,000

100,000

120,000

Pre-1970s Housing* Public Health

Investigations

Abatement

Requests

Housing Abated

Nu

mb

er o

f S

tru

ctu

res

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 24

F. Geographical Analysis

Minorities and low-income residents are at a much greater risk for lead poisoning than other

demographics. The minority and low income populations of city of Toledo are concentrated in the high

risk zip codes for lead poisoning. The dangers posed by lead poisoning of children falls disproportionately

on Toledo’s on low-income and African American populations.

In Lucas County and Toledo, the areas which have older housing stock (built prior to the 1970s or 1950s),

are the same areas where non-white populations are concentrated and have a higher incidence of public

health lead investigations.

Source: Ohio Dept. of Health85

85

“Childhood Lead Poisoning Fact Sheet for the Toledo-Lucas County Health Department.”

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 25

Source: Ohio Dept. of Health86

In one small census tract, the Ohio Department of Health predicts that 38.77% of the residents have lead

poisoning. In this tract, 92.5% of the population identifies as African American.

86

“Childhood Lead Poisoning Fact Sheet for the Toledo-Lucas County Health Department.”

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 26

Census Tract 32 Demographics87

Total Population 1412

White 47

African American 1306

Asian 5

AIAN 4

NHPI 0

Some Other Race 8

Two or More Races 42

Source: City of Toledo Consolidated Plan FY2010-201588

Looking at a map of the City of Toledo, it is clear that a large number of census tracts in the center of the

city contain a high proportion of housing that was built prior to 1970 and is thus likely to contain lead

paint.

87

Data from the U.S. Census Bureau 88

“Housing Market Analysis and Housing Needs for Special Populations,” City of Toledo: Consolidated Plan FY2010-2015.

Age of Housing Units in the City of Toledo

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 27

The following map show the concentration of non-white populations within Lucas County, as determined

by Census 2000 data. Additional maps show locations for public health investigations and lead

abatements.89

89

Note: In this section, all maps were created using GoogleEarth software from 2000 Census data and data provided by the

Ohio Department of Health and the City of Toledo Department of Neighborhoods.

Concentration of non-white populations, Lucas County

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 28

Within the center of Toledo, some of the census tracts are over 90 percent non-white. These are the same

areas where a high proportion of public health lead investigations occur. The following map shows the

locations of public health lead investigations within Lucas County:

Public Health Lead Investigations 2000-2009, Lucas County

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 29

When zoomed in on the map to focus on the Toledo area, it is clear that the vast majority of lead

investigations are in areas that have a high proportion of non-white residents.

Public Health Lead Investigations 2000-2009, Toledo Urban Area

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 30

Although there have been many public health lead investigations over the past decade, it seems that much

of this housing does not go through the abatement process.

To look at the most recent data available to ABLE, when comparing the locations of public health

investigations from 2009 to the locations of abated structures in 2009, it is likely that many housing

structures still contain lead hazards.

Public Health Lead Investigations and Housing Structure Abatement, 2009, Toledo

Data from the Ohio Department of Health and the City of Toledo Department of Neighborhoods.

Note: White dots represent the locations of public health lead investigations and green dots represent locations of abatement.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 31

V. IMPLICATIONS AND POLICY RECOMMENDATIONS

Lead poisoning is a serious problem in the city of Toledo and the problem is clearly concentrated in the

low-income and African American communities, where most, if not all of the housing stock was built

prior to 1950.

While lead exposure has many adverse health effects, the most common risk of harm to children is subtle

impairment of neurodevelopment, with small but measurable effects on cognitive and behavioral

outcomes. 90

Impaired cognitive development can have major impacts on their likelihood of finishing high

school, going on to higher education, and for their success in the job market. The cognitive and behavioral

effects of lead poisoning, permanently limits our children to fully benefiting from educational and

economic opportunities.

Additionally, society has an economic interest in reducing lead poisoning. Children with lead poisoning

suffer impaired cognitive abilities, which affect school performance, educational attainment, and success

in the labor market and is thus positively associated with earnings. Improvements in cognitive ability

benefit society by raising economic productivity and by avoiding placing the burden of care of lead

poisoned children on the public or government agencies. While it is difficult to measure the economic

effects of health outcomes, in a 2002 study by the Centers for Disease Control and Prevention, researchers

found that the economic benefit from the reduction in childhood lead exposure between 1976 and 1999

ranged from $110 billion to $319 billion.91

The goal of this proposed ordinance is to address the dangers of lead for families who are residential

rental property tenants. Minorities and low-income residents are at a much greater risk for lead poisoning

than other demographics. The minority and low income populations of city of Toledo are concentrated in

the high risk zip codes for lead poisoning. The dangers posed by lead poisoning of children falls

disproportionately on Toledo’s on low-income and African American populations.

Eliminating childhood lead exposure and abating housing structures should not begin when it is

discovered that a child has lead poisoning. Enacting and fully implementing an ordinance that requires

residential rental property owners to fully inspect for and correct lead hazards, before the property is

rented to a family with children, will prevent lead poisoning from occurring in the first place.

90

Grosse, Scott D., Thomas D. Matte, Joel Schwartz, and Richard J. Jackson, “Economic Gains Resulting from the Reduction

in Children’s Exposure to Lead,” Environmental Health Perspectives 110: 6, June 2002, National Center for Environmental

Health, Centers for Disease Control and Prevention, http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1240871/pdf/ehp0110-

000563.pdf. 91

Grosse et. al., “Economic Gains Resulting from the Reduction in Children’s Exposure to Lead.”

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 32

BIBLIOGRAPHY

Statistics and data regarding Lucas County and the City of Toledo specifically were calculated

using the following sources:

Number of children under the age of 72 months who were tested for elevated blood lead levels, and the

number who had a confirmed elevated blood lead level; data by zip code provided by Ohio Health

Department via email.

Addresses of housing where there had been a public health lead investigation 2000-2009, data provided

by the Ohio Health Department via email.

Addresses of housing which went through an abatement process and addresses of housing that was denied

an abatement grant; data provided by the City of Toledo Department of Neighborhoods, Division of

Housing via email.

2010 Census Data

Demographics and data for when housing structures were built, total population, population under age 5,

and population by race by zip code; data retrieved online from the Census Factfinder, 2010 data.

Data and Methodology

The data used in this report has been primarily collected from the 2010 Census, the U.S. Department of

Housing and Urban Development (HUD), the U.S. Environmental Protection Agency (EPA), the Ohio

Department of Health, Ohio Healthy Homes and Lead Poisoning Prevention Program, the Ohio

Administrative Code, the Center for Disease Control, the Lucas County Health Department, and the City

of Toledo Department of Neighborhoods. The 2010 Census was used to gather demographic data

regarding population, race, and age of housing by zip code as well as at the city and county level.

Percentages and analysis of race were calculated using this data.

Data for the number of confirmed cases of lead poisoning and testing of children under the age of 72

months by zip code in Lucas County was sent directly to ABLE by the Ohio Health Department in 2010.

The list of addresses where a public health lead investigation had occurred was also sent directly to ABLE

by the Ohio Health Department. Since then, new data on this subject has not been available to ABLE. It is

worth noting that there is a discrepancy between the number of confirmed cases of lead poisoning and the

number of public health lead investigations. This could be due to several factors, including multiple

affected children per household or cases where an investigation should have taken place, but did not

occur. However, for privacy reasons, it is not possible to obtain the addresses of children who reported

testing positive for a blood lead level of10 μg/dL or higher, that data can only be reported in aggregate, so

it is not possible to determine the cause of the difference.

The list of addresses that notes where housing structures went through lead abatement, received an

abatement grant, or were denied an abatement grant was provided directly to ABLE by the City of Toledo

Department of Neighborhoods. This data is only for the city of Toledo and does not include any

abatement that the Lucas County Health Department might have processed. This information was

received in 2010, and new data has not been available since that time.

ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 33

A scholarly journal called Public Health Reports provided the history of lead paint and the Mahoning

County study.

As stated before, it is important to remember that the CDC’s new reference value for what constitutes a

confirmed case of lead poisoning changed in 2012. Since Ohio has officially adopted the new reference

value of 5 μg/dL, the number of people testing positive for lead will likely increase. Therefore, the

number of confirmed lead poisoning cases is much lower in this report.

Maps used in this report that were not generated using GoogleEarth software are from the Center for

Disease Control, Ohio Department of Health, Lucas County Health Department, and City of Toledo.

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2014. http://www.city-data.com/zipmaps/Toledo-Ohio.html.

City of Toledo. “Housing Market Analysis and Housing Needs

for Special Populations.” Consolidated Plan FY2010-2015. http://www.ci.toledo.oh.us/ and

http://www.ci.toledo.oh.us/LinkClick.aspx?fileticket=jup1CpUKdjs%3D&tabid=393.

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http://toledo.oh.gov/media/36650/2012_-_2013_Final_CAPER_Part_2.pdf.

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ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 34

National Safety Council. “Lead Poisoning.” Accessed June 19, 2014.

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ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 35

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ADVOCATES FOR BASIC LEGAL EQUALITY, INC. | JULY 2014 36

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