EDF Health

Denver Water proposes innovative plan to remove an estimated 75,000 lead service lines in 15 years

Lindsay McCormick, is a Program Manager. Tom Neltner, J.D., is the Chemicals Policy Director.

Update (9/10/19): Denver Water is currently taking comment on its final proposal through October 10, 2019.  Denver Water will present feedback received to EPA and CDPHE. If you would like to weigh in, you can submit comments here.”

Yesterday, Denver Water’s board approved its proposed “Lead Reduction Program Plan” to fully replace the estimated 75,000 lead service lines (LSLs) in their system within 15 years.  The plan is an innovative solution that will remove the primary source of lead within Denver Water’s system, while avoiding the use of orthophosphate that can further exacerbate nutrient pollution problems in rivers, streams and oceans, an issue EDF’s Ecosystems team is working hard to solve.

As proposed, Denver Water would fund full replacement of LSLs through water rates, bonds and sales of new connections to the system, hydropower production and other sources rather than have individual property owners contribute.  In addition, the utility’s proposal to provide filters to residents until their LSLs are replaced represents a model other communities should consider based on the effectiveness of their ongoing pilot.  Before implementing the plan, Denver Water will need to receive approval from the Environmental Protection Agency (EPA).

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Why do we know so little about chemical exposures? Emerging technology could disrupt the status quo.

Lindsay McCormick is a Program Manager.

EDF report identifies emerging market for personal chemical exposure monitoring technologies through a first-of-its-kind analysis.

When I first started working at EDF in 2014, I learned a statistic that shocked me: We have human exposure data on less than 4% of the roughly half-million chemicals in commerce.[1] In other words, we know next to nothing about the vast majority of chemical exposures that people were experiencing on a daily basis.

Chemicals are found in nearly all commercial products and serve a foundational role in our economy. Yet this ubiquity comes with its downsides, as some chemicals are hazardous and can find their way into our environment and ultimately end up in our water, land, and air—and in our bodies. Exposure to certain chemi­cal substances have been linked to a variety of adverse health impacts, including reproductive harm, disruption of normal hormone activity, and impaired neurological development in children.

The lack of knowledge about chemical exposures poses a major problem: Without better information on exactly which chemicals individuals are exposed to every day, it is challenging to develop effective policies and interventions to reduce harmful exposures and protect health.

Disrupting the status quo

But what if anyone could use a simple home-delivered kit or wearable device to reveal the chemicals in their environment—and in their body? Such technologies could make the invisible visible—providing individuals, as well as policy makers, businesses, health professionals, and others, with critical information needed to accelerate reductions in the public’s exposure to hazardous chemicals.

In 2017, EDF pursued a Year of Innovation to better understand opportunities to advance the market for personal chemical exposure monitors (PCEMs) – with the ultimate goal of improving public health. As part of this effort, we conducted interviews and convened an expert workshop to identify bottlenecks in the development and use of such technologies.

We learned that a significant gap exists between the demand and promise of PCEM technologies and the current cost or scalability of many of the available technologies today. Experts noted that while there is significant qualitative or anecdotal evidence of demand, a quantitative understanding of the potential market for these technologies is needed to drive a robust market.

EDF took that lesson and embarked on a two-part study to fill this gap.

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EDF to OMB: Ban on methylene chloride in paint strippers must protect workers in addition to consumers

Lindsay McCormick, Project Manager, and Joanna Slaney, Legislative Director

Over 11,000 concerned Americans have sent messages to Members of Congress over the last two weeks to urge EPA and OMB to protect workers – the population at most risk – from methylene chloride in paint strippers.

Today, EDF met with the White House Office of Management and Budget (OMB) about the Environmental Protection Agency’s (EPA) draft final rule on methylene chloride-based paint strippers. We urged the office to ensure the ban on methylene chloride-based paint and coating removers covers both consumer and most commercial uses – as the agency originally proposed.

Removing these deadly products from stores, workplaces, and homes is a critical step to protecting public health. Methylene chloride is acutely lethal. Exposure to the chemical has led to over 50 reported worker deaths since the mid-1980s, more than 40 of which are attributed to use of methylene chloride-based paint strippers. Many more deaths have likely gone unreported. The chemical is also associated with a host of other serious health effects, including neurotoxicity, cancer, and liver impairment.

Despite the facts that workers represent the vast majority of reported deaths and face the highest risks of other health effects, it appears that EPA is poised to finalize a rule that excludes a ban on commercial uses entirely – and will instead merely initiate a lengthy, uncertain process that may lead to certification and training approaches EPA had already considered and rejected as inadequate to protect workers.

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EPA Updates its 3Ts Guidance for Reducing Lead in Drinking Water

Lindsay McCormick, is a Project Manager. Tom Neltner, J.D., is the Chemicals Policy Director.

Earlier this month, EPA released its updated 3Ts for Reducing Lead in Drinking Water Toolkit, which provides guidance for schools and child care facilities seeking to ensure children are safe from lead in water.  The new 3Ts – an update to the agency’s 2006 guidance – is now a web-based toolkit that includes modules, customizable templates, and factsheets.

Overall, the new toolkit is an improvement.  While the protocol itself is largely the same, the new toolkit is more user friendly and written for the non-technical audience, making it more likely that school and child care staff will use it.  EPA has also reframed the toolkit from “Training, Testing, and Telling” to “Training, Testing, and Taking Action” – placing more emphasis on the critical step of addressing lead sources than the previous version.  “Telling” is now integrated throughout the entire toolkit to highlight the importance of communication at every step. The agency has also developed a helpful flushing best practices factsheet, which is a topic that often causes considerable confusion.

In EDF’s June 2018 report on our pilot of 11 child care facilities, “Tackling lead in water at child care facilities,” we recommended EPA update its 2006 guidance to address four key gaps.  The agency has made progress on the two most important of those but leaves the other two unresolved. The most important change to the guidance is that the agency has removed the 20 parts per billion (ppb) action level and instead recommends action whenever there are “elevated lead levels.” While EPA does not define an elevated lead level, a deep dive into the appendix suggests that levels over 5 ppb warrant follow-up. The updated guidance also puts a greater emphasis on the identification of lead service lines (LSLs) and includes LSL replacement as a permanent control measure, though not as an explicit recommendation. Further, the agency did not update the protocol to deal with challenges posed by aerator cleaning and hot water heaters.  Below we explore each of these issues in further detail. Read More »

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Mapping state-level lead service line information: Indiana as a model

Lindsay McCormick, is a Project Manager. Tom Neltner, J.D., is the Chemicals Policy Director.

Developing inventories to document and share what water utilities know – and do not know – about lead service lines (LSLs) with the public is a difficult, but critical, step in creating an effective LSL replacement program.

States can play an important role in collecting estimates of the number of known and potential LSLs for each utility and shaping how that information is communicated to the public. 14 states have surveyed utilities operating community water systems in their state to acquire such information.

States have made this information publicly available through different methods. Some have posted individual utility reports, while others have provided a report summarizing the findings. In analyzing the approaches, we found that no state currently makes the results available in a format that allows the public to easily see the information from multiple utilities.

But in today’s world, people typically expect data to be presented in a visually friendly and digestible format. So as a model, we decided to create a state-level map of LSL information.

Of the 14 states, we found that Indiana has one of the most robust surveys, asking detailed questions about portions of the service line containing lead, information sources checked, and service line ownership on public versus private property.  Further, it has a good response rate for a voluntary survey. While only 57% of systems responded, these systems account for 92% of the service lines in the state – as most non-respondents were primarily smaller community water systems.

EDF acquired a spreadsheet from the Indiana Department of Environmental Management and combined this information with data from EPA’s State Drinking Water Information System (SDWIS) to develop a map of LSLs in Indiana as a model.

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California becomes eighth state to require licensed child care centers to test and remediate lead in water

Lindsay McCormick, is a Project Manager. Tom Neltner, J.D., is the Chemicals Policy Director.

Today, California Governor Jerry Brown signed legislation that will better protect children in the state from the harmful effects of lead exposure. AB 2370, sponsored by Assembly Member Chris Holden and passed unanimously by state lawmakers, sets forth new requirements for licensed child care centers to test their drinking water for lead and use an alternative source if elevated lead levels are discovered.

EDF recently released a report highlighting child care facilities as a major gap in protecting kids from lead in water. As children under the age of six are most vulnerable to harm from lead, these facilities should be prioritized for reducing exposure. Compared to lead in schools, which has garnered national attention, child care has gone relatively unnoticed.

We applaud California for taking this important step to expand its school lead in water testing mandate to include child care. With the new legislation, California joins seven other states that have enacted such requirements. The state’s approach is largely similar to other states but it has an unusual feature – laboratories must directly report results to the state, which then will post the results online. Most of the details – including the definition of an elevated lead level in drinking water that warrants shutting off the fixture – are left to the state’s child care licensing agency to define in rulemaking.   Read More »

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