EDF Health

Lead service line inventories – Indiana as a good model of a voluntary survey

Tom Neltner, Lindsay McCormick, and Audrey McIntosh

This blog is part of a series focused on how states are handling the essential task of developing inventories of lead service lines (LSLs) and making them public. The first blog identified 14 states that were taking on the issue: 4 with mandatory programs and 10 with voluntary. The second blog described programs in four states that mandate an inventory. In this blog, we highlight Indiana’s 2016 voluntary survey of utilities operating community water systems (CWSs) as a model because it ask utilities to: 1) identify who owns the line and provide the legal basis for that claim; and 2) rate its confidence in its estimates on a 1 to 10 scale. 

We found no other state survey asked about LSL ownership even though it is a central question in determining who is expected to pay for replacement. The Environmental Protection Agency’s (EPA) National Drinking Water Advisory Council (NDWAC) recommended[1] in 2015 that the agency require utilities to provide states this information as part of a revised Lead and Copper Rule (LCR). Unfortunately, 43% of the 781 CWS did not respond to Indiana’s survey, revealing a serious limitation of voluntary surveys.

In January 2016, a month before EPA encouraged states to develop an inventory of LSLs and make it available to the public, the Indiana Department of Environmental Management (IDEM) sent a two-page survey to utilities that operate CWSs in the state asking about drinking water service lines. The agency posted scanned PDF copies of the individual responses online but has not yet released a summary.[2]

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Mandatory lead service line inventories – Illinois and Michigan as strong models

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

This blog is part of a series focused on how states are handling the essential task of developing inventories of lead service lines (LSLs) and making them public. The first blog identified 14 states that were taking on the issue: four with mandatory programs and ten with voluntary.  In this blog, we explore the four mandatory programs and highlight Illinois and Michigan as strong models for other states to consider.  Updated 11/3/18 to reflect updated estimates from Illinois.

Four states – California, Illinois, Michigan and Ohio – require utilities that operate community water systems (CWSs) to identify and report to the state in some form their number of lead service lines (LSLs). Illinois and Michigan both have strong approaches that could serve as models for other states and EPA to require nationally. California’s approach is seriously flawed because it ignores part of the service lines and can be misleading. Ohio requires utilities to either report they have zero LSLs or provide maps where the LSLs are likely to be found, with no requirement to provide an estimated number. We explore all of these approaches below.

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Developing accurate lead service line inventories and making them public: Essential tasks

Tom Neltner, Lindsay McCormick, and Audrey McIntosh

This blog is the first in a series focused on how states are handling the essential task of developing inventories of lead service lines (LSLs) and making them public.

Most communities have a general sense of how many lead service lines (LSLs) they have and what neighborhoods have them. The utilities that manage these community water systems (CWSs) base their estimates on installation and maintenance records, size and age of the service line, and professional experience supplemented with field investigations. It is the 80:20 rule in action; most utilities know enough to scope out the problem, develop a strategy, and set broad priorities.

Utilities hesitate when they are expected to provide precise numbers or say with confidence whether a specific address has or does not have a LSL. It is especially difficult for older neighborhoods where records are particularly weak and there are long histories of repairs.

It takes leadership for utilities to share what they know – and don’t know – about LSLs with their customers and the public. They need to be prepared for questions, including why they don’t know more and what they plan to do to remove the lead pipes. Sharing the information with state regulators and the Environmental Protection Agency (EPA) brings additional scrutiny, especially if they claim they have zero LSLs.

For these reasons, EDF applauds leaders such as Boston, MA; Washington, DC; Cincinnati, OH; Columbus, OH; Evanston, IL; Providence, RI; and Pittsburgh, PA that have address-specific maps available online showing what is known and not known about each customer’s service line. We encourage you to check out their maps. In the coming months, we will share a study EDF recently conducted that evaluates consumer reactions to various approaches to online maps to help guide communities planning similar efforts.

An accurate, publicly-accessible inventory of LSLs was a key element of the National Drinking Water Advisory Council’s (NDWAC) recommendations to EPA in December 2015 for its overdue revisions to the Lead and Copper Rule (LCR).[1] Two months later, EPA sent letters to each governor and state environment/public health commissioner asking, as one of five near-term actions, that they:

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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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FDA-approved PFAS and drinking water – Q & A on analytical measurements

Tom Neltner, J.D., Chemicals Policy Director, and Maricel Maffini, Ph.D., Independent Consultant

On May 2018, we released a blog highlighting paper mills as a potentially significant source of drinking water contamination from 14 Food and Drug Administration (FDA)-approved poly- and per-fluorinated alkyl substances (PFASs) used to greaseproof paper. We showed that wastewater discharge could result in PFAS concentrations in rivers in excess of the Environmental Protection Agency (EPA)’s 70 parts per trillion (ppt) health advisory level for drinking water contamination for PFOA and PFOS, the most studied of the PFASs. Readers of the blog have asked some important questions highlighted below. We provide our best answers based on EDF’s FOIA request to FDA. See also our Q & A blog on textile mills and environmental permitting

Question 1: Would EPA’s analytical method for PFASs actually measure any of the FDA-approved PFASs in rivers and drinking water?

The answer is “likely no.” To understand why, we first need to explain which chemicals FDA approved and compare those chemicals to the list of 18 specific perfluorinated alkyl acids measured by Method 537, the EPA-approved analytical method used to report on PFASs in drinking water. Acids are only one of many functional groups that can be attached to the fully fluorinated carbons in the alkyl chain.

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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.

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Also posted in Emerging Testing Methods, EPA, Health Policy, Health Science, lead, Public Health, Regulation, States / Tagged , , , | Comments are closed