EDF Health

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 LSLs 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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EDF submits comments for peer reviewers on EPA’s exposure, use and hazard information on five PBT chemicals

Lindsay McCormick, is a Project Manager. Richard Denison, Ph.D.is a Lead Senior Scientist.

Yesterday, EDF filed comments on several draft EPA documents that are part of the basis for developing restrictions EPA is required to impose on five persistent, bioaccumulative and toxic (PBT) chemicals under the 2016 reforms made to the Toxic Substances Control Act (TSCA).  The draft documents are to undergo peer review, and EDF’s comments raise issues we believe peer reviewers need to pay particular attention to.

As required by TSCA section 6(h), EPA last year identified five PBT chemicals (DecaBDE, HCBD, PCTP, PIP (3:1), and 2,4,6 TTBP) that meet the statutory criteria for “expedited action”: By June 22, 2019, EPA must propose a rule to restrict these five chemicals.  Last month, EPA released draft documents for peer review and public comment that summarize available hazard information and assess exposure and use of each of the five PBTs.

Our main points for consideration for the peer review committee are summarized below: Read More »

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Illinois moves forward with critical rules to address lead in water at child care facilities

Lindsay McCormick, Project Manager.

Last week, EDF submitted comments to the Illinois Department of Children and Family Services (DCFS) on the state’s proposed rules for lead in water testing at licensed child care facilities. Our comments focused on what we learned from our pilot in 11 child care facilities, including 4 in the Chicago area.

Even at very low levels, lead can impair brain development, contributing to learning and behavioral problems as well as lower IQs. While national attention on lead in drinking water has spurred action in schools, few states have addressed lead in water in child care settings – even though these facilities serve children at younger, more vulnerable ages.

Illinois is one of seven states that EDF has highlighted in a previous blog for requiring lead in water testing in child care facilities. In January 2017, Illinois General Assembly enacted SB550, establishing a new set of requirements to address lead in drinking water in the state. Under the legislation, Illinois was required to adopt rules prescribing the procedures and standards to assess lead in water in licensed day care homes, day care centers, and group day care homes (herein after “child care facilities”). Read More »

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New report: Tackling lead in drinking water at child care facilities

Lindsay McCormick, Project Manager, Sam Lovell, Project Specialist and Tom Neltner, J.D.Chemicals Policy Director

Recent crises around lead in drinking water have focused national attention on the harmful effects of children’s exposure to lead. While the particular vulnerability of children to lead is well understood by most – what might be surprising is that the majority of child care facilities are not required to test their water for lead.

Only 7 states and one city have such regulations on the books. And while the Environmental Protection Agency (EPA) has provided a voluntary guidance, the “3Ts for Reducing Lead in Drinking Water,” for schools and child care, the document has significant gaps in the child care setting – including an outdated action level of 20ppb and little emphasis on identifying and replacing lead service lines.

Given the critical need for more investigation in this area, we conducted a pilot project to evaluate new approaches to testing and remediating lead in water at child care facilities. EDF collaborated with local partners to conduct lead in water testing and remediation in 11 child care facilities in Illinois, Michigan, Mississippi, and Ohio. We have previously blogged about some early takeaways from testing hot water heaters and our preliminary findings from the project. Today, we released our final report, which provides the full results of the pilot and recommendations to better protect children moving forward.

Read More »

Posted in Drinking Water, Emerging Testing Methods, EPA, Health Policy, Health Science, lead, Public Health, Regulation, States / Tagged , , , | Comments are closed