From: The Honorable Bill Pascrell, Jr.
The water crisis in Flint, Michigan and across the nation has highlighted the urgent need to improve the public’s awareness of lead contaminated drinking water to ensure that our drinking water is safe. To inform the public sooner about lead contaminated drinking water we encourage you to sign our bipartisan letter to the Environment Protection Agency (EPA) as they undergo long term revisions of the Lead and Copper Rule (LCR).
In 1991, the EPA established the LCR to control and monitor the levels of lead in drinking water. The rule requires public water systems to take certain actions to minimize lead and copper in drinking water, reduce water corrosively, prevent the leaching of these metals, and replace lead service lines when other measures are not enough when an “action level” of 15 parts per billion (ppb) is exceeded in more than ten percent of tap water samples collected during any monitoring period. This level was established
at a time when EPA used a reference level of 10 micrograms per deciliter to identify children with blood lead levels that are much higher than most children’s levels. In recognition of lead’s high toxicity, the CDC cut in half the amount at which a child’s blood lead level requires reporting and possible intervention from 10 to 5 micrograms per deciliter. Despite the CDCs updating its recommendation four years ago, EPAs trigger for public notification and action on lead in drinking water has not changed.
In 2011, the World Health Organization established guideline of 10 ppb for lead on the basis of treatment performance and analytical achievability. Further, the European Union Council Directive on drinking water quality established 10 ppb in its standards for lead in 1998. While there are no safe levels for lead exposure, lowering the action level that triggers public notice can help to reduce the public’s exposure to drinking water contamination.
To sign on to the below letter, please contact Aileen Monahan in Rep. Pascrell’s office at
Aileen.Monahan@mail.house.gov, Leslie Haymon in Rep. Stefanik’s office at
Leslie.Haymon@mail.house.gov, Jordan Dickinson in Rep. Kildee’s office at
Jordan.Dickinson@mail.house.gov or Jeff Orzechowski in Rep. Miller’s office at
Bill Pascrell, Jr. Elise Stefanik
Member of Congress Member of Congress
Dan Kildee Candice Miller
Member of Congress Member of Congress
Dear EPA Administrator McCarthy:
As the Environment Protection Agency (EPA) undertakes revisions of the Lead and Copper Rule (LCR), we urge you to ensure it reflects the latest science on lead levels in drinking water and adequate notification of elevated levels.
We understand the LCR requires public water systems (PWSs) to take certain actions to minimize lead and copper contamination in drinking water (i.e., reduce water corrosivity to prevent the leaching of these metals), conduct public education if there is a lead action level exceedance, and replace lead service lines when other measures are not sufficient for the water system to avoid an action level exceedance of 15 parts per billion (ppb) in more than ten percent of tap water samples collected during any monitoring period. While the current action level was developed based on the practical feasibility of reducing lead through controlling corrosion, it was established approximately 25 years ago, at a time when our understanding of the negative impacts of lead were not as fully understood.
We strongly urge you to bring the current action level in line with the most up-to-date scientific research for PWSs as you undertake revisions to the LCR. In 1991, the EPA used a reference level of 10 micrograms per deciliter to identify children with elevated blood lead levels. As a result, 10 micrograms per deciliter became a benchmark for measuring progress in the implementation of the LCR. However, in 2012 the Centers for Disease Control and Prevention (CDC) recognized lead’s high toxicity by cutting in half – from 10, down to 5 micrograms per deciliter – the amount at which a child’s blood lead level requires reporting and possible intervention. Despite the CDC’s recognition of the negative health impacts of lead for children, the LCR still maintains an action level of 15 ppb. In 2011, similar to the CDC action, the World Health Organization established guidelines of 10 ppb for lead in drinking water on the basis of treatment performance and analytical achievability. The European Union Council Directive on drinking water quality also established 10 ppb in its standards for public notification.
While we understand the action level does not represent a health based standard, it is an important tool for triggering public notification and other actions to reduce the public’s exposure to lead drinking water contamination. The overwhelming consensus of major public health officials, federal and state public health agencies, and international public health organizations have long recognized is that there is no safe level of lead. This consensus has formed based on decades of scientific research and public
health documents demonstrating that it does not matter if a person breathes-in, swallows, or otherwise absorbs lead, there are negative health impacts from lead exposure. Further, the health effects from exposure to lead are especially concerning for pregnant women, infants, and young children – often disproportionately impacting minority communities and low income individuals. CDC reports that there are at least four million households where children are exposed to high levels of lead. Additionally, the CDC estimates there are approximately 500,000 U.S. children ages one through five with blood lead levels above 5 micrograms per deciliter, the reference level at which CDC recommends public health actions be initiated.
We urge you to establish a national clearinghouse of information for the public, as recommended in the Lead and Copper Rule Working Group report drafted by the National Drinking Water Advisory Council. We believe it is critical that the public and all levels of government are notified when a significant number of tests come back above the LCR’s action level.
Leadership by the EPA is essential to improving the effectiveness of corrosion control treatments to reduce exposure of lead in drinking water. While we understand this cannot be achieved by EPA regulation alone, we must put strong regulations in place to protect the public’s health and ensure that our drinking water is safe. We look forward to working with you in the future as EPA updates and implements the LCR. Thank you for your consideration.