Compliance With Mandated Testing for Lead in Drinking Water in School Districts in New Jersey.

Author:Sullivan, Marianne
Position:ADVANCEMENT OF THE SCIENCE - Report
 
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Introduction

Despite dramatic improvements, childhood lead exposure is an ongoing problem in the U.S. An estimated 0.5% of children had blood lead levels (BLLs) exceeding the reference level of 5 [micro]g/dL in 2013-2014, the level at which the Centers for Disease Control and Prevention recommends public health intervention should begin (Tsoi, Cheung, Cheung, & Cheung, 2016). Low-level lead exposure in childhood is associated with developmental effects such as problems with behavior and attention and decrements in IQ (National Toxicology Program, 2012; U.S. Environmental Protection Agency [U.S. EPA], 2013). As no level of lead exposure is thought to be safe for children, there is widespread agreement in the public health community that preventing lead exposure is critical for children's optimal health and development (Centers for Disease Control and Prevention [CDC], 2012).

In the U.S., efforts to prevent lead exposure in children have focused primarily on lead exposure in and around the home due to lead in house dust and in the soil from deteriorating lead paint (CDC, 2004). Though some public health experts have argued that drinking water is an important source of childhood lead exposure, there has not been coordinated state and federal action to address this issue (Renner, 2010). The U.S. Environmental Protection Agency (U.S. EPA) estimates that exposure to lead in drinking water could account for as much as one fifth of a person's total lead exposure (U.S. EPA, 2018). There is a growing understanding from a prevention perspective that it is important to control and minimize all sources of lead exposure in a child's environment, including from drinking water (Levallois, Barn, Valcke, Gauvin, & Kosatsky, 2018).

Lead in drinking water recently has become a significant national issue as a result of the crisis in Flint, Michigan. In 2014 and 2015, growing resident complaints, independent water testing by researchers at Virginia Tech, and media attention brought the Flint lead crisis into public view. Many households in Flint were found to have lead in water above U.S. EPA's action level. An epidemiologic study comparing children's blood lead levels before and after the city changed its source of drinking water attributed increases in elevated blood lead levels among children in certain Flint neighborhoods to contaminated drinking water (Hanna-Attisha, LaChance, Sadler, & Champney Schnepp, 2016). The Flint crisis heightened awareness among professionals and the public that lead in drinking water might be a more widespread problem in the U.S. than previously acknowledged due to aging infrastructure and a history of using lead in solder, pipes, service lines, and fixtures.

Lead in Water Standards

In 1991, U.S. EPA set the action level for lead in drinking water at 15 ppb and required drinking water providers to take action to reduce lead in water if 10% of their tap water samples exceed this level. U.S. EPA's non-enforceable maximum contaminant level goal for lead is 0 ppb, in recognition of lead's toxicity and the public health imperative to prevent any lead exposure, particularly among infants, children, and pregnant women (U.S. EPA, 2018).

After water leaves the water treatment facility, lead enters drinking water typically from lead service lines, lead-containing solder, or through lead-containing fixtures such as faucets or bubblers. Water that is corrosive is particularly of concern, as corrosive water can contribute to more leaching of lead from pipes or fixtures (U.S. EPA, 2018).

School drinking water has been identified as an important point of exposure to lead for U.S. children because many schools in the U.S. contain aging infrastructure such as pipes with lead solder and lead-containing bubblers, water fountains, or faucets. Additionally, because schools typically are in use for only 8-10 hours per day and not on weekends or during holidays, there are long periods of time in which water sits in the pipes, which can increase the migration of lead into drinking water (Lambrinidou, Triantafyllidou, & Edwards, 2010).

Lambrinidou and coauthors (2010) noted that the problem of lead in school drinking water has suffered from "systemic neglect," as U.S. EPA regulation has been minimal. Currently there are no federal requirements to test for lead in school drinking water unless the school "operate(s) their own public water system" (e.g., schools that use well water). In this instance, schools must follow the testing and remediation requirements of the Lead and Copper Rule (LCR), a federal regulation that requires periodic lead testing; however, the testing is not comprehensive and there is no requirement under the LCR to test all outlets where exposure could occur (U.S. EPA, 2017). According to the U.S. EPA (2017), approximately 8,000 schools and child cares in the U.S. are routinely required to test drinking water under the LCR; however, the vast majority of schools (598,000 schools and child cares) are not required to do so.

Childhood Lead Exposure in New Jersey

New Jersey requires blood lead testing for all children at 12 and 24 months of age. In

2015-2016, 26.8% of all New Jersey children

In New Jersey in 2016, likely due to heightened awareness of the issue because of the lead water crisis in Flint, Michigan, several high-profile cases of lead in school drinking water were reported in the press. One such case was the Newark Public School District: lead in excess of 15 ppb had been found in some drinking water outlets in district schools dating back to 2010. In 2016 the district was said to be taking steps to test all outlets and to publicly report results (McGeehan, 2016). Other districts also began to test and report on lead levels in their drinking water and some elevated results were reported.

Responding to public concerns, in May 2016 Governor Chris Christie ordered the New Jersey Department of Education to ensure that all New Jersey public school districts test for lead in all drinking water outlets in all district schools within 1 year and that the results be publicly posted for parents and students to view. Additionally, parents would have to be notified if lead in water at their child's school exceeded 15 ppb (Santora, 2016).

In July 2016 the New Jersey Department of Education, in consultation with the New Jersey Department of Environmental Protection, released the regulation corresponding to the Governor's Order, which provided detailed procedures for districts to follow when testing water for lead. The regulation specified that districts must develop a plumbing survey at all schools and sample all drinking water outlets in all schools and facilities within 1 year of promulgation, although extensions for another year were possible. Other...

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