Lead in water: What level should prompt action?
March 2, 2017

Water utilities recognize corrosion control measures reduce lead exposure at a system-wide level, but there can still be elevated lead levels in individual homes.

So public health agencies, regulators and utilities are left to wrestle with a key question: What level of lead in drinking water should prompt action by households or assistance from public health experts?

The current 15 ppb action level leads some customers to assume all is safe at levels below, and unsafe at levels above. But water professionals know that figure isn’t health-based, but rather a measure of the effectiveness of corrosion control. 

More confusion could be on the horizon.

In January, the U.S. Environmental Protection Agency took an important step when it initiated a peer review of scientific modeling approaches to arrive at a health-based benchmark for lead in water. If, and when, the agency announces a new health-based figure – which may be different than 15 ppb -- utilities could face a barrage of questions from media and customers.

“Once this number or numbers come out, those of us that have been testing water for customers should be prepared to have our customers ask a lot of questions -- and if you haven’t been explaining that 15 ppb is not health-based, this may be difficult,” said Melissa Elliott, director of public affairs for Denver Water and chair of AWWA’s Public Affairs Council. “I’m concerned that we have utilities that are not ready for this.”

Elliott said she hears utilities say, ‘We’re below the action level,’ which to a customer means that their water is safe to drink, but it’s not the same thing.”

The peer review committee is expected to meet in June to consider several approaches to setting a benchmark. In the meantime, EPA has extended the public comments period for its draft to April 5.

Just this week, the Environmental Defense Fund recommended that families use benchmarks for formula-fed infants of 3.8 and 8.2 ppb, depending whether the infant lived in a home built before 1950 or not.

Benchmark Sought

The widely publicized Flint crisis put the longstanding 15 ppb action level figure on the public’s radar.
But even before Flint, numerous voices had called for a health-based benchmark for lead. Now that EPA is considering a health-based action level, utilities need to develop a communications game plan -- especially if the figure is lower than 15 ppb, which some insiders expect.

AWWA is preparing materials to help members communicate with their customers about lead in water as well as a health-based benchmark. Utilities can also refer customers to the Association’s online Lead Resource Community, which includes the latest on lead service line replacement and other topics.

The drive for a health-based action level focuses on the fact that children age 6 and younger are particularly susceptible to the effects of lead, which has been linked to learning disabilities, memory problems, and hyperactivity.

The formal road to a health-based benchmark began in late 2015 when the National Drinking Water Advisory Council recommended – and AWWA supported – establishing a household action level for lead in water, to be based on the amount it would take a healthy formula-fed infant to have a blood lead level greater than five micrograms per deciliter. The NDWAC recommended that if a water sample from a home exceeds this household action level, the local health department would be contacted to assist the family in deciding if and what actions they should consider.  

The results of the peer review that began in January are crucial as the agency considers revisions to the Lead and Copper Rule.

Communication key

Resolving this confusion requires overcoming communication challenges, said SteveVia, AWWA's director of federal relations.

“The NDWAC recommendation to create a household action level is intended to buttress the existing – and accepted – public education requirements of the LCR,” Via said, “and improve on the existing transparency provisions required when reporting monitoring results to customers.”

A new health-based number will help utilities guide their customers in figuring out how to handle lead in their drinking water, Elliott said. “It answers the question we get all the time: ‘Is my water safe to drink?’”

While the responsibility of premise plumbing issues ultimately falls to the homeowner, AWWA President Jeanne Bennett-Bailey said utilities need to meet the requirements of the LCR – and all regulations – in both substance and spirit.

“When we strive to protect public health, we’re trying to protect every family, every child,” Bennett-Bailey said. “So, until every tap is free of lead, we can’t be fully satisfied.”

Jeff Swertfeger, water quality superintendent for the Greater Cincinnati Water Works, said a new health-based benchmark for lead will help resolve a utility manager’s dilemma.

“What do we tell people who have a 5, 6, 7, or 8 ppb reading?” Swertfeger asked. “I have no idea what to tell them, so we just say 15 is the action level for us, but that there’s no safe level. So I don’t really know how to guide them, where they should take precautions, what they should do and how worried they should be. So I think having a health-based number would be very helpful for us in that case.”

Will some customers feel they were misled because they thought 15 ppb was a health-based number?

“I certainly think some people could feel that way,” Swertfeger said, “and I think our answer to that is, ‘The EPA has revised what level is important based on new data they have. This is what we have now.’ I think people will understand that.”

Consult with local health department

Tom Neltner, chemicals policy director for the Environmental Defense Fund, said utilities should talk now with state and local health departments -- before a health-based figure is announced – and explain how lead gets into water and what the utility does to keep levels low. That will help health agencies advise the public if, and when, EPA announces a health-based action level.

“That’s who people are going to be asking – it’s not the utility as much as the health departments,” Neltner said. “My sense is while utilities are trusted to talk about water and provide water, they are not seen as experts on health.

“If I were in a utility’s shoes, I would be building that connection now with the local health department. The utility will want to make sure their message is aligned with the health department’s because that’s who the public is going to believe. That’s who the pediatricians are going to believe.”

This week, EDF posted on its blog its take of EPA’s report and suggested levels that health professionals should use when providing advice to people who ask them what the water test results mean.

For formula-fed infants, the nonprofit group advocates a 3.8 ppb action level in homes built before 1950, and 8.2 ppb in homes built between 1950 and 1978. For other children up to age 7, it recommends an action level of 5.9 ppb in pre-1950 homes and 12.9 ppb in those built between 1950 and 1978. 

The numbers are lower than what some insiders expect EPA to recommend in part because they take other environmental exposures to lead into account. In homes where tests show no lead in the home’s dust and soil, EDF recommends a health-based benchmark of 11.3 ppb for formula-fed infants, and 27.3 ppb for other children age 7 and younger.

“This represents the idea that a child living in that home will have less than a 1 percent chance of having a level we think of as elevated,” Neltner said. “At EDF, we tend to be cautious when it comes to children.”

Neltner said it’s important to note the numbers are based on actual exposure. “The compliance sample that utilities typically take is not actual exposure. If you let water sit in a pipe for six hours and then do the sample, it usually overestimates the exposure.”

Part of the challenge is making sure the public understands the distinction between actual exposure readings versus a sample reading, Neltner said. “Because what will happen is some people may take the number and say, ‘Well, you’ve exposed me. You’ve poisoned my child.’”

A well-developed risk communications strategy includes explaining that even though water comes out of a treatment plant at 0 ppb, lead in plumbing and lead service lines can push household readings above the action level, Elliott said. A strong strategy can also help utilities guide customer response to a new health-based household action level.

“Our role is to make sure customers have the tools they need to take action, should they want to,” Elliott said. “As long as you give people constructive actions they can take to reduce their risk, they are okay.”

 

Do you have a comment or story idea for Connections? Please contact Ann Espinola at aespinola@awwa.org or at 303-734-3454.



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