EDF Health

Selected tag(s): Drinking Water

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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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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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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Lead service lines on private property – 3 states’ approaches to the challenge

Tom Neltner, J.D.is Chemicals Policy Director

After the tragedy in Flint, Michigan, there is broad agreement that lead service lines (LSLs) need to be replaced. While corrosion control is essential, it isn’t a fail-safe, long-term solution. With the risks posed by lead to children’s brain development, we must eliminate LSLs – which currently account for an estimated 50 to 75% of the lead in drinking water.

One of the most significant challenges is determining who pays for replacing the portion of a LSL on private property and how it can be done in a way that does not leave low-income residents behind. Most utilities consider service lines on private property to be the responsibility of the property owner. They see replacing customer-owned portions of LSLs as improvements to private property and are typically restricted from using funds collected from all customers to fund an upgrade that benefits only a few. States often impose restrictions as well.

The interpretation that customers are responsible for LSLs on their property is ironic in communities such as Chicago, which mandated the use of LSLs until Congress banned them in 1986.  Given that they had a hand in creating the problem, it seems that they have at least some responsibility in fixing it. The threat posed by lead was well known for decades before Congress acted. Cities such as Cincinnati banned the use of lead pipes in 1927 and Boston in the 1930s.

It is difficult to put responsibility solely on the homeowner since they are unlikely to have been told they have a LSL by the seller. Even if they were aware that their home is serviced by an LSL, the risk a LSL poses to their family’s health is only now becoming clear.

Without support, low-income residents often cannot afford to pay for their portion of the LSL replacement, even if they get zero- or low-interest loans. However, wealthy residents have more options to make the investment than their low-income neighbors and landlords should be making the investment as part of their business.

In December 2016, Congress weighed in and authorized EPA “to establish a $300 million grant program to replace lead service lines on residential property in disadvantaged communities.”[1] It is up to Congress to appropriate the funds as part of its infrastructure investments and ensure that the grant program will not be a hollow promise.

But many states are not waiting on Congress. Three states, Indiana, Pennsylvania, and Wisconsin, have been wrestling with whether to allow communities to use a portion of rates paid by customers to pay for LSL replacements. Collectively, these states have an estimated 690,000 LSLs, 11% of the national estimate. In this blog, we will explore these three state approaches. Read More »

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When it comes to lead, formula-fed infants get most from water and toddlers from food, but for highest exposed children the main source of lead is soil and dust

Tom Neltner, J.D.is Chemicals Policy Director

On January 19, the Environmental Protection Agency (EPA) released a major new draft report proposing three different approaches to setting health-based benchmarks for lead in drinking water. We applauded EPA’s action and explored the implications for drinking water in a previous blog. One of the agency’s approaches provides useful, and surprising, insights into where the lead that undermines the health of our children comes from. Knowing the sources enables regulators and stakeholders to set science-based priorities to reduce exposures and the estimated $50 billion that lead costs society each year.

The EPA draft report is available for public comments until March 6, 2017, and it is undergoing external peer-review by experts in the field in support of the agency’s planned revisions to its Lead and Copper Rule (LCR) for drinking water. Following this public peer-review process, EPA expects to evaluate and determine what specific role or roles a health-based value may play in the revised LCR. With the understanding that some of the content may change, here are my takeaways from the draft:

  • For the 20% of most exposed infants and toddlers, dust/soil is the largest source of lead. Since we know that 21% of U.S. homes (24 out of 114 million) have lead-based paint hazards, this should not be surprising.
  • For most infants, lead in water and soil/dust have similar contributions to blood lead levels, with food as a smaller source. If the infant is formula-fed, water dominates.
  • For 2/3 of toddlers, food appears to provide the majority of their exposure to lead. This result was a surprise for me. EPA used data from the Food and Drug Administration’s (FDA) Total Diet Study collected from 2007 to 2013 coupled with food consumption data from the National Health and Nutrition Examination Survey collected from 2005 to 2011. In August 2016, FDA reported on levels of lead (and cadmium in food) commonly eaten by infants and toddlers based on a data set that is different from its Total Diet Study. FDA concluded that these levels, “on average, are relatively low and are not likely to cause a human health concern.”
  • For all children, air pollution appears to be a minor source of lead exposure. We think it is most likely because exposure is localized around small airports and industrial sources.

For a visual look at the data, we extracted two charts from the draft EPA report (page 81) that show the relative contribution of the four sources of lead for infants (0-6 month-olds) and toddlers (1 to <2 year-olds) considered by the agency. The charts represent national exposure distributions and not specific geographical areas or age of housing.

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