EDF Health

ASDWA provides new recommendations to states and utilities for lead service line inventories

Tom Neltner, J.D., Chemicals Policy Director

The Association of State Drinking Water Administrators (ASDWA) released a new white paper to help states and utilities develop more useful inventories of lead service lines (LSLs). The paper builds on guidance the organization issued in August 2019. ASDWA partnered with BlueConduit to leverage that firm’s experience developing a statistical model for Flint, Michigan that accurately predicted which service lines were made of lead, galvanized steel, plastic or copper.

The guidance is timely as EPA prepares to finalize its Lead and Copper Rule revisions. We anticipate those revisions will require utilities to develop – and make public – inventories that identify the location of each service line made of lead or when the material is unknown and may be lead. Utilities would also be required to notify customers annually if they have a lead or unknown service line. Customers who buy a home and open a new water account would also be notified in the first bill.

The ASDWA/BlueConduit white paper encourages utilities to use five principles to best characterize the uncertainty in their inventories:

  1. Ensuring clean data management and organization;
  2. Not accepting all historical records as truth;
  3. Conducting a representative randomized sample of unverified service lines;
  4. Being transparent in public outreach and reproducibility; and
  5. Demonstrating accuracy on “hold-out sample.”

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FDA takes an important step by phasing out paper greaseproofing agents containing a specific PFAS

Tom Neltner, J.D.Chemicals Policy Director and Maricel Maffini, Ph.D., Consultant

Last week, the Food and Drug Administration (FDA) announced the phase-out of per- and polyfluorinated alkyl substances (PFAS) used to greaseproof paper and paperboard food packaging made from a specific type of short-chain PFAS known as 6:2 fluorotelomer alcohol (6:2 FTOH).  The action, narrow as it is, is welcome news for efforts to protect public health and the environment from the risks posed by short chain PFAS, known as “forever chemicals” because they do not degrade.

FDA secured voluntary agreements with three companies, Archroma, Asahi Glass, and Daikin, to phase-out products based on 6:2 FTOH. A fourth company, Chemours, asked FDA to suspend the agency’s approvals on its products containing the PFAS one year ago. The action affects 15 food contact substance notifications (FCN) approved by the agency between 2006 and 2016. It does not address 13 FCNs for similar greaseproofing uses made from PFAS other than 6:2 FTOH. And, under the agreement, consumers may still find 6:2 FTOH-laden, carry-out containers until June 2025.

The process FDA took, and the time it took to get there, reveals the significant difficulties the agency has in reversing past actions in the face of mounting evidence of a chemical’s risk:

  • FDA must seek out information because companies have no obligation to affirmatively notify the agency of new studies showing potential problems;
  • When FDA finds the information and identifies potential safety concerns, it appears to act as if it has the burden of proving the use is no longer safe; and
  • FDA continued approving uses of 6:2 FTOH even after it identified problematic data gaps.

These difficulties reinforce the need for actions being taken by states such as Washington, Maine, New York, and California, by Congress, and by retailers to reduce uses of PFAS in their products. When it comes to food packaging, PFAS are dinosaurs and their time is running out.

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Why now is the moment for cities around the world to act decisively on air pollution

Sarah Vogel, Ph.D.is Vice President for Health.

This is the second in a series of Global Clean Air blogs on COVID-19 and air pollution. EDF scientists and program experts will share data about pollution levels during quarantine from a local and global perspective, and provide recommendations for governments and companies to Rebuild Better.

New COVID-19 air quality/ transportation measures in Bogotá, Colombia.

Around the world, we’ve seen dramatic improvement in air quality as a result of the response to COVID-19. While it’s come from an artificial and unwanted brake on the global economy, it’s drawn renewed attention to the devastating impacts of outdoor air pollution.

As many large cities around the world emerge from lockdown, city authorities need to act decisively to prevent air pollution rebounding and even exceeding pre-COVID-19 levels. That was the conclusion of participants in a “Clear Skies to Clean Air” webinar I moderated last week by the Organisation for Economic Co-operation and Development World Wildlife Fund and Environmental Defense Fund, in collaboration with the World Bank.

The improvements in air quality seen during the COVID-19 lockdown have shown individuals and policymakers what is possible and could open the door to reinvigorated efforts to address pollution.

London and Bogotá demonstrate clean recovery strategies

The webinar heard from policymakers on the front lines of addressing air pollution: Shirley Rodrigues, Deputy Mayor of London, with responsibility for environment and energy; and Claudia López, Mayor of Bogotá, Colombia.

New COVID-19 air quality/ transportation measures in London.

Cities need devolved powers if they are to address local air pollution, argued Rodrigues: “We can’t have a centralised approach … Citizens deal with their local authorities, mayors know what is needed in their cities. Devolving powers, alongside funding, is absolutely critical so we can push the electrification agenda and the reclamation of roads, so we can avoid a car-based recovery.”

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Amid COVID-19, the Trump administration sets dangerous air pollution standards. What is at stake for Houstonians?

Ananya Roy, Senior Health Scientist; Rachel Fullmer, Senior Attorney; Jeremy Proville, Director; Grace Tee Lewis, Health Scientist

The Trump administration’s disregard for science has been clear in the response to the COVID-19 pandemic, but it’s not the only health threat they’re making worse by ignoring overwhelming scientific evidence. For three years the administration has systematically sought to weaken clean air safeguards, endangering all Americans.

We know air pollution causes heart disease, diabetes and lung disease—and that the people suffering from these conditions are at greater risk of severe illness from COVID-19. Independent of the ongoing pandemic, air pollution is responsible for tens of thousands of deaths across America year after year. This underscores the vital importance of pollution protections to protect human health both during and after the COVID-19 crisis.

Unfortunately, EPA Administrator Andrew Wheeler has proposed to retain an outdated and inadequate standard for fine particulate matter (PM2.5) pollution despite strong scientific evidence that it must be strengthened to adequately protect human health.

To understand what having this pollution standard means for families living in the Greater Houston area, Harvard University and EDF scientists undertook an analysis of the impacts of PM2.5 exposure across the city. We found that:

  • Exposure to fine particle air pollution in 2015 was responsible for 5,213 premature deaths and over $49 billion in associated economic damages.
  • More than 75% of the health burden was borne by communities exposed to PM2.5 levels below the current standard.
  • Meeting the current standard alone would have prevented 91 deaths of the more than 5,000 premature deaths due to fine particle pollution.

By ignoring the scientific evidence and retaining the current standard, Administrator Wheeler is ignoring the very real health impacts felt by Houstonians and communities across the country from exposure to fine particle pollution.

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Michigan utilities report much lower percentages of service lines of lead or unknown material than Wisconsin or Illinois

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

Note to readers: As we all grapple with the grave global health challenge from COVID-19, we want to acknowledge the essential service that the public health professionals at water utilities provide in delivering safe water not only for drinking but for washing our hands and our surroundings. In the meantime, we are continuing to work towards improved health and environmental protections – including reducing lead in drinking water. We’ll plan to keep sharing developments regarding lead in drinking water that may be useful to you. In the meantime, please stay safe and healthy.

Lead service line (LSL) inventories provide useful insights into the location and number of LSLs in states and the funding needed to fully replace these lines. In previous blogs, we examined mandatory reporting by utilities of service line material in Illinois and Wisconsin.[1] Here, we examined a March 2020 preliminary report by the Michigan Department of Environment, Great Lakes, and Energy (EGLE) summarizing data submitted by 1,029 utilities. Unlike the annual reporting in Illinois and Wisconsin, Michigan required utilities to submit a preliminary inventory by January 1, 2020 and requires a complete inventory before 2025. While the preliminary report allows lines to be designated as unknown, the material must be determined by 2025. This is a two-step process, rather than the annual report approach that California has taken.

Michigan reports less than 100,000 LSLs and 276,000 lines of unknown material that may be lead

The state’s preliminary report is based on 1,029 utilities[2] (74% of the state’s 1,386 total) with 2.40 million service lines (90% of the 2.66 million total).[3] This reporting rate is lower than what Illinois experienced at a similar stage in the first year of mandatory reporting.

For the 1,029 utilities that reported, utilities reported 99,000 (4% of total) lead, 21,000 (0.9%) galvanized steel,[4] 177,000 (7%) of unknown material but likely to be lead, and 276,000 (12%) as unknown with no information. If all of the four categories are actually lead (which is unlikely), there would be 573,000 (23%) LSLs in Michigan.

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Latest Wisconsin data on water service lines provides important insights, reveals over 150,000 lead pipes

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

Note to readers: As we all grapple with the grave global health challenge from COVID-19, we want to acknowledge the essential service that the public health professionals at water utilities provide in delivering safe water not only for drinking but for washing our hands and our surroundings. In the meantime, we are continuing to work towards improved health and environmental protections – including reducing lead in drinking water. We’ll plan to keep sharing developments regarding lead in drinking water that may be useful to you. In the meantime, please stay safe and healthy.

With the comment period now closed on the Environmental Protection Agency’s proposed revisions to its Lead and Copper Rule (LCR), agency staff are busy reviewing the 687 distinct comments submitted to the docket with a goal of finalizing the rule by the end of the year. To help water professionals plan ahead, the cover article in the March edition of Journal AWWA walks readers through the proposal and its implications. It ends with six suggestions to water systems that include developing a service line material inventory and identifying funding strategies to accelerate full lead service line (LSL) replacement.

With this suggestion in mind, we are continuing our work evaluating state efforts to develop LSL inventories by taking a closer look at reporting by Wisconsin municipal and private water utilities[1] to the state Public Service Commission (PSC) for calendar year 2018.[2] Of the other states with mandatory inventory reporting, we have previously covered Illinois in detail and will evaluate Michigan’s newly released reports soon. The only other state with mandatory reporting is California, but it has limited value because it only covers the portion of the service line owned by the utility and excludes the portion on private property.

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