The Time to Lead on Lead Is Now
| Author | Ronnie Levin |
| Position | Retired after 37 years working as a scientist for EPA. Since 2017, she has been a visiting scientist and instructor at the Harvard T.H. Chan School of Public Health |
| Pages | 59-59 |
NOVEMBER/DECEMBER 2021 | 59
Reprinted by permission from The Environmental Forum®, November/December 2021.
Copyright © 2021, Environmental Law Institute®, Washington, D.C. www.eli.org.
THE DEBATE
The Time to
Lead on Lead
Is Now
By Ronnie Levin
REPLACING all lead pipes in
the United States is compel-
ling, but complicated. Lead
pipes are the single greatest
contributor to elevated tap water lead
levels, or WLLs. ough not the only
source of lead in public and private
plumbing, where present such pipes
usually dwarf the contributions from
other lead sources.
e health impact alone compels
us to replace lead pipes. Lead is toxic
to everyone, although not all Ameri-
cans have the same lead exposures.
For most Americans currently, lead
in drinking water probably poses
the greatest exposure risk, weighing
particularly heavily on low-income
communities and communities of
color. Even the typically low levels of
lead in U.S. tap water can aect the
blood lead levels of local children —
that is, slightly higher WLLs translate
to slightly higher pediatric blood lead
levels. ese levels are not benign.
Research shows that even in com-
munities where drinking water meets
federal and state requirements, higher
WLLs are associated with poorer out-
comes in, as diverse examples, dialysis
patients and children’s performance
in school.
Lead’s adverse impacts are evident
at even the lowest levels. Eects are
detectable at every level measured,
and no threshold has yet been deter-
mined. Children aren’t the only ones
at risk — for example, there’s also
no threshold for lead’s impact on the
blood pressure of pregnant women or
older men. For many of these eects,
the dose-response relationship is
non-linear, showing a steeper slope at
lower exposures. is means that the
lower lead concentrations in drinking
water that serves the general popula-
tion cause greater damage, not less.
Maintaining public infrastructure
also provides a compelling reason
to replace pipes. Except in Chicago,
which mandated the installation of
lead service pipes until the federal
ban in 1986, most lead pipes in the
United States date to the Victorian
era, when cities were expanding rap-
idly to accommodate the Industrial
Revolution. Public water systems
serving burgeoning urban centers
chose to install higher-grade lead
pipes because they would last longer.
ose lead pipes are now 100 years
old and far beyond their useful lives.
e American Society of Civil En-
gineers estimates that in the United
States, a water main break occurs
every two minutes. ASCE also es-
timates that over 20 percent of the
water leaving a water treatment plant
never reaches a customer due to leak-
ing pipes. Beyond addressing public
health, lead pipe replacement would
also improve critical public assets.
However, these compelling argu-
ments are complicated by costs and
questions of who will assume respon-
sibility. ere are an estimated 6 to
13 million lead pipes buried in U.S.
cities. Replacing them costs on aver-
age $3,000-5,000 each; again, Chi-
cago is the outlier, with an estimated
cost of $25,000 per pipe. Cities that
have replaced all their lead pipes,
such as Lansing, Michigan, and
Madison, Wisconsin, reduced their
unit costs through improvements in
technology and productivity. Cur-
rently, over 100 cities in at least 13
states have committed to replacing all
their lead pipes.
Remediation is complicated fur-
ther by a lack of data on the number
of lead pipes that exist. In a recent
national survey, only 10 states could
estimate how many lead pipes they
have. More alarmingly, almost half
of states — 23 — admitted that
they still don’t know the location or
number of lead pipes in their juris-
diction. (is, despite the fact that
the 1991 Lead and Copper Rule
required water utilities to assess the
materials within their systems, in-
cluding lead pipes.) States must rst
commit to nding the lead pipes
that exist before they can begin to
replace them.
Ensuring safe drinking water also
requires corrosion control treatment,
eective monitoring, and enforce-
ment. Lead is a corrosion by-product;
utilities must control corrosion
while waiting for pipe replacement
funds and to control lead from other
plumbing sources. Monitoring tells
water utilities how much lead is
leaching into water. e asco in
Flint, Michigan, taught us that en-
forcement oversight is necessary.
is brings us to the biggest
complication: EPA’s and the water
industry’s failure to accept responsi-
bility for controlling lead exposures
from public water. Flint got national
headlines, but Flint is not unique. In
2015 and 2016, USA Today and the
Natural Resources Defense Council
both found that thousands of public
water systems serving millions of
Americans in all 50 states had lead
violations. EPA’s own audits docu-
mented that over 90 percent of lead
violations are not reported by states.
Protecting U.S. public drinking water
should be a responsibility shared by
EPA, state oversight agencies, and lo-
cal water utilities. But the behavior of
those three entities mirrors the three
monkeys: see nothing, hear nothing,
say nothing. Without newspaper cov-
erage and one valiant pediatrician, we
never would have known what hap-
pened in Flint.
e Biden infrastructure bill, if
passed, will provide a down payment
for these eorts, but it won’t fund
replacing all U.S. lead pipes. And it
won’t ensure lead-safe public drink-
ing water. Only a committed coali-
tion of federal, state, and local leaders
can ensure that — ones willing to
take responsibility and act. e time
for the buck to stop is now.
Ronnie Levin retired after 37 years working as
a scientist for EPA. Since 2017, she has been a
visiting scientist and instructor at the Harvard
T.H. Chan School of Public Health.
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