EDF Health

Selected tag(s): lead

Lead pipe replacement in action: New case examples highlight innovative approaches to financing, outreach, and more

Sam Lovell, Project Manager.

See new case examples of state and local agencies, community groups, and other stakeholders tackling lead service line replacement challenges.

Across the country, over 9 million homes still get their water through a lead pipe, called a lead service line (LSL). Fully replacing LSLs poses a myriad of challenges – cost chief amongst them – but replacement is critical to protecting the public from the harms posed by lead exposure. It is also a necessary step to upgrading the country’s aging water infrastructure.

To assist water systems, elected officials, health professionals, and other key stakeholders with navigating these challenges to accelerating LSL replacement, the Lead Service Line Replacement Collaborative developed an online toolkit several years ago. EDF is a founding member of the Collaborative, which now has 27 members representing public health, water utility, environmental, labor, consumer, housing, and state and local governmental organizations. The toolkit includes everything from technical replacement information to recent LSL replacement news to equity considerations.

Now, the Collaborative is featuring case examples and interviews with states, water utilities, and advocates advancing LSL replacement with innovative strategies.

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House Oversight Committee draws renewed attention to heavy metals in baby food and calls for FDA to act

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

Last week, the House Committee on Oversight and Reform’s Subcommittee on Economic and Consumer Policy released an important report summarizing baby food testing data submitted by four companies (Beech-Nut, Gerber, Happy Family, and Earth’s Best), finding that “baby foods are tainted with dangerous levels of arsenic, lead, cadmium and mercury.” These heavy metals are widely recognized as harming children’s brain development.

The report found that three of the four companies (all but Gerber) used ingredients that had exceeded limits set in their internal standards. Additionally, the committee cited “grave concerns” that three other companies (Walmart, Plum, and Sprout) did not provide their internal standards and testing results in response to the legitimate request by the House Committee. Their lack of transparency undermines credibility and trust.

Due to the alarming nature of these findings about a food marketed as safe and healthy for infants and toddlers, the report garnered significant attention and has prompted calls for the Food and Drug Administration (FDA) and food manufacturers to do more on this issue.

Importantly, the report provides new insights into industry decision-making processes, highlights the need for greater oversight, and adds urgency to EDF’s ongoing efforts to reduce heavy metals in food.

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Spotlighting advocates for environmental justice: LaTricea Adams with Black Millennials for Flint

LaTricea Adams credits her background as an educator with motivating and shaping her community advocacy work. For five years, Adams taught Spanish to middle and high school students in Nashville, Tennessee.

Now, she’s the Founder Chief Executive Officer and President of Black Millennials for Flint (BM4F) – a grassroots, environmental justice and civil rights organization with the purpose of bringing like-minded organizations together to collectively take action and advocate against the crisis of lead exposure specifically in African American and Latino communities throughout the nation.

Last month, we sat down (virtually) with Adams to learn about her experience advocating for environmental justice.

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EPA’s new service line inventory: The good, the bad, and the absurd

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

This is the first in a series of blogs evaluating various aspects of EPA’s December 2020 revisions to the Lead and Copper Rule (LCR) and what they may mean for accelerating lead service line (LSL) replacements. The blogs cover: 1) the new service line inventory; 2) three new LSL notices; 3) environmental justice implications; 4) communicating health effects of lead; 5) economic implications; and 6) sampling and trigger/action level. 

Note that President Biden’s Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis directs agencies to review the former administration’s regulations and actions, including the Lead and Copper Rule. 

The backbone of the revised LCR is a new service line inventory[1] that all public water systems, whether large or small, rural or urban, must develop by January 2024 unless they can demonstrate that they have no LSLs. If properly designed and implemented, the inventory should transform how utilities, communities and states approach LSLs by moving from rough estimates to a data-driven approach that allows water systems to identify what is known and not known about the service lines, communicate that information to the public, and establish LSL replacement priorities.

Unfortunately, EPA has included an unfortunate and absurd new detail in the inventory that requires systems to categorize service lines that contain a two-foot piece of lead pipe, often known as a gooseneck, as “Non-lead.” We anticipate that the absurdity of calling a lead pipe “Non-lead” will undermine the inventory’s credibility and effectiveness.

What is the new service line inventory and how is it used?

By January 2024, water systems must submit a service line inventory to the state and make it publicly accessible pursuant to 40 CFR § 141.84(a). To develop the inventory, they must assign all service lines, regardless of ownership, for the portions on public or private property to one of four categories:

  1. Lead: where a portion of the service line is made of lead (excluding lead connectors, such as goosenecks, as explained below). We presume this includes lead-lined pipe.
  2. Galvanized Requiring Replacement: where a portion of the service line is galvanized iron or steel.[2] If the system can determine that the galvanized pipe was never downstream of an LSL (or lead connector, such as a gooseneck[3]), then it is essentially a galvanized pipe not requiring replacement and can be categorized as “Non-lead.”
  3. Non-lead: where the line is determined not to be “Lead” or “Galvanized Requiring Replacement” (see discussion below for lead connectors). Our understanding is that systems could assume service lines installed after the 1986 federal ban on lead pipe are “Non-Lead.”
  4. Lead Status Unknown: where it has not been determined if the service line met the SDWA Section 1417 definition of “Lead-free” at 42 U.S.C. § 300g-6. We presume this means that solder or flux must be less than 0.2% lead and other wetted surfaces must be less than 8% from 1986 to 2013 and less than 0.25% for 2014 to present.[4]

Under these requirements, a service line is classified as an LSL if it is in the “Lead” or “Galvanized Requiring Replacement” categories.[5]

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Clear communication about lead service line ownership is difficult – but here’s why it really matters

Sam Lovell, Project Manager.

Any successful initiative to replace lead service lines (LSLs) – the lead pipes connecting the water main under the street to homes – must be built on clear and consistent communications to residents. This will not only accelerate LSL replacement progress and equip people with information that impacts their health – it will also help build trust.

Many residents likely don’t even know what an LSL is, let alone that they need to take proactive steps if they want it fully replaced. In most communities, ownership of the water service line is split between the drinking water utility and the resident. Fully replacing an LSL entails removing the portions of lead pipe both on public and on private property. A partial replacement (when only one of the sides of an LSL is removed – see image below) is an issue because it can spike lead levels in the short-term and does not have the long-term benefit of reduced lead exposure seen with a full LSL replacement.

When describing LSLs and the replacement process, water systems must explain whether they are referring to the full LSL or only one of the sides, and the implications of this for the resident.

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In major step, Chicago announces lead pipe replacement plan – but could it widen the equity gap?

Lindsay McCormick, Program Manager

In September, Chicago took an important – albeit modest – step towards tackling its colossal number of lead service lines (LSLs) – the lead pipes providing drinking water from the main under the street to homes.

With an estimated 389,900 LSLs, Chicago has more than two times as many LSLs as any other city in the country. In fact, Chicago city code mandated their installation until 1986, when Congress banned it.  Since then, the city has largely turned a blind eye to the problem of existing lead pipes – that is, until now.

On September 10th, Mayor Lightfoot announced the city’s new Lead Service Line Replacement Program, acknowledging the problem and taking initial steps towards fully replacing its lead pipes.  While the starting investment is $19 million, Lightfoot estimates the full cost of the program, including restoration and bringing underground sewerage and water infrastructure up to code, at $8.5 billion. The city currently does not yet have the funds – or a plan – to fully cover the cost. Chicago’s move comes just weeks before the Environmental Protection Agency is slated to release its final revisions to the Lead and Copper Rule.  Read More »

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