Health Stream Literature Summary - Issue 50 - June 2008

DC Water and Sewer Authority and lead in drinking water: a case study in environmental health risk management
Guidotti, T.L., Moses, M.S., Goldsmith, D.F. and Ragain, L. (2008) Journal of Public Health Management & Practice, 14(1); 33-41.

This paper describes the experiences of the District of Columbia Water and Sewer Authority (DC WASA) in dealing with a high profile environmental risk management problem. The problem arose when efforts to comply with regulations requiring a reduction in levels of disinfection byproducts by switching from chlorination to chloramination caused an increase in lead levels. In 2002 the lead levels triggered a mandatory response program by the water utility under the Lead and Copper Rule. In January 2004 a front page report about the issue in a leading newspaper raised high levels of public concern with the perception that this was a major and urgent public health problem. Public and media concerns about the water supply declined several months later as the results of a screening program for children showed that lead in drinking water was not associated with elevated lead levels in blood. This case study reports the utility's response to the initial problem, the risk management options it faced and the magnitude of costs incurred.

DC WASA noted the following "lessons learned" from the experience:
• the significance of initial water monitoring changes was not appreciated as lead levels had not previously been of concern to the utility. Early results were dismissed as analytical errors and the focus was on regulatory compliance not on understanding system behaviour.
• the magnitude of the issue overwhelmed the capacity of existing resources for public communication, laboratory testing and pipe replacement work. It required several months to increase numbers of public relations and legal staff, develop laboratory and research capacity, hire contractors, and engage the required range of experts and consultants to address the issue.
• lack of public knowledge about the water system made it difficult to communicate risk messages.
• water suppliers need to be aware of potential trade-offs and unintended consequences that may result when practices are changed to achieve compliance with new regulations.
• information and applied research in a wide range of disciplines is needed to support utilities in their efforts to achieve simultaneous compliance with multiple water quality regulations.
• responses triggered under the LCR may not be effective in addressing public exposures as customers are seldom willing to pay to replace lead piping for which they are responsible. In addition, pipe replacement programs by the utility can be terminated once compliance is reached.
• the public notification, education language and activities specified by the LCR assume that most people will have access to written information at a high literacy level and understanding of complex scientific risk information. This was not the situation in Washington.
• this incident highlighted the need for preparation in risk communication and effective coordination between agencies. Neither the risk communication nor the crisis communication worked well during the period of concern as the basis for customer and public confidence had not been established.

The difficulties of simultaneous compliance with multiple regulations faced by the DC WASA is likely to be faced by other regulated utilities in the future. Management interventions to address one water quality issue may have unintended impacts on other water quality parameters. Monitoring activities should not simply focus on regulatory compliance but also on changes and anomalies in system performance that may foreshadow impending problems. The incident also suggests that utilities may benefit from having direct access to expertise on environmental risk management, and need to develop their own capacity to analyse and interpret health risk information. The US EPA is currently reviewing the implementation of the Lead and Copper Rule, largely as a result of this incident.

Comment See Health Stream Issue 47 for an article by Guidotti et al. describing the changes in lead levels and the public health response program in Washington DC.