Lead Coated Copper Metal (LCC): A Case Study of Public Health Addressing Regulatory Gaps

Lead coated copper (LCC) has become popular as a stain free replacement for copper in large renovation and new construction projects. The Boston Public Health Commission investigated the home of a child with an elevated blood lead level (EBLL) of 11ug/dl. LCC was used on the roof, flashing, and a wall around the ground floor patio. The condominium interior was free of lead hazards. Sampling found lead dust levels of 224,377 mgs/ft2 wiped from the wall, 36, 441 mg/ft2 on patio, 79,400 mgs/ft2 under the roof drip line, and 11,517 mgs/ft2 at a roof drain to the patio indicating that the LCC was the probable source of the EBLL. Roof areas receiving runoff from the LCC had high lead levels while others had low levels. This presented a unique problem because LCC is not paint and thus not addressed by the Massachusetts Lead Law. Using the Massachusetts Public Health Nuisance Laws, an Abatement Order was issued to remove the LCC, but stayed for six months pending study by all parties. The LCC wall was removed, but roof runoff still contaminated the patio and building perimeter. An encapsulant paint is being investigated to abate lead hazards by covering the LCC roofing. A survey found widespread use of LCC in Boston buildings including hospitals, universities, daycare centers, libraries, office buildings, hotels, and residences. A Public Health Advisory was issued, the manufacturer removed LCC from the market, and city policy was developed to restrict the use of LCC on city-owned buildings.