Household Action Level for Lead in Water: EPA Needs to Release Health-based Estimate

Tom Neltner, Chemicals Policy Director.

A new article in USA Today’s series on lead in drinking water shines a light on the Environmental Protection Agency’s (EPA) delays in releasing a health-based “household action level” for lead. EPA’s National Drinking Water Advisory Council (NDWAC) recommended that the agency develop this number to help parents, in consultation with their pediatrician and public health agency, decide whether to invest in a filter for the water they use to make up their child’s infant formula.

Without a health-based number, people are mistakenly using EPA’s current “lead action level” of 15 parts per billion (ppb) as the level below which no action is needed. The problem is that this level has no relation to the health risk. It is based on a provision in the drinking water rule that requires utilities to undertake corrosion control and, potentially, lead service line replacement when at least 10% of worst-case sample results exceed that level.

A year after committing to develop a household action level, it appears tied up in the agency’s long overdue overhaul of its broken 1991 regulation designed to protect people from lead in drinking water. Communities all across the country are raising legitimate concerns about the safety of their water and need proper public health guidance. They should not have to wait on rulemaking for this important information. I know EPA is a regulatory agency that thinks in terms of rulemaking. But first and foremost EPA is a public health agency with responsibility to consumers for the safety of drinking water.

I also understand the challenge of developing an estimate given that there is no safe exposure to lead— people may misconstrue the levels below the number as completely safe. On the other hand, in the absence of such a number, they are already mistakenly using the 15 ppb current lead action level to mean the water is safe and no action is needed.

There is precedent for setting health-based numbers for different lead hazards. The agency has done it for lead in soil and for lead in dust on floors or window sills. For lead in dust, EPA established 40 micrograms of lead per square foot of the floor of homes and child-occupied facilities as the definition of a hazard that must be eliminated. This is equivalent to one gram – the same amount of sugar in a packet we add to our tea – spread evenly over about 1/2 of a football field. The agency set this level because it would “result in a 1 to 5% probability of an individual child’s exceeding a blood lead level of 10 µg/dL” (the definition of elevated in 2001 when the rule was promulgated). While subsequent research showed that the risk of lead in dust was much greater and, in 2009, EPA committed to revising the number, it still shows the value of providing people with a level at which a household should act.

These measurements help public health officials, housing agencies, and parents better assess the risk from lead hazards, determine what they should do to reduce the risk, and guide how they set priorities. A health-based number empowers people to make informed choices. The agency has done it for dust and soil. It needs to do it for water.

In February 2015, NDWAC’s workgroup asked EPA to develop an estimated value for a household action level to help guide the workgroup’s development of its recommendations. The agency agreed and provided updates in April 2015 and reaffirmed its commitment in June 2015.  No number has been released.

Given the developments in Flint and the evidence of lead in water systems throughout the country (as explained in a compelling USA Today series), delay is untenable. EPA must not wait on a proposed rule to act. It must focus its scientific expertise to developing a sound estimate, make it public, and use an external peer review process to ensure the science is strong.

For more information on the Household Action Level for lead in drinking water.  See also

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One Comment

  1. Posted March 26, 2016 at 6:03 pm | Permalink

    What an excellent blog post Tom!
    As I spend most of my time advising parents and others on lead action levels to keep themselves and their families safe from lead, I have been waiting for soil, water, paint, dust wipe, etc “lead action levels” to be revised downwards in line with the “blood lead action level” drop from 10ug/dL (micrograms per decilitre) to 5 ug/dL in the US, and with the proposed drop to a blood lead goal of less than 1ug/dL in Canada.
    Being an un-resourced but impatient scientist parent myself, my while-waiting-for-the-US-EPA-to-act-solution has been to search the globe for the lowest “lead action levels” in the various environmental media, and then take simple arithmetic ratios depending on the “blood lead action level” at the time the dust- or soil- or water- etc “lead action level” was recommended or set. For instance, Australia has a drinking water “guideline” (action) level of 10 ppb (10 ug/L) which I re-set to 1ppb (ie 1/10) the moment my Technical Advisors Professors Chris Winder, Mark Taylor and Bruce Lanphear wrote that the new goal for all blood lead levels should be less than 1 ug/dL (ie 1/10 of Australia’s then 10 ug/dL “blood lead action level”). In other words, I would recommend that a parent only use water containing less than 1ppb lead to make up infant formula and that if their mains water or rainwater contains more lead than that, they determine the source of the lead and accordingly complain to the Water Authority or replace the house taps or pipes, the rainwater pump or roof or tank or get rid of lead flashing etc. Filtration in my view is the last line of defence in the hierarchy of controls and should be used as a last resort if eradication of the lead source proves impossible. Similarly, I recommend that child-accessed window sills and play floors all have dust wipe lead levels below 12 ug/m2. Here’s how I calculated that:
    “Levels of PbD [lead dust] on floors between 6 ug/ft2 [approx. 60 ug/m2] and 12 ug/ft2 [approx. 120 ug/m2] can be expected to protect most children living in pre-1978 homes from having a blood lead level greater than or equal to 10 ug/dL. Protection at lower blood lead levels would require lower PbD.” Reference: “U.S. Children’s Exposure to Residential Dust Lead, 1999-2004: II. The Contribution of Lead-contaminated Dust to Children’s Blood Lead Levels” at (14/11/08).
    In light of The LEAD Group’s blood lead recommendation (see above), I have applied a simple factor of 1/10 to the above EHP Reference conclusion and arrived at The LEAD Group dust wipe lead level recommendation for Australia (where 1997 is the closest equivalent to the US lead paint standard of 1978):
    “Levels of PbD [lead dust] on floors between 6 ug/m2 and 12 ug/m2 can be expected to protect most children living in pre-1997 homes from having a blood lead level greater than or equal to 1.0 ug/dL. Protection at lower blood lead levels would require lower PbD.”
    With my pragmatic maths-based lead action levels, I maintain that parents can achieve non-detectable blood lead levels while their young children’s brains are still developing, rather than waiting for government-set action levels which may not happen until their children are already at school (and struggling).
    Elizabeth O’Brien, Lead Advisor, Lead Safe World Partnership, The LEAD Group Inc, Australia