EDF Health

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EDF’s assessment of a health-based benchmark for lead in drinking water

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: February 28, 2017

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

Health professionals periodically ask me how they should advise parents who ask about what constitutes a dangerous level of lead in drinking water. They want a number similar to the one developed by the Environmental Protection Agency (EPA) for lead in dust and soil (which is the primary source of elevated blood lead levels in young children). I usually remind them that EPA’s 15 parts per billion (ppb) Lead Action Level is based on the effectiveness of treating water to reduce corrosion and the leaching of lead from plumbing; it has no relation to health. Then I tell them that EPA is working on one and to hold tight. Admittedly, that is not very satisfying to someone who must answer a parent’s questions about the results of water tests today.

On January 12, EPA released a draft report for public comment and external peer review that provides scientific models that the agency may use to develop potential health-based benchmarks for lead in drinking water. In a blog last month, I explained the various approaches and options for benchmarks that ranged from 3 to 56 ppb. In another blog, I described how EPA’s analysis provides insight into the amounts of lead in food, water, air, dust and soil to which infants and toddlers may be exposed. In this blog, I provide our assessment of numbers that health professionals could use to answer a parent’s questions. Because the numbers are only a start, I also suggest how health professionals can use the health-based benchmarks to help parents take action when water tests exceed those levels.

EDF’s read on an appropriate health-based benchmark for individual action on lead in drinking water

When it comes to children’s brain development, EDF is cautious. So we drew from the agency’s estimates calculated by its model to result in a 1% increase in the probability of a child having a blood lead level (BLL) of 3.5 micrograms of lead per deciliter of blood (µg/dL).

EDF’s assessment of a health-based benchmark for individual action on lead in drinking water
Age of child in home and type of exposure Houses built before 1950¹ Houses built 1950 to 1978² Tests show no lead in dust or soil³
Formula-fed infant 3.8 ppb 8.2 ppb 11.3 ppb
Other children 7 years or younger 5.9 ppb 12.9 ppb 27.3 ppb

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Posted in Drinking water, Emerging science, Lead / Also tagged , , , , | Comments are closed

When it comes to lead, formula-fed infants get most from water and toddlers from food, but for highest exposed children the main source of lead is soil and dust

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: February 3, 2017

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

On January 19, the Environmental Protection Agency (EPA) released a major new draft report proposing three different approaches to setting health-based benchmarks for lead in drinking water. We applauded EPA’s action and explored the implications for drinking water in a previous blog. One of the agency’s approaches provides useful, and surprising, insights into where the lead that undermines the health of our children comes from. Knowing the sources enables regulators and stakeholders to set science-based priorities to reduce exposures and the estimated $50 billion that lead costs society each year.

The EPA draft report is available for public comments until March 6, 2017, and it is undergoing external peer-review by experts in the field in support of the agency’s planned revisions to its Lead and Copper Rule (LCR) for drinking water. Following this public peer-review process, EPA expects to evaluate and determine what specific role or roles a health-based value may play in the revised LCR. With the understanding that some of the content may change, here are my takeaways from the draft:

  • For the 20% of most exposed infants and toddlers, dust/soil is the largest source of lead. Since we know that 21% of U.S. homes (24 out of 114 million) have lead-based paint hazards, this should not be surprising.
  • For most infants, lead in water and soil/dust have similar contributions to blood lead levels, with food as a smaller source. If the infant is formula-fed, water dominates.
  • For 2/3 of toddlers, food appears to provide the majority of their exposure to lead. This result was a surprise for me. EPA used data from the Food and Drug Administration’s (FDA) Total Diet Study collected from 2007 to 2013 coupled with food consumption data from the National Health and Nutrition Examination Survey collected from 2005 to 2011. In August 2016, FDA reported on levels of lead (and cadmium in food) commonly eaten by infants and toddlers based on a data set that is different from its Total Diet Study. FDA concluded that these levels, “on average, are relatively low and are not likely to cause a human health concern.”
  • For all children, air pollution appears to be a minor source of lead exposure. We think it is most likely because exposure is localized around small airports and industrial sources.

For a visual look at the data, we extracted two charts from the draft EPA report (page 81) that show the relative contribution of the four sources of lead for infants (0-6 month-olds) and toddlers (1 to <2 year-olds) considered by the agency. The charts represent national exposure distributions and not specific geographical areas or age of housing.

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Posted in Drinking water, Emerging science, FDA, Food, Health policy, Lead / Also tagged , , , , , | Comments are closed

California requires replacement of all lead service lines – but vigilance needed on implementation

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: January 19, 2017

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

In 2016, California became the first state in the country to make enforceable commitments to eliminating all lead service lines (LSLs) in the state.  These lead pipes that connect the main under the street to homes are the primary source of lead in drinking water and unpredictably release lead particulate when disturbed.  Under the leadership of Senator Connie Leyva, the state’s Senate voted unanimously, and the Assembly voted 72 to 7 to pass SB1398 to require drinking water utilities to inventory LSLs in use and then provide the State Water Resources Control Board (Water Board) a timeline for replacement of the lines.

Based on a national survey of utilities, the American Water Works Association reported that California has 65,000 LSLs out of 6.1 million nationally.  Large utilities have the most with 46,000 LSLs, medium systems have 4,700 and small systems have 15,000.  However, most utilities do not have an accurate inventory of LSLs, so the true number may be much greater.

California’s SB1398 recognized that an accurate inventory was critical and laid out a thoughtful two-step plan to accomplish the objective of full LSL replacement.  By July 1, 2018, it requires public water systems (PWS) to submit an inventory of known LSLs and a timeline for their replacement.  Two years later, PWSs must submit an updated inventory of LSLs and provide a timeline to replace any service line where it may be made of lead.  The law does not set a deadline for replacement that PWSs must meet.

This two-step approach makes replacing known LSLs the highest priority and, by essentially presuming that a service line is lead unless known otherwise, also creates an incentive for PWSs to develop accurate inventories in the next three years.

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Posted in Drinking water, Lead, Regulation / Also tagged , , , , , , , | Authors: / Comments are closed

With draft report, EPA takes major step to help communities assess risks from lead in drinking water

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: January 13, 2017

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

Communities around the country are testing their water for lead. But when they get the results, parents, public health officials, housing agencies and school officials have little guidance about what the number means and what actions to take or priorities to set. For lead in dust and soil in homes, child-care and schools, they have health-based numbers that serve as benchmarks for assessing risk. There is no such benchmark for drinking water. As a result, many are using the “Lead Action Level” of 15 parts per billion (ppb) as a surrogate. Yet, this level is based on the effectiveness of corrosion control; it has no relation to the associated health risks of lead exposure.

Yesterday, the Environmental Protection Agency (EPA) helped fill the void by releasing a draft report that provides three different approaches to setting a scientifically-robust “health-based benchmark” for lead in drinking water. The agency is seeking public comment on the draft and will convene a panel of scientific experts to consider each of the approaches.

The report is a critical step in implementing the recommendations of the agency’s National Drinking Water Advisory Council (NDWAC) which called for this type of health-based benchmark as part of an overhaul of the Lead and Copper Rule. The agency went a step further and provides alternatives to consider. We applaud EPA for its action and its rigorous, scientific analysis.

Accounting for the various models and assumptions, EPA developed a range of potential health-based benchmarks that range from 3 to 56 ppb of lead in water that people actually drink. However, you cannot readily compare these values to the typical water testing results reported by utilities or schools. Those tests are based on the first draw of water that has been sitting in the faucet and plumbing overnight and do not necessarily reflect what people drink over the course of a day. Later samples would likely be lower but could be higher if the building has a lead service line, especially if the line has been disturbed. Read More »

Posted in Drinking water, General interest, Health science, Lead, Regulation / Also tagged , , , , | Read 2 Responses

Perchlorate regulation: Critical opportunities for EPA and FDA to protect children’s brains

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: December 15, 2016

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

All Americans who have been tested have perchlorate in their bodies. Perchlorate threatens fetal and child brain development by impairing the thyroid’s ability to transport iodine in the diet into the gland to make a thyroid hormone, known as T4, that is essential to brain development. Both the Environmental Protection Agency (EPA) and the Food and Drug Administration (FDA) are scheduled to make decisions in 2017 that could significantly reduce exposure to this hazardous chemical.

Based on statements in a new report by EPA, we estimate that at least 20% of pregnant women are already iodine deficient, resulting in T4 levels that put the fetuses’ developing brains at risk. For this population of pregnant women, any perchlorate exposure results in an even greater risk of impaired brain development in their children and potentially a lifetime of behavioral and learning difficulties.

This is why it is critical that our public health agencies take actions to reduce exposure to perchlorate with a focus on this vulnerable population. There are three key decisions to be made in the coming year:

  1. EPA will decide in January 2017 whether hypochlorite bleach, an antimicrobial pesticide, degrades to perchlorate in significant amounts. If EPA agrees it does, the agency must set standards to limit that degradation as part of its 15-year update to the pesticide’s registration. Bleach is a widely-used disinfectant in food manufacturing facilities and likely a significant source of perchlorate in contaminated foods. Research shows that reducing hypochlorite concentration limits degradation and this, coupled with expiration dates on the product would significantly reduce exposure to perchlorate.
  2. FDA will decide whether perchlorate should continue allowing perchlorate to be added to plastic packaging for dry food at levels up to 12,000 ppm to reduce buildup of static charges. The agency has evidence that the perchlorate migrates from the packaging into food, especially when it flows in and out of the container. In response to a lawsuit filed by public interest organizations, FDA told a court that it aims to make a final decision by the end of March 2017. A 2008 report by FDA indicated that almost 75% of all food types are contaminated with perchlorate.
  3. EPA told a court that it will complete external peer review of a dose-response model in October 2017 and sign a proposed rule to regulate perchlorate in drinking water a year later. This model is a critical step in establishing a drinking water standard for perchlorate pursuant to its 2011 determination that an enforceable standard was necessary under the Safe Drinking Water Act. The perchlorate is most likely from contaminated source waters (e.g. from military and defense industry activities and some fertilizer use in agricultural regions) or from degradation of hypochlorite bleach used to disinfect water. EPA acted in response to a lawsuit by the Natural Resources Defense Council.

To guide their decision-making, FDA and EPA collaborated to develop a biologically-based dose-response model to predict T4 levels in pregnant women, fetuses, and infants exposed to perchlorate. EDF and NRDC submitted joint comments on the model and the summary report requesting that EPA ensure protection of fetuses during the first two trimesters for pregnant women with serious iodine deficiencies.  These fetuses are particularly vulnerable because their thyroids is not yet functioning. The current fetal model only considers the third trimester when the fetus has a functioning thyroid. The current model fails to adequately protect their vulnerable subpopulations, falling shot of both the EPA’s Science Advisory Board recommendation and the Safe Drinking Water Act requirements.

For decades, federal agencies have been charged with protecting children from environmental health risks with the recognition that they are uniquely vulnerable to chemical exposures. The upcoming decisions on perchlorate present critical opportunities to protect what many of us value the most—our children’s health and their ability to learn and thrive to their fullest potential.

Posted in Drinking water, Emerging science, FDA, Food, General interest, Health policy, Perchlorate, Regulation / Also tagged , , , , , , , | Comments are closed

Making federally-assisted housing lead-safe for children

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: November 30, 2016

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

Housing supported by the Federal Government should not be poisoning children.

That was the simple message Congress delivered to the Department of Housing and Urban Development (HUD) in the Residential Lead-Based Paint Hazard Reduction Act of 1992. Despite some real progress since then, recent cases of lead poisoning in federally-assisted housing in Chicago and Indiana suggest there is still much work to be done.

Thanks to a strong public push to highlight these failings, HUD recently proposed changes to its “Lead Safe Housing Rule.” At the heart of these changes is lowering the level of lead in children’s blood considered “elevated,” the trigger for local housing authorities to conduct detailed inspections of a child’s home for lead. HUD has continued to use a level of 20 µg/dL set in 1999, despite a consensus that lead is harmful to children at much lower levels. HUD is on track to finalize the rule in January 2017 after sending it to the Office of Management and Budget on November 21 for final review.  Jan. 13, 2017 update: HUD issued a final rule that was similar to what was proposed.

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