EPA and Partners Defend their PSA Campaign, Despite Objections from ACA and Others; ACA Lodges Complaint and Requests Correction of Information


On June 9, ACA received a letter from the U.S. Environmental Protection Agency (EPA), the U.S. Department of Housing and Urban Development (HUD, the Coalition to End Childhood Lead Poisoning, and the Ad Council in response to ACA's objections to their recent public service announcement (PSA) ad campaign. In its letter, the four partner organizations stated 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 may be viewed at


The association believes the print and video information and depictions used in the PSAs are dangerously misleading and wholly misrepresent the coatings industry and its products. Instead of focusing on proper work practices, including the hiring of a qualified contractor or educating consumers — which is now required by a U.S. EPA final rule that became effective in April — ACA has noted that the PSAs wrongly and unfairly imply that paint currently contains lead. ACA deems the visual depictions of the industry's products being poured onto cereal or into "sippy cups" or baby bottles are completely inappropriate, without merit, and improper, as industry’s products have never been intended to be ingested or used in this manner.


"Without question, the legitimate goals stated by EPA and HUD for their partnering with the lead PSAs are actually distorted by their obvious lack of fundamental information quality and integrity," said Thomas Graves, ACA vice president, general counsel, and corporate secretary. "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."


Other organizations have also voiced their opposition to the campaign through written letters. The International Dairy Foods Association wrote a letter to the Coalition to End Childhood Lead Poisoning (copying the other partners in the campaign) objecting to the ads, noting that the visuals are denigrating and mislead consumers with regard to the benefits of milk. Additional letters of opposition have been sent to the campaign partners from The Association of Food, Beverage and Consumer Products Companies, the Painting and Decorating Contractors Association, and the Society for Protective Coatings.


On June 16, ACA lodged a formal complaint called a "Request for Correction of Information," with HUD and EPA's respective Information Quality Guidelines Offices. In 2002, each federal government agency was required, by the federal government's Office of Management and Budget (OMB), to publish its own guidelines setting up this process in furtherance of the Information Quality Act of 2001. ACA's complaint chiefly repeated its conviction that the PSAs violate the information quality elements of objectivity, utility, and integrity, as set forth as guiding principles by OMB and the respective agencies themselves. ACA urged the 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.


ACA has also addressed the issue on a grassroots level, reaching out to individuals through its CoatingsConnect program and garnering the support of officials in Washington state, where the Manager of Lead Programs has refused to allow the ads on the agency's websites. She is encouraging other such agencies in her region to do the same.


ACA is awaiting response to its RFC from the agencies.




For more information: contact ACA's Tom Graves -



Date Posted: June 17, 2010