The DC WASA Case Study: Lead in Drinking Water

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The DC WASA Case StudyLead in Drinking Water
Marina S. Moses eohmsm_at_gwumc.edu The George
Washington University School of Public
Health Center for Risk Science and Public
Health [phone]
Metropolitan Washington Council of
Governments November 19, 2007
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Risk Communication Objectives

• Convey accurate information and facts
• Provide a framework for the public and the
  publics trusted interpreters to explain
  information
• Provide the people most concerned with
  information and context, from which to draw
  conclusions and/or make decisions for themselves.

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Lead Today An Overview

• Lead is the single most important toxic threat to
  children in the US.
• Lead poisoning is now rare, driven by lead paint
  exposure, imported items.
• Recent studies have changed perspective
• Neurodevelopmental effects
• Manifested as lower intelligence (IQ), impulsive
  behavior
• No threshold observation first molecule
• Disproportionate at lower levels.

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Sources and Exposure

• Blood lead levels have been going down in US for
  decades.
• US geometric mean 1.6 ?g/dL
• DC geometric mean 2.3 ?g/dL
• Current sources
• Legacy of leaded gasoline)
• Legacy of lead paint
• Secondary sources
• Food
• Drinking water
• However, frequency of elevated BLL in DC
• Still approximately 250 cases/y of elevated BLL
  (gt10 ?g/dL).
• Driven by lead paint

NHANESUS, children 1-5 yo,
2004
Distribution of blood lead in children lt 6 yo in
DC
?
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National Average Lead Exposure Source Distribution
These are averages there is great variation in
individuals! Source FDA
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Rising Lead Levels after 2000

• Chlorine was replaced with chloramine in 2000 in
  order to satisfy the new Disinfection Byproducts
  Rule. (Washington Aqueduct)
• Before, a high level of residual chlorine
  oxidized the lead to form an insoluble lead oxide
  (PbO2) scale.
• After switch to a weaker oxidant (chloramines),
  the lead was no longer being oxidized, started
  dissolving.
• Rise in lead levels started in mid-2001 but not
  immediately recognized. Circumstances disputed.
  (DC WASA)
• As in most old cities, primary source of lead is
  service line, which runs from main (lead free) to
  house.
• Part of service line is public (DC WASA), part is
  private (homeowner).

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Lead Service Lines
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Key Issues

• Simultaneous compliance
• Environmental risk communication
• Partly dictated by LCR
• Associated with risk management measures
• Filters on tap
• Flushing
• Expedited replacement for vulnerable families
• Public meetings
• Lead screening program (with DC Dept. of Health)
• Lead service line replacement (public portion)
• Required under LCR
• Homeowner compliance for private section
  replacement

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Simultaneous Compliance

• Water utilities are required to comply
  simultaneously with
• Lead and Copper Rule (LCR 40 CFR 141.80)
• Sets sampling strategy (very complicated)
• 15 ppb on first draw from tap lead action level,
  not an MCL
• Derived from corrosion control strategy
• LAL exceeded when 90th ile (i.e. 10 ) of all Pb
  tests performed are gt 15 ppb exceedance is not a
  violation
• No regulatory linkage with health standards,
  blood lead level
• Sets complicated response requirements when there
  is exceedance
• Microbial and Disinfection Byproducts Rule
• Water chemistry is very complex
• Addressing one issue may impact another (e.g.,
  disinfection byproducts)
• Analogy pulling thread from a carpet

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Emergence of Public Health Concern

• Increasing inquiries beginning fall 2003
• Assistance requested from DoH, initially helpful
• Dramatically increased after article in
  Washington Post 31 Jan 2004, A1 above fold
• Public health concern peaked in Feb-Mar 2004
• Sampling in schools in late March extended
  concern outside homes
• Sampling protocol for schools is very different
• Schools dont have lead svc lines sources are
  on property

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Risk PerceptionMedia Coverage

• Media coverage reinforced perception of public
  health crisis
• Perception of changing recommendation (flushing
  times)
• Washington Post 14 Mar 2004
• Downside of trying to accommodate new information
• Undermined confidence in future recommendations
• Homes identified (against WASA policy)
• Washington Post 18 Mar 2004
• Months later, reevaluation begins
• Washington Post 7 May 2004
• Lead activists in DC recognized priorities

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(No Transcript)
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Risk Perception

• Public was extremely alarmed and concerned about
  health effects.
• DC WASA addressed public concerns by technical
  explanations, committing to technical programs.
• Public outreach was intensive but initially
  ineffective.
• Credibility issues
• Contradicted in media

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Negatives in Risk Perception This issue hit
most of the bad notes
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DC WASAs Burden

• Out in front from beginning.
• Complexity of local context (e.g. primacy).
• Locked into LCR language. (Intended to prevent
  spin but also alarming to some readers.)
• Engineering culture of objectivity made it
  difficult to deal with emotionality.
• No large reservoir of trust to draw on.
• Adjustments in message came across as
  inconsistency.

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What factors were working against WASA?

• Consider the effects of the following
• Historic concern over lead in DC
• Fear of unknown publicity on lead
• Information vacuum
• Confusion over catastrophic v. incremental nature
  of hazard
• The Bhat case

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U.S. EPAs Seven Cardinal Rules of Risk
Communication
How did WASA do?
as formulated by
Vince Covello
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1. Accept and involve the public as a legitimate
partner
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2. Plan carefully and evaluate your efforts.
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3. Listen to the audiences specific concerns
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4. Be open, honest and frank.
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5. Coordinate and collaborate with other credible
sources
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6. Meet the needs of the media
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7. Speak clearly and with compassion
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Scorecard Tactics
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Which Cardinal Sins did WASA actually commit?

• Not coordinating message with other parties.
• Withholding information.
• Mixed messages.
• Failure to follow-up.
• Denying a mistake.
• Faking an answer.

• Detachment and remaining aloof.
• Unresponsive to peoples feelings.
• Explanations in jargon.
• Bureaucratic presentation.
• Wrong spokesperson at a public meeting.

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Lessons Learned

• Importance of documentation at key junctures
  (e.g. sample invalidation)
• Organizations that are grounded in a technical
  culture often have difficulty responding
• There was no public health crisis but
  presentation made it seem that way
• Media attention
• Unfolding of story
• Investigations, allegations of suppression (Bhat
  case)
• Perception that disclosure too slow
• Public education materials difficult to
  understand
• Activists moved on to reforming DC legislation

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Evidence Suggesting that Lead Service Lines
Contributed to Risk in DC

• Children from homes with lead service lines
  higher BLL
• Children from homes with lead service lines
  higher frequency of elevated BLL
• Source not documented for some cases elevated
  BLL
• Altho DoH concluded that there were no homes in
  which water was only lead source, documentation
  disputed
• House surveys reported by NPR without
  interpretation

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Evidence Suggesting Lead Service Lines Have Not
Contributed to Risk in DC

• Line status clusters with many other risk factors
  for lead exposure.
• Similar and sustained downward trend.
• Highest tap water lead levels not associated with
  elevated BLL -- No correlation between BLL, tap
  levels
• DoH assessment reported as showing no
  contribution
• Increase in BLL detected in 2001 does not fit
  timing
• Confined to one Ward with no service line
  implications.

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DC Blood Leads Not Very High Even With Water _at_ gt
300 Ppb
MMWR. March 30, 2004/53(Dispatch) 1-3.
http//www.cdc.gov/mmwr/preview/mmwrhtml/mm53d330
a1.htm
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Lead Service Lines

• Orthophosphate treatment is controlling situation
  now.
• Replacement required by LCR.
• Replacement is a permanent solution.
• Partial replacement is a proportionate solution
  only.
• Residual sources of lead
• Lead-containing fixtures in home
• Lead-containing fixtures in schools
• Private line if not replaced.
• Big sources untouched.

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Summary

• Risk communication approaches are critical in
  managing public health threats.
• Risk communication skills provide a framework on
  how to respond to public health concerns.
• Lessons learned can assist an organization in
  planning for the future but only if it retains
  the knowledge.