EDF Health

Every lead service line replaced yields an estimated $22,000 in reduced cardiovascular disease deaths

Tom Neltner, J.D. is the Chemicals Policy Director.

See all blogs in our LCR series.

Using publicly available information from the Environmental Protection Agency (EPA), EDF estimated that fully replacing the 9.3 million lead service lines (LSL) in 11,000 community water systems (CWS)[1] across the country would yield societal benefits of more than $205 billion, or about $22,000 per LSL removed. This estimate is based solely on reducing lead exposure in adults in order to have fewer cardiovascular disease (CVD) deaths over 35 years. It does not include the benefits to children’s brain development.

We submitted our analysis in comments to EPA on its proposed revisions to the Lead and Copper Rule (LCR), the federal regulation that limits lead in drinking water. Given the magnitude of the benefits, we called on the agency to incorporate CVD mortality into its economic analysis and consider strengthening its proposal by requiring full LSL replacement as an integral part of every CWS’s efforts, instead of as a last resort when lead levels get too high.

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A closer look at the environmental justice implications of EPA’s proposed lead in water rule

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

See all blogs in our LCR series.

Household-level changes that depend on ability-to-pay will leave low-income households with disproportionately higher health risks.

 

EPA Environmental Justice Analysis of the proposed rule.

Reviewing a rulemaking docket can be intimidating, especially for a major rule like the Environmental Protection Agency’s (EPA) proposed revisions to its Lead and Copper Rule (LCR), which includes 853 supporting documents and tens of thousands of pages. Though we cannot claim to have read all of the documents, we did a targeted scan of key materials, knowing that they often yield insights and results that are lost in the summary that appears in the Federal Register. 

The effort for us paid off when we read EPA’s Environmental Justice (EJ) Analysis of the LCR proposal revisions (the Proposal), commissioned in response to Executive Order 12898. The Order directs agencies to identify and address, “as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations” in rulemaking. The agency’s contractor essentially found:

  • The current LCR disproportionately impacts low-income and minority populations as they are more likely to live in older housing that has lead service lines (LSLs), the most significant source of lead in drinking water.
  • The Proposal’s corrosion control requirements should help reduce current disparities. Because water treatment is consistent across an entire community, stronger requirements that reduce the ability of lead to leach into water from LSLs, leaded solder, and other sources should mitigate, but not eliminate, the disproportionate burden in homes with LSLs.
  • The Proposal may make disparities worse if it depends on individual household’s ability to pay for LSL replacement (LSLR). The report stated that “Household-level changes that depend on ability-to-pay will leave low-income households with disproportionately higher health risks.”[1]

In the Federal Register notice, EPA glossed over the third point and concluded that the Proposal is “not expected to have disproportionately high and adverse human health or environmental effects on minority populations and low-income populations.”[2] The agency ignores the fact that the Proposal makes no change to the current LCR provisions that rely on a household’s ability to pay when it says water systems are “not required to bear the cost of removal of the portion of the [LSL] it does not own.”[3] We are aware of only a small – but growing – number of communities that have funding options to assist households with the cost of LSLR on private property.

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When it comes to testing heavy metals in food, the result is only as good as the lab.

Tom Neltner, J.D., Chemicals Policy Director and Boma Brown-West, Senior Manager.

“Even though the levels of a metal in any particular food is low, our overall
exposure adds up because many of the foods we eat contain them in small amounts.”

 

Dr. Conrad Choiniere, leader of FDA’s Toxic Elements Workgroup on April 20, 2018

Heavy metals such as arsenic, cadmium, and lead are present in most foods, whether conventional or organic, usually as the result of environmental contamination. Because heavy metals pose significant threats even at low levels, the Food and Drug Administration (FDA) has made reducing cumulative exposure a priority. The Baby Food Council – consisting of Beech-Nut Nutrition Company, Happy Family Organics, Earth’s Best, and Gerber Products Company and supported by Healthy Babies Bright Futures (HBBF), Cornell University and EDF – shares this goal and seeks to reduce heavy metals in the companies’ products to as low as reasonably achievable using best-in-class management practices.

Through the Council, EDF is coordinating a proficiency testing program to enable retailers, food manufacturers, ingredient suppliers, and others to identify laboratories that are capable of measuring arsenic, cadmium, and lead at levels in the low parts per billion (ppb). The Council has arranged for FAPAS, a leading proficiency testing provider for the food and water testing industries, to manage the testing program.

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Which faucets and fixtures have the lowest lead levels? California asks plumbing manufacturers.

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

Until California Water Board publishes its lists of fixtures that leach minimal lead, we recommend that schools and child care facilities routinely flush newly installed drinking water fixtures for several weeks and retest before allowing children to consume the water.

In November, the California Water Board took an important step that should benefit anyone seeking to buy a new faucet, drinking water fountain or other fixture – especially schools and child care facilities. The Board sent letters to more than 300 plumbing manufacturers and certifiers asking them to voluntarily provide information on fixtures that leach minimal lead. Specifically, it seeks to identify fixtures that meet lead leaching limits that are five times more protective than the current limits in the NSF/ANSI 61 standard.

The Board plans to make the compiled responses publicly available and encourage the 14,000 licensed child care centers in the state to buy new fixtures from those on the list when water testing indicates the fixture should be replaced. We anticipate that the Board will utilize the list to identify fixtures to purchase through a $5 million grant program the California State General Legislature established when it enacted AB-2370 last year. The funds are designed to help licensed child care facilities meet the state’s new mandated water testing and remediation program.

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EDF asks EPA to strengthen key lead service line definition, inventory, and notification provisions in its proposed revision to the LCR

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

See all blogs in our LCR series.

Yesterday, EDF submitted comments to the Environmental Protection Agency (EPA) on their proposed revisions to the Lead and Copper Rule (LCR), focusing on changes that EPA should to make to the:

  • Definition of a lead service line (LSL);
  • Requirements for water systems to develop LSL inventories; and
  • Notification of individual consumers who drink water that passes through an LSL.

We highlighted strengths and weaknesses of the LCR in a blog earlier this week, and we encourage states and communities to consider adopting the positive provisions now in addition to the changes we ask EPA to adopt in these comments. Below is a summary of our comments on these three issues. We plan to address other issues on the proposed revisions to the LCR in later comments.

Lead Service Line Definition

EPA’s proposed change to the current definition of an LSL at 40 CFR § 141.2 is flawed because it continues to exempt goosenecks, pigtails, or other connectors made of lead. These connectors are a major source of lead in drinking water not just because they are made of lead, but because they can release significant amounts of lead particulate into water as they flex with temperature, are scoured by turbulent water flow, and as other conditions change.

The exemption of these connectors from the definition of an LSL would render a water system’s LSL inventory and periodic notices to customers misleading because service lines described as “non-lead” may actually have some lead pipe in them. This will give residents a false sense of security. We recommend that the agency modify the proposed definition by deleting the exemption and explicitly stating that goosenecks, pigtails and connectors made of lead are LSLs.

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Despite its flaws, states and communities should get ahead of the curve on EPA’s proposed lead in drinking water rule

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

See all blogs in our LCR series.

In October, the Environmental Protection Agency (EPA) proposed changes to its outdated Lead and Copper Rule (LCR), the federal regulation designed to control those contaminants in drinking water. As the result of more than a decade of work by dedicated agency experts, the proposal makes several improvements to key parts of the rule, including requirements for lead service line (LSL) inventories and customer notification. LSLs are the lead pipes that connect the main under the street to homes and buildings and are the most significant source of lead in drinking water.

Unfortunately, EPA’s proposed rule has several serious flaws, including that it:

  • Continues to treat full LSL replacement as a last resort. The proposed rule should make LSL replacement an integral part of a long-term solution, including periodic benchmarks for all water systems to achieve regardless of water testing results.
  • Continues to allow water systems to conduct partial replacements where the property owner is unwilling or unable to pay the cost for the portion not owned by the water system. Partial LSL replacement may significantly increase lead levels in drinking water for months and does not reliably reduce lead levels in the long term. While water systems would be required to gives residents tools (e.g. advanced notice and filters) to reduce the exposure, more is needed. EPA’s own analysis finds that relying on a resident’s ability-to-pay to replace the LSL on their property to avoid partial replacements will leave low-income households with disproportionately higher health risks.
  • Backslides on the rate of mandatory LSL replacement. When a water system’s lead levels are so high that full LSL replacement is mandated, EPA proposes an annual replacement rate that gives the system at least 33 years rather than the current minimum of 15 years to replace all of its LSLs. While more systems are likely to have to conduct mandatory full LSL replacement because of the stricter sampling requirements, most will not.

EPA is accepting comments on the proposed revisions until February 12, 2020. We are preparing detailed comments calling for the agency to fix the flaws before finalizing the rule, and we encourage others to comment as well.

Despite these shortcomings, we want to highlight four positive elements of the proposed rule and encourage states and communities to consider implementing them now – not just because they are likely to be required in the future – but also because they set the stage for full LSL replacement. These elements are that water systems must:

  • Develop an LSL inventory, update it annually, and make it publicly accessible;
  • Notify customers that they have or may have an LSL;
  • Take precautions when disturbing LSLs; and
  • Sample more homes with LSLs and take earlier action based on the results.

In this blog, we provide an overview of these key improvements. In future blogs, we will describe our recommendations to strengthen the rule based on our comments to the agency.

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