{"id":8198,"date":"2018-10-16T16:18:11","date_gmt":"2018-10-16T21:18:11","guid":{"rendered":"http:\/\/blogs.edf.org\/health\/?p=8198"},"modified":"2018-10-16T16:19:49","modified_gmt":"2018-10-16T21:19:49","slug":"epa-updates-3ts-guidance-lead-drinking-water","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2018\/10\/16\/epa-updates-3ts-guidance-lead-drinking-water\/","title":{"rendered":"EPA Updates its 3Ts Guidance for Reducing Lead in Drinking Water"},"content":{"rendered":"

Lindsay McCormick,<\/a>\u00a0is a Project Manager.\u00a0Tom Neltner, J.D.<\/a>, is the Chemicals Policy Director.<\/em><\/p>\n

Earlier this month, EPA released its updated 3Ts for Reducing Lead in Drinking Water <\/em>Toolkit<\/a>, which provides guidance for schools and child care facilities seeking to ensure children are safe from lead in water.\u00a0 The new 3Ts \u2013 an update to the agency\u2019s 2006 guidance<\/a> \u2013 is now a web-based toolkit that includes modules, customizable templates, and factsheets.<\/p>\n

Overall, the new toolkit is an improvement.\u00a0 While the protocol itself is largely the same, the new toolkit is more user friendly and written for the non-technical audience, making it more likely that school and child care staff will use it.\u00a0 EPA has also reframed the toolkit from \u201cTraining, Testing, and Telling\u201d to \u201cTraining, Testing, and Taking Action\u201d \u2013 placing more emphasis on the critical step of addressing lead sources than the previous version.\u00a0 \u201cTelling\u201d is now integrated throughout the entire toolkit to highlight the importance of communication at every step. The agency has also developed a helpful flushing best practices factsheet<\/a>, which is a topic that often causes considerable confusion.<\/p>\n

In EDF\u2019s June 2018 report on our pilot of 11 child care facilities, \u201cTackling lead in water at child care facilities<\/em><\/a>,<\/em>\u201d we recommended EPA update its 2006 guidance to address four key gaps.\u00a0 The agency has made progress on the two most important of those but leaves the other two unresolved. The most important change to the guidance is that the agency has removed the 20 parts per billion (ppb) action level and instead recommends action whenever there are \u201celevated lead levels.\u201d While EPA does not define an elevated lead level, a deep dive into the appendix suggests that levels over 5 ppb warrant follow-up. The updated guidance also puts a greater emphasis on the identification of lead service lines (LSLs) and includes LSL replacement as a permanent control measure, though not as an explicit recommendation. Further, the agency did not update the protocol to deal with challenges posed by aerator cleaning and hot water heaters. \u00a0Below we explore each of these issues in further detail.<\/p>\n

Action level<\/u><\/strong><\/p>\n

The decade-old 3Ts guidance used an action level to trigger remediation of 20 ppb, a level that EPA recognizes is not based on health risks. \u00a0In our report, we recommended that EPA lower its action level from 20 ppb to 5 ppb as an interim measure \u2013 further lowering it once NSF International\u2019s leachability<\/a> standard (which allows new brass fixtures to leach up to 5 ppb of lead) is updated. We argued that a lower action level at child care facilities may be even more prudent than schools because they serve younger children that are more vulnerable to harm from lead.<\/p>\n

In its update, EPA has removed the 20 ppb action level from the toolkit but has not recommended a new action level. \u00a0The guidance states, \u201cIf testing results show elevated levels of lead in drinking water, then you should implement remediation measures,\u201d but EPA does not define \u201celevated lead level\u201d anywhere in the toolkit.\u00a0 The person using the toolkit is expected to define the term. \u00a0This strategy gives considerable leeway to schools and child cares to identify an appropriate action level for themselves (if their state or city has not already established one) \u2013 and has the potential to cause confusion.<\/p>\n

EPA does, however, provide some benchmarks illustrated through examples in the toolkit. The agency describes 1 ppb as \u201cclose to the detection level\u201d (page 39).\u00a0 Since lead is rarely found in source water, presumably, any level greater than detection is elevated.\u00a0 For additional clues, we reviewed Appendix D, which is designed to help the user pinpoint the source of lead, and found the following:<\/p>\n