Abstract
Lead exposure that occurs from contamination inadvertently brought home from a workplace is known as take-home exposure. Take-home exposures are a public health hazard that adversely affects health equity for families and communities. This article describes coordinated action by agencies in Minnesota to curb lead exposure among children of workers at a facility that produces fishing sinkers and battery terminals. (Am J Public Health. 2022;112(S7):S655–S657. https://doi.org/10.2105/AJPH.2022.306982)
Because lead can cause permanent neurological damage, it is important to prevent lead exposure from all sources, including take-home lead.1–3
In Minnesota, all blood lead level (BLL) test results are reportable to the Minnesota Department of Health (MDH). At the time of the intervention, MDH shared BLLs of 5 micrograms per deciliter (µg/dL) or higher for pregnant people and children aged younger than 6 years with local public health agencies, which provide education and outreach. Children with confirmed BLLs of 15 µg/dL or higher received environmental investigations to determine the source of lead exposure; agencies could choose to provide environmental investigations for children with BLLs of 5 to 14.9 µg/dL.
The Water Gremlin Company manufactures lead fishing sinkers and battery terminals using a variety of processes, including die-casting and extrusion. These processes generate lead dust that settles on surfaces, including floors and workers’ bodies. St Paul‒Ramsey County Public Health (SPRCPH) notified MDH of 12 individual take-home lead cases linked to Water Gremlin Company from January 2018 to September 2019. SPRCPH communicated concerns with company leadership and offered recommendations to reduce take-home lead from the facility. Consultation among SPRCPH, MDH, and the Minnesota Department of Labor and Industry (DLI) highlighted limitations of state statutes for enforcement of take-home lead hazards.
Inspections by DLI in October 2019 found the company was not adhering to its personal protective equipment hazard assessment. Multiple avenues for unnecessary lead contamination and cross-contamination were identified, and safety training was not provided in languages spoken by many of the workers. For example, locker rooms were in the building interior, which required workers to walk through lead-contaminated areas after changing into nonwork clothing.
The objectives for this legal and public health intervention were to require that Water Gremlin provide cleanup for existing take-home lead contamination and make worksite changes to prevent future take-home exposures, identify any additional persons impacted by take-home lead exposure, and ensure workers and families were aware of lead exposure risks.
On October 28, 2019, DLI issued an order temporarily stopping operations at Water Gremlin Company. That same day, the Commissioners of Labor and Industry and Health filed a complaint and motion for preliminary injunction in Ramsey County District Court, stating that Water Gremlin had created a public health nuisance. The Commissioners asked the court to require Water Gremlin to provide testing and cleanup of worker vehicles and residences, conduct worker training in appropriate languages, make worksite modifications, and hire a third party for monitoring.4 The court ordered Water Gremlin to complete those activities.
A local triage center was established for Water Gremlin workers the week of October 28, 2019. Translators were available, and services included free BLL testing for workers and families, unemployment assistance, and job counseling. Free BLL testing was offered at community centers through November 2019.
The court required Water Gremlin to provide names and addresses for all workers from the previous two years. Worker information was cross-referenced with the BLL database from the MDH to conduct additional case finding.
Water Gremlin resumed operations on November 5, 2019, following the first phase of remediation activities.
A certified remediation firm tested and cleaned the cars of workers. Cars had to pass a clearance standard of 40 micrograms per square foot (µg/ft2) through cleaning or replacement of components such as floor mats.
MDH and SPRCPH posted Web sites with information on take-home lead, cleaning homes, and signing up for residential cleanup. Resources included fact sheets, YouTube videos, and hotline numbers in five languages. MDH issued a press release, resulting in extensive media coverage. Local Spanish and Hmong radio stations played announcements about take-home lead. Water Gremlin workers were contacted directly through mailings and phone calls from SPRCPH staff fluent in the workers’ languages.
Water Gremlin Company appealed the requirement to provide testing and cleanup in workers’ homes; the order was upheld by the appeals court on June 1, 2020.5 In September 2021, two families opted in to residential cleanup; no lead hazards were identified.
Water Gremlin Company is located in Ramsey County, Minnesota. Workers speak a variety of languages, including English, Spanish, Hmong, Somali, and Karen. Workers were aged 19 to 70 years; 93% were male.
Identification of cases among children of Water Gremlin workers occurred from January 2018 to September 2019. An injunction was filed in October 2019. A final settlement and consent decree were accepted by the court in October 2021.
There is no known BLL that is safe for children; even low BLLs are associated with decreased intelligence and worse school performance.6–8 This intervention was intended to stop children’s exposure to take-home lead dust from Water Gremlin Company.
At free BLL testing events, 207 people received BLL tests. BLL testing that occurred during October to November 2019 resulted in the discovery of three children living with Water Gremlin workers who had confirmed elevated BLLs (≥ 5 µg/dL). Environmental testing demonstrated take-home lead was the probable exposure source for these children. Records reviews and matching with worker names and addresses resulted in the identification of a total of 24 children over the previous two years with elevated BLLs who were likely household members of Water Gremlin workers, including the 12 children identified by SPRCPH and three newly confirmed cases. Interviews and environmental testing determined take-home lead exposure was not a likely factor for four children. In-home environmental investigations could not be completed for five children.
From November 2019 to May 2022, no additional cases of take-home lead exposure were identified among children of Water Gremlin workers.
A total of 287 workers’ cars were tested; 219 (89%) cars had at least one initial dust wipe result greater than 40 µg/ft2. The highest initial lead level in a car was 42 000 µg/ft2.
For the 180 workers who received BLL tests in both 2019 and 2021, BLLs decreased significantly (P < .001). The average decrease in BLL was 4.2 µg/dL (95% confidence interval = 3.6, 4.8).
Water Gremlin cleaned and sealed floors and constructed a new locker room system. These actions and facility environmental lead levels were monitored by a third party.
No unintended consequences of this intervention have been confirmed. Anyone with concerns about retaliation or improper job termination is referred to the Minnesota Department of Human Rights.
Water Gremlin implemented physical changes to the layout of their facility. These engineering controls are more sustainable and effective than the use of administrative controls and personal protective equipment alone.9
MDH established precedent for declaring a public health nuisance to respond to take-home lead exposure. The Minnesota Legislature amended the Lead Poisoning Prevention Act in 2021, adding authority for MDH and other assessing agencies when an environmental investigation determines that lead in a child’s home originated from another source location. The assessing agency can now require the responsible person of the source location both to perform lead hazard reduction at the child’s home and to remediate the conditions that allowed lead to migrate from the source location.10
This intervention highlights the importance of addressing all lead exposure sources. It established a legal precedent that could be applied in similar cases. Furthermore, the expansion of authority in Minnesota’s Lead Poisoning Prevention Act is the first of its kind in the United States, offering a template that could be adopted by other jurisdictions. Importantly, the cessation of cases of elevated BLLs among children of Water Gremlin workers is an indicator that this public health intervention prevented lead exposure among children.
ACKNOWLEDGMENTS
The authors would like to acknowledge the workers at Water Gremlin, who were working in hazardous conditions to provide for their families. The authors would also like to acknowledge staff and leaders at the Minnesota Department of Labor and Industry for the technical expertise and contributions to this case.
CONFLICTS OF INTEREST
The authors have no actual or potential conflicts of interest.
HUMAN PARTICIPANT PROTECTION
This was a public health response and did not require institutional review board review.
