Improving How We Communicate​

the Risk

• The Need
• Federal Examples                  
• State Examples 
• Opportunities              

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Communicating the hazards posed by lead in water is challenging because the consumers have heard so much about lead, its sources, and its risks over the years. Once these understandings are established, expanding or updating them can be challenging.

​The public health community generally considers lead in drinking water as secondary to lead-based paint and that the water is safe if the level is below the lead action level of 15 ppb. They may not be aware that 15 ppb is related to the effectiveness of the utility’s corrosion control program and has no relationship to resident health. The concept that there is no safe level of exposure to lead for children or adults is difficult to act on since zero is nearly impossible to achieve since lead is ubiquitous in our plumbing, our homes, and our communities.
 
It is particularly difficult to communicate the risk posed by lead service lines (LSLs) for the following reasons:

• Lead and Copper Rule compliance sampling analyzes the lead concentration from the first liter of water that comes out of a tap. The first liter sample must come from a tap that has been stagnant for at least 6 hours. This first liter sample is not always representative of the “peak” lead levels that can be released to the tap.
• For homes with LSLs, the service line typically contributes the greatest percentage of lead to the tap. However, lead release is inherently variable and particles can break off at any time.

As long as residents or property owners are responsible for funding all or part of an LSL replacement, there are two situations where it is particularly important to communicate the risks posed by LSLs and whether they have one.

• When one of the residents is pregnant or is a child younger than six, especially if the child is dependent on infant formula for nutrition.
• When a resident considers whether to buy or rent a home. They have the option of selecting another unit. If buying, they could also have the seller replace the LSL as a condition of purchase or have the costs of LSL replacement added to the mortgage so the buyer makes the replacement later.

• In 2017, the federal government updated the “Protect Your Family from Lead in Your Home” booklet to expand the information provided on lead in drinking water from a few lines to a full page. Since 1996, when someone rents or buys a home built before 1978, the property owner or landlord is required to provide them with a copy of this booklet. The last update to the booklet was made in 2012. One new recommendation said “Contact your water company to determine if your home has a lead service line and to learn about lead levels in the system’s drinking water and water testing for residents.”
• In May 2018, EPA released an online resource highlighting communities that it identified as “Leaders in Lead Service Line Replacement.” 
• In December 2018, the President’s Task Force for Environmental Health Risks and Safety Risks to Children released a Lead Action Plan that said the federal government would “create an online portal to enhance, consolidate and streamline federal-wide communication to the public. Links will direct the public to agency-specific information.” 

• In 2017, Illinois enacted legislation which, among other requirements regarding LSL replacement, directed utilities to provide notice to occupants of residences potentially affected by construction or repair work on water mains, LSLs, or water meters at least 14 days before work begins. The notice must warn residents about the dangers of lead exposure and recommend practices to reduce exposure, including flushing and aerator cleaning.
• In May 2018, Ohio EPA updated the state’s Lead and Copper Rule to require specific practices when performing work that could disturb LSLs. Utilities must notify customers at least 45 days in advance of  replacing any portion of an LSL or conducting a water main replacement in areas with known or likely LSLs (unless work is an emergency repair). The notice is required to inform residents of the potential lead increase in drinking water, provide instruction of filter use, and provide guidance on other measures to reduce lead in water.
• In June 2018, Michigan Department of Environmental Quality filed new standards overhauling the state’s Lead and Copper Rule. Among other requirements, the rule identifies new standards for notification to customers if a water system has LSLs or service lines of unknown material. For such systems, the utility must include the number of LSLs, service lines of unknown material, and total service lines in the utility’s annual Consumer Confidence Report. Additionally, the utility must notify the owner and occupant of the property within 30 days of determining a service line is lead or when a new water account is opened if the property has known or presumed LSLs. 

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Opportunities to support efforts include:​

• USDA could develop educational programs and deliver them through the Cooperative Extension Service to help property owners who have lead pipes servicing private wells.
• State health departments could facilitate better communication between local health departments and utilities regarding lead in drinking water.
• State health departments could educate other professionals about LSL risks, including lead poisoning prevention program staff, lead risk assessors and inspectors, and home inspectors.
• Organizations such as the American Academy of Pediatrics and other trusted resources for the healthcare community could better educate their members on the risks posed by LSLs.
• EPA, Centers for Disease Control and Prevention (CDC), and philanthropic organizations could invest in research to identify, evaluate the best risk communications regarding lead poisoning prevention, and communicate the results to communities and utilities as the research develops.