EDF Health

Cincinnati adopts an innovative plan to eliminate LSLs that is a model for other cities

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: October 12, 2017

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

The Cincinnati City Council enacted three ordinances in June 2017 that establish an innovative legal framework to replace the city’s 27,000 lead service lines (LSLs) over the next 15 years. The Council acted after finding that “high levels of lead in water create serious health risks to residents of the City, particularly young children, and using lead service lines between public water mains and properties increases the risk that the lead content of drinking water to the properties served will increase to a dangerous level” and that “replacing lead service lines is in the best interest of the public health, safety, morals, and general welfare.” Although the City stopped allowing new LSLs in 1927, an estimated 1 in 9 service connections still have a portion made of lead pipe.

A member of the GCWW Repair Services Team replaces an LSL. Photo credit: GCWW

Cincinnati’s program is based on Madison, Wisconsin’s successful effort, which began in 2000 and was completed in 2011. Cincinnati is roughly three times larger than Madison in terms of population, service connections, and LSLs.

Under the program, residential property owners within Greater Cincinnati Water Works’ (GCWW) service area can receive between 40 and 50% off of the cost of replacing the portion of the LSL on their property up to $1,500 if they agree to have GCWW arrange for the replacement. Owners within the limits of the City of Cincinnati may choose to have the remaining cost assessed semiannually on their property tax bill and repaid over 5 or 10 years. Property assessments must be approved by the political entity where the property resides. As of today the assessment option is only available for the residential properties in the City. However, GCWW is reaching out to the other jurisdictions it serves to discuss expanding the assessment program to those jurisdictions as well.

GCWW will also be replacing the portion of the LSL on public property so that the entire service line is replaced. The City is committed to fund its share of the work from GCWW’s Capital Budget.

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

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: October 9, 2017

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

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: September 14, 2017

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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New Pew/RWJF report rigorously evaluates options and recommends 10 policies

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: August 30, 2017

Tom Neltner, J.D., Chemicals Policy Director

For the past 2 years, the issue of lead – in paint, water, dust, soil, food, toys, and kids’ blood – has been extensively covered in the news. The crises in Flint and East Chicago have laid bare the vulnerability of communities across the U.S. The evidence is now clear that there is no safe level of lead in children’s blood. What used to be tolerable is no longer acceptable. Evidence from studies of children show clearly that levels of lead in blood affect brain development at levels below those once considered acceptable and should not be tolerated. We must be vigilant to prevent young children’s exposure to lead.

We have already made substantial progress as a nation. From 1999 to 2014, mean blood lead levels in young children dropped 56% and the levels over 5 micrograms of lead per deciliter of blood dropped 86%. This change was due to smart policies, effective regulations, funding, and vigilance from federal, state and local agencies as well as private and non-profit organizations. Despite this headway, lead exposure continues to be a significant problem, preventing our communities from thriving and holding back the future generations from achieving their full potential.

Last year, several organizations developed comprehensive plans1 to eliminate lead exposure. Each added value to the discussion. Today, a new report from the Health Impact Project, a collaboration of The Pew Charitable Trusts and Robert Wood Johnson Foundation (RWJF), provides a rigorous analysis of the costs of lead and the impact of various policy solutions to help protect children from the harms of lead exposure. My colleague, Ananya Roy, and I served as advisors on the project.

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Protecting the most vulnerable: Lead in drinking water testing requirements for child care facilities

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: August 17, 2017

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

[Updated April 2018 and June 2018] .  See here for the most up-to-date information on state testing requirements.

Children under the age of 6 are most vulnerable to the detrimental impacts of lead exposure. Even at low levels, lead exposure can harm the brain development of young children – resulting in learning and behavioral problems for the rest of their lives.

The recent national attention on lead in drinking water and reports of high levels in certain schools has spurred action to address the problem in schools. As a result of state-level requirements and voluntary state programs, many schools across the country are testing their drinking water for lead and taking actions to fix problems.

In contrast, child care (also called day care or early childhood education) has gone relatively unnoticed – even though such facilities serve children at their most vulnerable ages.

However, several states and cities have or are developing proactive programs requiring testing for lead in child care facilities’ drinking water and mandating action when high levels are found. Seven states – Connecticut, Illinois, New Hampshire, New Jersey, Oregon, Rhode Island, and Washington – and one city – New York City– require licensed child care facilities to test their drinking water for lead [1].

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Fourteen communities set goal of replacing more than 240,000 lead pipes and 19 take important steps forward

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: August 7, 2017

Tom Neltner, J.D., Chemicals Policy Director and Sam Lovell, Project Specialist

An estimated 6 to 10 million homes in the US still get their water from aging lead service lines (LSLs) – the lead pipes connecting the water main under the street to homes and other buildings. As the primary source of lead in drinking water, eliminating LSLs is essential to protecting public health and responding to community concerns.

Communities across the country are taking on the challenges posed by LSLs. EDF considers it important to recognize those leaders who are taking action. In a past blog, we highlighted the work of the Lead Service Line Replacement Collaborative and its 25 members, including EDF, in developing a toolkit to help communities accelerate replacement of LSLs. Additionally, the American Water Works Association – the main organization for drinking water professionals – deserves recognition for its declaration that LSLs need to be eliminated.

Through our review of publicly available information, EDF identified:

  • 14 communities that have publicly set a goal of eliminating LSLs in their jurisdiction – which collectively represents more than 240,000 LSLs. Setting a goal of full replacement is a critical step in the process—while clearly much work remains to ensure that LSLs are safely replaced.
  • 19 other communities that are taking important steps to replace LSLs, but may not yet be ready or willing to set a public goal of full replacement.

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