EDF Health

Selected tag(s): Drinking Water

EPA distorts the scientific evidence and fails to protect kids’ brains in its proposed limit for perchlorate in drinking water

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

Today, the Environmental Protection Agency (EPA) proposed a Maximum Contaminant Level (MCL) of 56 parts per billion (ppb) for perchlorate in drinking water – more than three times less protective than an interim health advisory level set in 2008. To justify this increase, EPA turned its back on scientific evidence showing that this potent neurotoxin undermines childrens’ motor development and control and can increase their anxiety and depression. The agency’s reasoning is inconsistent with its own analysis published in a draft report in late 2017 and the findings of a peer review panel it convened last year to review that report.

If the agency had used the most protective scientific study and the most sensitive endpoint evaluated in the proposed rule, the MCL would likely be 4 ppb – more than three times more protective than the current health advisory. As a result, the agency fails to adequately protect children from a lifetime of harm. With this MCL, EPA is allowing pregnant women to be exposed to perchlorate in the first trimester of pregnancy at levels that pose much greater risk of impaired neurodevelopment in their children.

The proposed MCL – and how the agency reached it – was both a disappointment and a surprise to us. In late 2017, we applauded the agency’s scientists for developing an innovative model connecting a mother’s perchlorate exposure in the first trimester to fetal harm. We were not alone – in early 2018, EPA’s peer review panel congratulated the agency’s scientists on their analysis. We also complimented EPA’s population-based approach to developing an MCL by estimating the percent of pregnant women, and their children, with borderline thyroid dysfunction due to low iodine intake.

So how did EPA abruptly change course and estimate an MCL less protective than the current health advisory? By altering its analysis in three subtle but significant ways:

  1. Rejecting five epidemiology studies showing harm at even lower exposure levels in favor of one IQ study by Korevaar et al. in 2016.
  2. Choosing an MCL that allows an IQ loss of 2 points even though the study showed a 1 point loss was statistically significant.
  3. Dismissing an alternative, population-based method that EPA proposed in 2017 that reinforces the need for a more protective standard.

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Posted in Drinking Water, EPA, Health Policy, Health Science, perchlorate / Also tagged , , | Read 1 Response

EPA’s safety standard for perchlorate in water should prioritize kids’ health

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

The Environmental Protection Agency (EPA) will soon propose a drinking water standard for perchlorate. The decision – due by the end of May per a consent decree with the Natural Resources Defense Council (NRDC)— will end a nearly decade-long process to regulate the chemical that has been shown to harm children’s brain development.

In making its decision, EPA must propose a Maximum Contaminant Level Goal (MCLG) “at the level at which no known or anticipated adverse effects on the health of persons occur and which allows an adequate margin of safety.”[1] It must also set a Maximum Contaminant Level (MCL) as close to the MCLG as feasible using the best available treatment technology and taking cost into consideration.

To guide that decision, EPA’s scientists developed a sophisticated model that considers the impact of perchlorate on the development of the fetal brain in the first trimester when the fetus is particularly vulnerable to the chemical’s disruption of the proper function of the maternal thyroid gland. As discussed more below, the model was embraced by an expert panel of independent scientists through a transparent, public process that included public comments and public meetings.

In April, a consulting firm published a study critiquing EPA’s model. The authors acknowledged the model as a valuable research tool but did not think it is sufficient to use in regulatory decision-making due to uncertainties. Therefore, the authors concluded that EPA should discard the peer-reviewed model and rely on a 14-year old calculation of a “safe dose” that does not consider the latest scientific evidence and has even greater uncertainties. They didn’t offer other options such as using uncertainty factors to address their concerns about the model’s estimated values.

Given the importance of the issue and the risk to children’s brain development, we want to explain EPA’s model, the process the agency used to develop it, and the study raising doubt about the model.

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Posted in Drinking Water, EPA, Health Policy, Health Science, Industry Influence, perchlorate / Also tagged , , | Read 2 Responses

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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Posted in Drinking Water, lead, States / Also tagged , , , | Comments are closed

Wisconsin on the verge of taking an important step to replacing its lead pipes

Tom Neltner, J.D.is Chemicals Policy Director

In 2012, Madison, Wisconsin became the first city in the country to fully eliminate its lead service lines (LSLs), the lead pipes that connect the drinking water main under the street to interior plumbing. The project to replace its 8,000 known LSLs began in 2000. The City’s effort is a model of persistence and common sense as it overcame many barriers including challenges with the Public Service Commission of Wisconsin (PSC).

The PSC blocked the use of rates paid by customers to fund replacement of lead pipes on private property. The PSC, whose mission is to ensure adequate and reasonably priced water service, was concerned that customers without LSLs would be subsidizing improvements to the property of those with LSLs. Unlike most state commissions which are responsible for utilities operated by private companies, PSC approves rates for municipal and private utilities. Eventually, Madison used a different source of funding for its $15.5 million LSL replacement program.

Currently, the Wisconsin State Legislature is on the cusp of passing legislation to remove this barrier faced by Madison and empower communities to better protect residents from lead in drinking water. SB-48, introduced by Senator Cowles (R-Green Bay) and co-sponsored by Representative Thiesfeld (R-Fond du Lac), has passed both chambers. When the legislature returns to session in January 2018, they will need to resolve a difference between the two versions regarding the maximum amount of financial assistance allowed to homeowners. To hear from both authors on the legislation, check out the webinar from the National Conference of State Legislatures regarding financing options for replacing LSLs.

With passage of the legislation, Wisconsin would be the fourth state to pass essential legislation empowering communities to replace LSLs, using rates paid by consumers, joining Indiana, and Pennsylvania. They are among 12 states that have adopted administrative or legislative policies to support community LSL replacement.  These states have an estimated 3.3 million of the nation’s 6.1 million LSLs.

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Posted in Drinking Water, Health Policy, lead, Public Health, Regulation, States / Also tagged , , , , , | Comments are closed

Article reveals serious shortcomings in Georgia’s oversight of lead in drinking water

Tom Neltner, J.D.is Chemicals Policy Director

Safe drinking water largely depends on the integrity of the public water system and the vigilance of the state regulatory agency. The U.S. Environmental Protection Agency (EPA) sets the standards, conducts the research, and oversees the state regulatory agencies. As we saw in Flint, Michigan, these protections break down when the state regulatory agency fails to identify and address potential compliance issues. Criminal charges have been filed against both state and local officials.

The Flint tragedy prompted EPA to send letters in February 2016 to governors and state agencies reminding of them of their responsibilities under the Safe Drinking Water Act and asking for a meeting with each state to discuss concerns and a written response to key compliance challenges under the Lead and Copper Rule (LCR). EPA posted the state responses online.

The tap sampling required under the LCR is critical since it triggers treatment of the water for small and medium systems and public education and lead service line replacement for all systems if treatment is insufficient. Given this central role, the LCR requires water systems to take water samples from the taps of properties most likely to have lead. For small and medium systems, single family homes with lead service lines are a top priority.

The sampling requirement is challenging since it depends on the cooperation of the resident to let the water stagnate in the lines for at least six hours and then take a first draw sample before anyone uses the water. Residents may need an incentive to cooperate, especially over many years.

A disturbing, three-part investigative report by WebMD and Georgia Health News provided insight into potential shortcomings by utilities that are likely to underestimate the levels. It also highlights Georgia’s apparent failure to identify the problems. The investigators checked on changes in the sampling sites over the years and looked up the sampling locations to determine if they fit the criteria laid out in EPA’s rule. It is an impressive deep dive into LCR compliance sampling issues.

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New EPA model enables comparison of various sources of childhood exposure to lead

Tom Neltner, J.D.is Chemicals Policy Director and Dr. Ananya Roy is Health Scientist

This week, Environmental Health Perspectives published an important article by scientists at the Environmental Protection Agency (EPA) that sheds important light on the various sources of children’s lead exposure. Led by Valerie Zaltarian, the article shares an innovative multimedia model to quantify and compare relative contributions of lead from air, soil/dust, water and food to children’s blood lead level. The model couples existing SHEDS and IEUBK models to predict blood lead levels using information on concentrations of lead in different sources, intake and gut absorption. The predicted blood lead levels compared well with observed levels in the National Health and Nutrition Evaluation Survey population. Given the variety of independent sources of lead exposure, the model provides a critical tool that public health professionals can use to set priorities and evaluate the impact of various potential standards for all children and not just those with the greatest exposure.

This peer-reviewed article builds on a draft report EPA released in January 2017 evaluating different approaches to setting a health-based benchmark for lead in drinking water. The report has provided a wealth of insight into a complicated topic. Earlier this year, we used it to show that formula-fed infants get most of their lead exposure from water and toddlers from food, while the main source of lead for the highest exposed children is soil and dust. In our February blog, we provided our assessment of a health-based benchmark for lead in drinking water and explained how public health professionals could use it to evaluate homes. The information was also critical to identifying lead in food as an overlooked, but meaningful, source of children’s exposure to lead.

The new article reaffirms the analysis in the January 2017 EPA report and highlights that evaluating source contribution to blood lead in isolation versus aggregating across all sources can lead to very different answers and priorities. A health-based benchmark for lead in drinking water could vary from 0 to 46 ppb depending on age and whether all other sources of lead are considered. For example, a health-based benchmark for infants (birth to six months old) would be 4 ppb or 13 ppb depending on whether or not you consider all sources of exposure.

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Posted in Drinking Water, Emerging Science, EPA, Food, Health Policy, lead, Uncategorized / Also tagged , , , , , , , | Comments are closed