RESEARCH


National Policy, Standards, Legislation & Enforcement

STANDARDS, LEGISLATION AND ENCFORECEMENT ISSUES

Mr. Don Ryan

I appreciate the opportunity to provide the NGO perspective at this conference. Experience has shown in country after country that achieving progress on lead poisoning requires partnerships among government, the private sector, and NGOs. The Alliance that I represent is a leading policy and advocacy public interest organization dedicated to lead poisoning prevention. The Alliance was formed in 1990, with an initial focus on dealing with lead-based paint hazards in housing, the major cause of childhood lead poisoning in the US. The compelling global nature of lead poisoning prompted an early expansion of the Alliance's mission.

  • In 1992, we surveyed the Global Dimensions of lead poisoning in a report done jointly with the Environmental Defense Fund.
  • In 1994 we convened the First International Lead Poisoning Prevention Conference.
  • We have been instrumental in gaining commitments to lead poisoning prevention in several international fora: UN Commission on Sustainable Development; Habitat II; and Summit of the Americas.
  • We are now working with NGO's in many countries and will soon have in place an electronic network to link local advocates to share information on best practices on policies and programs for prevention

I welcome Dr. George's decision to focus the final day of this conference on developing an Action Plan. I can personally testify to the power of action plans. When the Clinton Administration first took office in 1992, the Alliance's national action plan helped make lead poisoning an Administration priority. Our International Action Plan provides a policy framework for prevention strategies, identifies the roles and responsibilities of different disciplines and sectors, and highlights the complementary efforts needed at the international, regional, national, and community levels. Several other countries have found this Action Plan helpful. Perhaps, this Plan can provide ideas for India as well.

Where Is India Now on Lead Poisoning Prevention?

This morning, I want to provide an advocate's view on where India now stands and offer a few thoughts for your consideration in developing India's Action Plan. At the outset, I must tell you that I am surprised and encouraged at how far India has come in the past 2-3 years. Project Lead-Free has demonstrated forcefully that India has a serious lead poisoning problem. Of course, the data are not complete or perfect -- they never are. But the point is that you have already collected sufficient data to demonstrate convincingly that India has a serious lead poisoning problem.

I was also surprised by the level of consensus and the clarity of understanding of the sources of lead poisoning in India. The priorities, as I heard them in workshop discussions are: leaded gas first and foremost, followed by (in some order) battery recycling, jewelry production, surma and home remedies, and glazes and paints. You now have a very good grasp of what the sources are, and in each case, you have a clear understanding of what control measures are needed. The challenge now facing India is to shift energy and attention beyond blood lead screening and surveillance to primary prevention by taking bold action to control significant sources of exposure.

In most of these cases, the government has the power to correct the problem, but the Government of India by all accounts places little urgency on lead poisoning and is not responsive. The general population seems to know and care little about lead poisoning. India also apparently has a limited tradition of broad-based environmental or consumer movements.

Another important factor is that India has many other public health and environmental problems, -- each of which at some level competes for resources and attention against the others. So what will it take to break this circle of policy paralysis? First, a problem with achievable solutions. Second, a problem whose solutions provide broader benefits. That's why I believe that lead poisoning prevention offers a logical starting place for India to make advances in environmental and public health.

What Is an Action Plan?

Action Plans mean different things to different people. I believe that an effective Action Plan needs to provide both a long term vision of what success looks like as well as identifying the strategic next steps for the near term. The Action Plan's time horizon must be long enough not to disqualify strategies that will take several years to implement. At the same time, the Action Plan needs to identify the next steps that are needed now to break the equilibrium.

The Action Plan needs to be focused on the ultimate goal: primary prevention through source control. The elements of the plan then need to serve - and must be continually checked against - that primary prevention goal. Screening and research may remain important strategies. But in the future, these activities will need to be designed and executed to serve the larger strategic objective of primary prevention.

Obviously, elements of the Action Plan need to address each of the major sources of exposure. You all know more than I do about the nuts and bolts that are specific to India. I want to offer one general word of warning and suggest seven generic strategies that I hope you will make part of your Action Plan. First, I want to urge you to avoid falling into the trap of pitting one source against others. In country after country, industry has paralyzed prevention efforts by playing one source against another. The truth is that all major exposure sources are important and all lead exposures are additive. Of course you must set priorities, but you also need to build in the flexibility to identify and respond to opportunities as they are created to control lead exposures.

Now let me turn to the crosscutting strategies that will help to ensure the relevance of your Action Plan as a lever for change.

1. Expanding the Base

Historically, those involved in the health and medical sectors have provided the leadership in lead poisoning prevention - and the mix of people in this room reflects that reality. You all have seen the tragedy of lead poisoning first hand and each of you cares deeply about protecting children from exposure to lead. At the same time, I think that each of you here today realizes that you yourselves don't have the power to effect change. So, first and foremost, your Action Plan needs to identify strategies for expanding the constituency of support for lead poisoning prevention.

If you all don't have the power to force source control, then you need to identify whom you need to recruit as allies. Just consider what could happen if the people in this room used your credibility, leverage, and contacts to convince the computer industry in India to get behind lead poisoning prevention. If the computer industry cared, think how much faster the Government would be likely to respond. Imagine how much faster India could achieve source control.

The allies you recruit need to be strategically selected based on the control strategies that are your priorities. You may not know it, but you have a powerful ally in phasing out leaded gasoline, the auto industry. Auto manufacturers seem to have difficulty finding the voice to forcefully express their interest in leaded gas phase-out You can help them. Think of other groups that have power and credibility: schoolteachers, university students, labor organizations, religious groups.

2. Press Strategy

The Action Plan also needs to have a press strategy, not simply to draw attention to lead poisoning as a problem, but to engage the press in issues related to source control. The George Foundation has done a tremendous job in directing the media's attention to India's lead poisoning problem. But I must prepare you: by the end of this week, the fact that India has a lead poisoning problem will be "old news." Keeping lead poisoning in the press will require focusing attention on control actions - and building pressure for government policies and programs and private industry responsibility. The press needs substantive stories related to source control; they need controversy; they need villains; they need irony; and all the rest. You already know the stories that need to be told. You just need to make it easy for the press to provide them in depth and in responsible coverage.

We have found in the US that statistics on lead poisoned children and prevalence rates grow stale quickly. In the US, framing lead poisoning in terms of children's learning and success in school has proven the best way to reach key audiences. You need to decide if this is the best context for India - or if it should be the loss of human capital, or sustainability, or national competitiveness in the 21st century. Whatever you decide, you need to find ways to make the problem vivid: What percent of the children starting school in each city have previously been lead poisoned? How many million IQ points has lead poisoning cost India this year?

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3. Education Strategy

The Action Plan also needs an education strategy. I would urge you to think of education broadly. So often education is viewed narrowly in terms of trying to change individual behavior. While clearly there is a need for that, education can also be aimed at broadening the constituency for prevention - educating policy makers to change their behavior - and building pressure on government and private companies. So I would urge you to think about education as a vehicle for policy change and constituency building, not simply for changing individual behavior.

4. Leaded Gasoline Phase-Out as a Strategy

Obviously, leaded gasoline phase-out must be a top priority of the Action Plan, and a variety of strategies are needed to ensure rapid phase-out. But your Action Plan needs to make strategic use of leaded gasoline phase-out to advance other longer-term prevention goals. Leaded gasoline provides the opportunity for a clear and early victory, and movements need victories to build momentum. Leaded gasoline phase-out also provides the opportunity for building broader networks, recruiting new allies who will then continue in the movement.

Leaded gasoline phase-out is also the first step in much larger journey, because eliminating lead in gasoline is a prerequisite to introducing catalytic converters and improved engine technology - advances that can reduce auto emissions by up to 90%. So I would urge you to think creatively about how to use leaded gasoline phase-out strategically to serve these larger goals. Start by framing the challenge not simply in terms of removing lead but in terms of clean fuels that improve engine performance and fuel economy while reducing aromatics and other emissions. India needs modern automobile emissions controls just as much as you need to eliminate tetraethyl lead.

5. Local Crisis Strategy

While some lead exposures in India, such as leaded gasoline, are countrywide, others are intensely local. Your Action Plan therefore needs to have a strategy for responding to lead poisoning "hot spots" caused by local sources. The Action Plan should address not only the services that need to be provided (by the Government or others) to respond to and treat children's lead exposure, but also advocate strategies that will mobilize action to control localized sources. In highly exposed communities, the Action Plan could encompass community needs and resource assessments as a way of engaging local leaders and building local constituencies for prevention. Most political systems respond faster to local pressure.

6. Transnational Strategy

I would hope that your Action Plan would also take advantage of outside forces and opportunities to move India to prevention. For example, you may be able to pressure the Government of India to live up to international agreements related to lead poisoning prevention. The Alliance is now pursuing regional strategies for lead poisoning prevention. Initially, we have been concentrating on Latin America. The multiple opportunities presented by this conference allowed us to convene a meeting in Bangkok last week of NGO, government, and private sector representatives from nine countries to focus on source control policies. I would also hope that advocates in India will participate in the Alliance's international electronic network focused on best practices for advancing source control.

7. Boldness Strategy

Finally, I want to urge you to think boldly in this Action Plan and in your advocacy. This Action Plan provides the chance for some of you to use the other side of your brains - to be wildly creative - to think outside the box. In the brainstorming mode last night, a few of us came up with three ideas:

  • What is the primary reason that 50% of children in India's cities are lead poisoned? You all have told me again and again: leaded gasoline. And who makes leaded gasoline? The sole remaining major manufacturer of tetraethyl lead is a British company named Octel. Your Action Plan could call for a lawsuit on behalf of these victims, not only to seek damages for their injuries but also to provide remedies and resources for prevention. That would help to focus national and world attention on fuel additives, air quality, and human health.
  • For three days, I have heard about how difficult it will be to educate India's population about the dangers of surma, which has been in use for 1,500 years. Instead of relying on convention health education strategies, your Action Plan could demand that the Government of India simply ban surma. "Impossible!" you say. "Too controversial?" Keep in mind that sometimes, controversy can be constructive. I dare say that the media's coverage of the controversy over "300 elite scientists demand that the Government of India ban on surma" would be more effective in getting out the word about surma's dangers than 10 million brochures and family education home visits.
  • Here's another wild idea: your Action Plan might promise some grand prize to the first oil company to phase out leaded gas and replace it with a clean fuel that improves fuel economy and performance without adding other metals or increasing aromatics. Remember, advocacy doesn't always mean throwing punches. Applause can sometimes be a powerful tool.

In closing, I want to note that the Action Plan needs to address resource and organization issues related to its own implementation. If you really want to make these things happen, then you need to assess the resources required realistically. Implementing this kind of Action Plan aimed at primary prevention through source control will require several full-time staff, at a minimum. These staff should not be doctors or scientists, but they need to know how to use your doctors and scientists for maximum impact. Based on your Action Plan's strategies and objectives, you will have to decide on needs of the staff. But you might begin by considering an environmental lawyer, a community organizer, and a media advocacy expert as a starting point.

The Action Plan also needs to deal with issues of organization, structure and

accountability. The George Foundation has put lead poisoning on the map in India, but

Dr. George cannot do this alone. To implement an Action Plan for preventing lead

poisoning across India, an organization is needed that reflects a central focus on primary

prevention through source control and the broader base of support needed to achieve this

goal. I urge you to be ruthless in skeptically examining any and all activities that might

distract from primary prevention: you must not allow screening or surveillance or even

the treatment of lead-poisoned children to stand in the way of primary prevention. Those

activities are also important, of course, but the Action Plan must be focused on

success of source control.. All of the Plan's strategies need to serve this goal.

That is my vision of an Action Plan for Preventing Lead Poisoning in India. As a group, you will need to decide together how your Action Plan will advance advocacy and action to achieve prevention through source control. In any event, the Action Plan needs to be explicit about its focus and objectives. If your Action Plan tries to be all things to all people, it is doomed to disappoint everyone.

And then each of you individually needs to decide whether or not this is your "cup of tea." For many of you, the answer will be "No," which is fine. In addition to advocates for prevention, lead poisoning needs good clinicians and scientists and researchers. But from listening and talking to many of you over the past two days, I know that many of you do have the desire and the passion to reach beyond your clinics and your laboratories and step beyond your "day jobs" to become powerful advocates for prevention.

In this room today are the seeds of a movement broad enough and powerful enough to place lead poisoning on India's national agenda and to hold the government and private industry accountable for source control. Dr. George has created a tremendous opportunity with this conference. The stage is now set for lead poisoning prevention to begin in India. I urge you to step forward and join in taking responsibility to achieve this goal.

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