The LEAD Group proposals on Blood Lead Levels rejected by NHMRC

Letters from The LEAD Group to the Federal Health Minister, and to NHMRC; a summary of NHMRC’s response, and The LEAD Group’s reply

In December last year, The LEAD Group wrote to the Federal Health Minister, the Hon Nicola Roxon, with a proposed new policy on Blood Lead Levels for Australians. The Minister passed on the letter to the National Health and Medical Research Council of Australia (NHMRC), the body responsible for making health recommendations. NHMRC rejected the proposals.

December 03, 2010 10:15 AM

Dear Minister,

A new policy on lead poisoning has been developed by The LEAD Group, aimed at the National Health and Medical Research Council of Australia (NHMRC).

The policy is for adoption by NHMRC, which would then recommend it to National and State health ministers. It is supported by an impressive 47 page background document which provides the weight of evidence (including 12 pages of references) to convince the NHMRC to improve on its current policy. [Please click on the links to see what’s being proposed and why.]

The policy is a radical departure from the practice of setting ‘goals’ and ‘targets’ for blood lead levels. Instead, it proposes ‘individual action levels’ for anyone with a blood lead level exceeding that of 95% (the 95th percentile) of others in their population group.

The starting point for the new policy is the present ‘world’s best practice’ adopted by Germany in April 2010.

Under the German policy, selected sub-populations are tested for their blood lead levels. The level which 95% of those in the sub-populations are at or below becomes the target for the remaining 5% of that sub-population to achieve.

The Germans do a blood lead study and then ensure, through action for those individuals in the top 5% of blood leads, to gradually bring their blood lead down to a safer level.

Their current action level for children is around one third of the goal anywhere else, including in Australia, and less than one quarter of the action level in NSW and Victoria.

A proposed long-term study of adults would likely verify US research findings that correlate lead exposure with early death.

Amongst the many proposals: that vets be educated to the fact that a pet with lead poisoning is the ‘canary in the mine’ for the household where the pet lives; that doctors be asked to use a questionnaire to decide which of their patients should be tested for lead.

The policy recommends research into the effectiveness of pectin, Vitamin C and other ‘lead-clawing therapies’, which drag lead out of the body. Determining the effectiveness of such therapies has the potential to help millions to live longer and healthier lives. All of us older than 8 years were exposed to the Australian lead that goes into leaded petrol and still goes into AvGas.

The current NHMRC policy (Public Statement) sets a blood lead goal, but requires no action on the part of public authorities or the medical establishment to achieve it. The LEAD Group’s model policy requires action.

Can you please ensure that the NHMRC adopts the basic principles of this model policy, by first requiring them to organise a national blood lead survey of all ages so that policy-makers can get started on preventing lead poisoning, especially tertiary lead poisoning of our ageing population (whereby the lead in our bones comes out to raise our blood pressure and age our brains)?

On August 22, 2009, internationally renowned lead poisoning expert Professor Bruce Lanphear shone a spotlight for the world on Australia’s lead policy when he wrote in The Australian newspaper:

“Why do public health officials and physicians permit obsolete standards to persist in the face of compelling science?

“Despite proof that reducing the source of lead is necessary to further reduce children's exposure, the NHRMC continues to rely on education -- washing children's hands, dust control -- rather than on reducing industrial emissions or tightening regulations to protect Australian children from lead hazards.”

I was advised over the phone by NHMRC staff on 12 February 2010 that despite being aware that Western Australia had introduced a policy of taking action to locate lead sources, and eliminate them for individual children under 5 yrs of age who have a blood lead level above 5 micrograms per decilitre (half the NHMRC’s 1993 and current goal), that “It's been agreed to annually review the lead level (ie next December it will be on the agenda again) and in the meantime to keep a watching brief and to revise the blood lead goal downwards if there is compelling evidence to do so.”

But when I rang the NHMRC yesterday, I was advised that no meeting, and no public announcement from the NHMRC on lead is slated for December. With the dissemination of our media release on this topic today, you might expect that there will be media interest in your response to this policy and plans to get the NHMRC moving on this issue. The world is watching. If Germany can have a proactive public health policy on lead, surely the world’s biggest lead exporter could take their ideas and improve on them to achieve a model policy for the world.

Today, we also hope to web-publish the attached two lists of references which provide the compelling evidence of the harm that lead does at blood lead levels under 10 micrograms per decilitre. Do you agree that the evidence is compelling, and that Australia need not wait for Canada or the US to lead the way on lead? Both countries are currently reviewing their blood lead targets so now, this month, is your opportunity to be a leader among Health Ministers of the English-speaking world.

Please respond as soon as possible.

Elizabeth O'Brien,
Manager, The LEAD Group

NHMRC rejected the proposed changes. In his reply to The LEAD Group Professor McCallum stated

“NHMRC conducted a search of new literature in late 2010 and found no new evidence compelling enough to warrant revising the BLL at this time.” He concluded by saying that NHMRC “is aware of the majority of the cited articles and references in the GLASS background document including the German model outlined in your correspondence to the Minister…”

The following is The LEAD Group’s reply to Professor McCallum, a copy of which was also sent to the Health Minister:

Professor John McCallum,     3rd February 2011

Executive Director, Health Evidence and Advice Branch,
NHMRC  nhmrc@nhmrc.gov.au
CC: The Honorable Nicola Roxon, Minister for Health and Ageing
Nicola.Roxon.MP@aph.gov.au ; nicola@nicolaroxonmp.com

Re: Proposed new health advice on LEAD. Response to your letter of 5 January, 2011

Dear Professor McCallum,

Thank you for your letter of 5th January 2011 on behalf of The Honorable Nicola Roxon, in response to my letter to the Minister dated 3rd December 2010.

Despite your letter’s reference to the NHMRC’s statement that “10 ug/dL is not the goal and should not be interpreted as either a ‘safe’ level or exposure or a ‘level of concern’, according to http://www.nhmrc.gov.au/publications/synopses/gp3syn.htm - “Annual Review of Scientific Literature: The NHMRC reviews new scientific literature annually to ensure that the Blood Lead Level of concern remains current with the most recent scientific evidence and international best practice. If the scientific evidence is compelling NHMRC will revise the blood lead level of concern.”

In NHMRC’s ‘Findings of October 2010 Review’ also at http://www.nhmrc.gov.au/publications/synopses/gp3syn.htm, it is stated:

‘The 2010 review of the recent scientific literature did not provide sufficient evidence to warrant reducing the blood lead level of concern. Both internationally and nationally the recommendation remains that lead levels should be less than 10 μg/dL’.

Our document was not presented to the Australian government and NHMRC as a LEAD Group policy. The LEAD Group is clearly not a policy-setting body, we can only propose.

In my letter to the Health Minister I said ‘A new policy on lead poisoning has been developed by The LEAD Group, aimed at the National Health and Medical Research Council of Australia (NHMRC).

The policy is for adoption by NHMRC, which would then recommend it to National and State health ministers.

I am aware, and we have stated in the documents, that NHMRC makes recommendations. I have used the word ‘policy’ to refer to what, in its Public Statement, are NHMRC recommendations, the first of which is ‘All Australians should have a blood lead level below 10 µg/dL.’

Our document was designed for review by the Minister’s advisors and adoption, as an improvement on, and replacement of, the information that is accessible from the  NHMRC webpage you cited in your letter and which is titled: “Blood lead levels for Australians” [http://www.nhmrc.gov.au/publications/synopses/gp3syn.htm ] Although your web-team has categorized it simply as “Publications”, the fact that you, as Senior Scientist, Public Health, by dint of being the person chosen by the Minister to answer my letter, means you ARE, de facto, the Minister’s advisor on this issue and thus the “Publications” that you have referred me to, are, de facto, the current Policy on lead. Or are you saying that the Australian Department of Health and Ageing has NO policy on lead? In other words, if the NHMRC’s “Publications” on lead are not the Policy, then where is the Department’s lead Policy to be found and who makes it?

To avoid further semantic stumbling blocks, I am happy to change the word ‘Policy’ to ‘Advice’. You have stated that NHMRC provides Advice to the government and the community. I can change the names of our documents to “Model Australian Public Health Advice on Lead” and “BACKGROUND to the Model Australian Public Health Advice on Lead” and ask that you now consider them afresh.

For example, our document suggests a raft of recommendations for NHMRC to make to agencies such the Department of Sustainability, Environment, Water, Population and Communities (DSEWPaC), and Customs (Australian Customs and Border Protection Service), which would reduce lead exposure, and thus help achieve NHMRC’s existing recommendations. I am disappointed that these recommendations are apparently to not even be considered because NHMRC ‘does not have a policy setting or regulatory role.’

I observe that the difference between NHMRCs current Advice on Lead and The LEAD Group’s (not GLASS’s) Proposed Advice on Lead is that our proposals involve NHMRC recommending action on the part of many stakeholders, whereas the current Advice leads to “business as usual” or no action taken by anyone. Our proposals are for the systematic reduction of blood lead levels, starting with surveys to determine what the blood lead levels actually are in specific sub-populations, then setting about lowering the levels of those within each sub-population to the level of the 95th percentile of that sub-population.

We did not say that NHMRC has a regulatory role.

When we stated:

“The NHMRC ‘Blood Lead Levels for Australians Information Paper for Practitioners and Policy Makers 2009’ still states 10 micrograms per decilitre (μg/dL) of blood as their recommendation for the Australian blood lead level (NHMRC, 2009)” [Ref: https://lead.org.au/Model_Australian_Public_Health_Policy_20101203_Background.pdf ] we were simply re-stating, using the term recommendation instead of goal, the following sentence: “It was never intended that this goal of 10 μg/dL be interpreted as either a ‘safe’ level of exposure or a ‘level of concern’”. [Ref: http://www.nhmrc.gov.au/_files_nhmrc/file/publications/synopses/gp02-lead-info-paper.pdf ]

Two other sentences repeated this “goal of 10 μg/dL” concept taken from NHMRC’s document. We can change them: “The LEAD Group Inc. strongly believes that the current recommendation of 10 μg/dL for Australia‟s blood lead level is too high;” and “This level is above the current NHMRC recommendation of 10 μg/dL” [Ref: https://lead.org.au/Model_Australian_Public_Health_Policy_20101203_Background.pdf ]

I am disappointed that NHMRC, being, as you say ‘aware of the majority of the cited articles and references in the background document including the German model’, should feel there is nothing ‘to warrant revising the BLL at this time.’ The concept behind the German model is ‘let’s not argue about how much lead is too much, let’s agree that all exposures (men, women and children) should be minimized, and that action be taken if an individual exceeds the 95th percentile blood lead level of their subpopulation, as determined by a national survey.’ 

Since I wrote to the Minister, and probably since the 21/12/10 review of your lead publications synopses page, the World Health Organisation (WHO) has stated at http://www.who.int/ceh/publications/leadguidance.pdf :

“Recent research indicates that lead is associated with neurobehavioural damage at blood levels of 5 μg/dl and even lower. There appears to be no threshold level below which lead causes no injury to the developing human brain. The Joint FAO/WHO Expert Committee on Food Additives re-evaluated lead in June, 2010 and withdrew the provisional tolerable weekly intake guideline value on the grounds that it was inadequate to protect against IQ loss.”

[The WHO document is dated 2010 but The LEAD Group and other lead-concerned NGOs globally were advised by WHO’s Dr Ruth Etzel by email on 22/12/10 that it had just been published.]

If it is good enough for WHO to review downwards their various recommendations in relation to lead, surely this should inspire an NHMRC review prior to the scheduled annual review. Please reply to this letter to let me know what you plan to do and when the next NHMRC lead review will occur.

Yours Sincerely

Elizabeth O'Brien,

Partner, UNEP Partnership for Cleaner Fuels and Vehicles (PCFV)

Member, WHO/UNEP Global Alliance to Eliminate Lead in Paint (GAELP)

Member, UNEP Chemicals Branch Lead and Cadmium Working Group

President, The LEAD Group Inc., an Australian Health Promotion Charity

Secretary, Australian Dust Removalists Association (ADRA)

PO Box 161 Summer Hill NSW 2130 Australia, Ph +61 2 9716 0014 www.lead.org.au