EDF Health

EDF considers potential health equity impacts of partial lead service line replacement

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: January 10, 2019

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

[pullquote]“LSL replacement initiatives should address barriers to participation so that consumers served by LSLs can benefit equitably, regardless of income, race or ethnicity.”

– A founding principle of the Lead Service Line Replacement Collaborative[/pullquote]States and communities across the country are taking important steps to accelerate replacement of lead service lines (LSLs) – lead pipes connecting the water main under the street to homes and other buildings. As part of this progress, many programs have strictly limited the standard practice of partial LSL replacement – replacing only the portion of the LSL on public property, which commonly arises when rehabilitating the main and reconnecting the existing line. Partial replacement is likely to increase, at least temporarily, lead levels in drinking water in homes and may not reduce lead exposure in the long run.

The default approach for most water utilities rehabilitating their main has been to simply alert property owners to the risk of partial replacement and advise them to hire a contractor to voluntarily replace the remaining portion of the LSL on their property.

Other utilities have rejected this approach and gone further to protect residents. For example, Washington, DC offers to coordinate private side and public side replacement to reduce costs and make participation easier but still expects the property owner to pay for the private side. Others, such as Cincinnati, OH, have required full LSL replacement, providing a significant subsidy to the homeowner and allowing the cost to be spread over ten years through a property tax assessment. Indiana American Water and Philadelphia, PA go even further and pay for the cost of full LSL replacement out of ratepayer or capital improvement funds. States are acting too, with Michigan requiring utilities to pay the cost of replacement on private property and Wisconsin requiring cost sharing. For more examples, see our webpages recognizing communities and states that are leading the way.

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From villages to states, significant progress on lead service line replacement in 2018

By Sam Lovell / Published: January 7, 2019

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

We recently finished a round of updates to our webpages recognizing states and communities leading the way in efforts to accelerate lead service line (LSL) replacement across the country. As we start the New Year, we wanted to summarize the good news from 2018 and highlight some opportunities for more success.

Ninety-five communities are leading the way on LSL replacement programs:[1]

  • 6 communities have publicly announced that they have completely replaced all known LSLs.
  • 53 communities have publicly set a goal of eliminating LSLs on public and private property, totaling more than 300,000 LSLs. Ten of the communities are in Wisconsin; Indiana has one investor-owned utility, American Water, which operates 27 separate community water systems; Michigan has four communities; Colorado and Ohio have two; and Arkansas, Massachusetts, Pennsylvania and Washington have one.
  • 36 communities are publicly taking steps to replace LSLs but have not yet set a goal of full replacement. One third of these communities are from Wisconsin; seven from Illinois; and five or fewer from New York, Massachusetts, Michigan, Pennsylvania, Rhode Island, Iowa, and Kentucky.

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Lead in hair dye – one company considers it safe

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: January 4, 2019

Tom Neltner, J.D., Chemicals Policy Director

In October 2018, the Food and Drug Administration (FDA) banned the use of lead acetate in hair dyes in response to a March 2017 color additive petition from EDF and other health advocates. In December, we learned that Combe, Inc., the maker of the lead-acetate based hair dye Grecian Formula, objected to FDA’s decision, requested a formal evidentiary public hearing to review the decision, and claimed the use is safe. The objection puts the FDA’s decision on hold awaiting a process that may take years to resolve. Apparently, the company thinks it is safe for men to slather skin-soluble lead on their head every couple of days and to risk exposing their families to a heavy metal for which no safe level of exposure has been identified.

Combe’s action was somewhat surprising because the company told CBS News that it removed lead acetate from its Grecian Formula “quite a long time ago,” but was unable to provide an exact date. Presumably, someone in the know updated the product’s Wikipedia page, which says Grecian Formula does not contain lead acetate as of July 2018, although an earlier version of the page said April 2018.

Whatever the date it was reformulated, why would Combe block FDA’s decision when it has long sold a lead-free brand – Just For Men – and had already reportedly removed lead from Grecian Formula? From a market standpoint, objecting to FDA’s decision benefits Youthair, Combe’s main competitor, which continues to sell a leaded-version of progressive hair dye.

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Trump Administration’s lead action plan is a missed opportunity to protect kids from lead

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: December 20, 2018

Tom Neltner, J.D., Chemicals Policy Director

Yesterday, the President’s Task Force on Environmental Health Risks and Safety Risks to Children released its long-delayed Federal Action Plan to Reduce Childhood Lead Exposures and Associated Health Impacts (Lead Action Plan). A year ago the Task Force described this document as a federal lead strategy that would identify clear goals and objectives to “serve as a ‘roadmap’ for federal agencies on actions to take to reduce childhood lead exposure.” It requested feedback on the approach and received over 700 public comments.

The Trump Administration’s Lead Action Plan falls far short of what was promised. To understand what the Plan is and what it is not, we compared it to two earlier documents from the Task Force: 1) A federal lead strategy released in February 2000 by the Clinton Administration focused on reducing exposure to lead-based paint; and 2) An inventory of key federal programs released in November 2016 by the Obama Administration summarizing the activities of the 17 federal agencies and departments with responsibilities to protect children from lead.

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California Water Board makes misleading claim that only four water systems have lead lines

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: December 7, 2018

Tom Neltner, J.D., Chemicals Policy Director

[Update 12/14/18: The California Water Boards added a webpage providing more background for customers on the inventory requirement, including the clarification that “user service line” does not include the service line on private property. This clarification was also added to the Status Map webpage.]

The California Water Board posted the results of its statewide inventory of lead service lines (LSLs) in community water systems (CWSs) yesterday. They also became the first in the nation to post the results in an interactive online map. We are pleased to see the state take this important step, but are disappointed that the press release it sent out to announce the map’s launch undermines its efforts with misleading and confusing statements.

The central problem is that the press release fails to be clear that the inventory does not cover the portion of the service line between the meter and the home or building.  As a result, a CWS that removed all of the lead pipes between the main under the street and the meter but left them on private property was listed as having no LSLs. A customer would justifiably – but mistakenly – assume that LSLs were not an issue in their community.

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Lead from a new “lead-free” brass faucet? More common than you’d hope

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: November 6, 2018

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

[pullquote]Until NSF/ANSI 61 standard is updated to reduce or eliminate lead leaching, users must extensively clean and flush new brass fixtures before use and make a short flush standard practice for older fixtures.[/pullquote]

During this past year, we undertook a pilot project to tackle the problem of lead in drinking water at child care facilities. As part of the effort, we collected 250 mL samples (about 8 ounces of water) from every drinking water fixture, as recommended in the Environmental Protection Agency’s (EPA) 3Ts guidance for schools and child care facilities. We replaced 26 faucets that exceeded our action level with new brass faucets that were labeled “lead-free” and complied with NSF/ANSI 61 standard for drinking water system components.[1] To our surprise, when we sampled the faucets a few days after replacement, the lead levels were higher– between 9 and 10 ppb – on three of the new faucets.

The increase left us scratching our heads. Federal law allows a drinking water fixture to be labeled “lead-free” if the amount of lead in wetted surfaces[2] averages less than 0.25% (down from the 8% limit between 1986 and 2014). However, it isn’t clear how much this amount might contribute to levels of lead in water. To explore this issue, we contacted the supplier who said its product was certified under NSF/ANSI 61 and, therefore, not likely the source. The supplier suggested the source could be from existing upstream valves or from disturbing the plumbing. We could not rule these other possibilities out.

A study by Virginia Tech’s Jeff Parks on three models of new NSF/ANSI 61 certified brass faucets found similar results and concluded that even newly manufactured “lead-free” faucets may not meet the 1 ppb limit that the American Academy of Pediatrics (AAP) recommends for schools.

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