The American Coatings Association (ACA) late last week lodged a formal complaint with the U.S. Environmental Protection Agency and U.S. Department of Housing and Urban Development (HUD), objecting to a public-service ad campaign about the new federal-lead-safe rule—the EPA’s “Lead-Safe Renovation, Repairs and Painting” rule.
In its formal complaint—called a “Request for Correction of Information” (RFC)—the ACA urged the government agencies “to withdraw from the campaign altogether unless the images are revised to meet basic information quality standards and to conform with depictions and imagery the agencies are using in major public-information campaigns dedicated to public lead safety and childhood lead-poisoning prevention.”
The new lead-safe rule, which went into effect in April, requires lead-safe certification of renovators and companies that disturb six square feet of interior paint in a home, school, or day care center built before 1978. The rule has generated harsh criticism from several industry associations, and the ACA has attacked the accompanying public-service ad campaign.
The ACA has called the public-awareness campaign—which targets parents and caregivers in order to increase compliance—“dangerously misleading.” In a May 20 letter to association members, ACA President Andy Doyle said the campaign’s “visual depictions of the industry's products being poured onto cereal or into ‘sippy cups’ or baby bottles are completely inappropriate, as these products have never been intended to be ingested or used in this manner. The use of such visuals is completely without merit and improper.” He said the public service announcements “wrongly and unfairly imply that paint currently contains lead.”
Doyle repeated those criticisms in a letter to the Coalition to End Childhood Lead Poisoning, the EPA, and HUD. EPA and HUD have run the PSA campaign in cooperation with the coalition and the Ad Council.
In the formal complaint filed last week, the ACA reiterated those arguments, and ACA Vice President and General Counsel Thomas Graves added, “Without question, the legitimate goals stated by EPA and HUD for their partnering with the lead PSAs are obviously distorted by their obvious lack of fundamental information quality and integrity.”
Graves said advertising images “designed admittedly to be ‘arresting,’ sending the wrong message, cannot be effectively relied on by the appropriate targeted audiences; they purposely undermine the concerted progressive and effective campaigns to eliminate childhood lead poisoning by public/private partners alike.”
The ACA said in its complaint that The Request for Correction of Information (RFC) is a mechanism established by the federal Office of Management & Budget (OMB), which in 2002 mandated that each federal agency publish its own Information Quality Guidelines “setting up this process in furtherance of the Information Quality Act of 2001.”
The ACA said it received a letter June 9 from EPA, HUD, the Coalition to End Childhood Lead Poisoning, and the Ad Council in response to the association’s objections to the PSA campaign. The association said the four partner organizations replied that the PSAs are intended to “motivate” parents and caregivers to visit the campaign website, that the PSAs are scientifically based, and that “the general public understands that the campaign targets old lead paint.” The PSAs can be viewed at http://multivu/prnewswire.com/mnr/adcouncil/43516/.
In a formal complaint to EPA and HUD,the ACA offered no additional comment on the letter from the partners in the PSA campaign.
The association also said in its complaint that other organizations have submitted letters voicing opposition to the PSAs. The International Dairy Foods Association called the PSA visuals “denigrating and mislead consumers with regard to the benefits of milk.” Also submitting protests were SSPC: The Society for Protective Coatings, the Painting and Decorating Contractors of America (PDCA), and The Association of Food, Beverage and Consumer Products Companies.