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, is Chemicals Policy Director.
A on lead in drinking water shines a light on the Environmental Protection Agency’s (EPA) delays in releasing a health-based “household action level” for lead. EPA’s National Drinking Water Advisory Council that the agency develop this number to help parents, in consultation with their pediatrician and public health agency, decide whether to invest in a filter for the water they use to make up their child’s infant formula.
Without a health-based number, people are mistakenly using EPA’s current “lead action level” of 15 parts per billion (ppb) as the level below which no action is needed. The problem is that this level has no relation to the health risk. It is based on a provision in the drinking water rule that requires utilities to undertake corrosion control and, potentially, lead service line replacement when at least 10% of worst-case sample results exceed that level.
A year after committing to develop a household action level, it appears tied up in the agency’s long overdue overhaul of its broken 1991 regulation designed to protect people from lead in drinking water. Communities all across the country are raising legitimate concerns about the safety of their water and need proper public health guidance. They should not have to wait on rulemaking for this important information. I know EPA is a regulatory agency that thinks in terms of rulemaking. But first and foremost EPA is a public health agency with responsibility to consumers for the safety of drinking water.
I also understand the challenge of developing an estimate given that there is no safe exposure to lead— people may misconstrue the levels below the number as completely safe. On the other hand, in the absence of such a number, they are already mistakenly using the 15 ppb current lead action level to mean the water is safe and no action is needed.
There is precedent for setting health-based numbers for different lead hazards. The agency has done it for lead in soil and for lead in dust on floors or window sills. For lead in dust, EPA established 40 micrograms of lead per square foot of the floor of homes and child-occupied facilities as the that must be eliminated. This is equivalent to one gram – the same amount of sugar in a packet we add to our tea – spread evenly over about 1/2 of a football field. The agency set this level because it would “result in a of an individual child’s exceeding a blood lead level of 10 µg/dL” (the definition of elevated in 2001 when the rule was promulgated). While subsequent research showed that the risk of lead in dust was much greater and, , it still shows the value of providing people with a level at which a household should act.
These measurements help public health officials, housing agencies, and parents better assess the risk from lead hazards, determine what they should do to reduce the risk, and guide how they set priorities. A health-based number empowers people to make informed choices. The agency has done it for dust and soil. It needs to do it for water.
In February 2015, asked EPA to develop an estimated value for a household action level to help guide the workgroup's development of its . The agency agreed and provided updates in and reaffirmed its commitment in . No number has been released.
Given the developments in Flint and the evidence of lead in water systems throughout the country (as explained in a compelling ), delay is untenable. EPA must not wait on a proposed rule to act. It must focus its scientific expertise to developing a sound estimate, make it public, and use an external peer review process to ensure the science is strong.
For more information on the . See also .
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