White House to Announce Crucial Lead in Water Principles

On January 27, 2023, the White House will unveil new principles for lead in drinking water intended to improve health protections for affected families. The goal of these principles is to accelerate the replacement of lead pipes to ensure a healthier environment for all, and it will be achieved through a partnership between the U.S. Environmental Protection Agency (EPA), the White House, the federal government, states, tribes, local communities, water utilities, labor unions, private companies, and nongovernmental organizations, including NRDC. We expect the principles to emphasize critically important approaches to addressing lead in drinking water, including prioritizing overburdened and underserved communities, promoting full lead service line replacement, encouraging blood lead testing and robust community engagement, promoting innovative methods, and spreading best practices for lead pipe replacement. These are all important points and values that should guide any lead service line replacement program.

The White House’s principles are largely consistent with those announced in March 2022 by NRDC and many of our frontline and national partners, though they are less specific on some important issues and do not address certain key aspects of the problem that need to be tackled. In our and our partners’ 2022 document, we emphasized the need for:

• Community involvement and communication
• Prioritization of at-risk communities
• Government or water systems that fully fund service line replacement
• Economic justice, prevailing wages, and immigrant justice
• Innovative methods and avoidance of plastic materials
• Reduced cost and risk
• Lead testing afterward
• Provision of safe drinking water during lead service line replacement and for at least six months afterward
• Replacement of lead service lines as quickly as possible but in no event slower than 10 years
• Ensurance that property owner consent is not required as this has been an impediment to replacement, especially where absentee landlords cannot be found

The White House’s and EPA’s previous statements, including the White House’s December 2021 Lead Pipe and Paint Action Plan, committed to the goal of removing all lead service lines within 10 years. Additionally, last month, EPA filed court papers announcing that it would no longer defend the Trump administration’s January 2021 Lead and Copper Rule revisions, stating that the agency “expects to propose requiring mandatory replacement of all lead service lines” in the revised Lead and Copper Rule. It is crucial that President Joe Biden, Vice President Kamala Harris, and EPA continue to support removal of all lead service lines within a decade, and that the Lead and Copper Rule require full replacement of all lead service lines in that time period. We continue to strongly urge EPA to ensure full lead service line replacement within no more than 10 years under the revised Lead and Copper Rule, and that public water systems will fully pay for such replacement to avoid environmental justice problems and to help guarantee efficient lead service line replacement programs.

We also support blood lead testing for children. Medicaid rules already require universal blood lead testing of children who are qualified under that program at 12 and 24 months of age, and any child between 24 and 72 months with no record of a previous blood lead screening test must receive one. We also support broad testing of children who may be at risk because of their housing, lead service line, or other environmental and health risk factors. The American Academy of Pediatrics recommends: a risk assessment at the following well-child visits: 6 months, 9 months, 12 months, 18 months, 24 months, and at three, four, five, and six years of age. The recommendation is to do a risk assessment and do a blood lead level test only if the risk assessment comes back positive. According to the [American Academy of Pediatrics] and CDC, universal screens or blood lead level tests are not recommended anymore except for high prevalence areas with increased risk factors as described in a 2012 CDC report, such as older housing.

However, there should be no requirement that a child must be found to have elevated blood lead levels before a lead service line is required to be replaced or other action is taken to address lead exposure. We don’t believe EPA or the White House have or are likely to propose such an approach, and it is imperative that no one ever do so. There is a very short half-life of lead in blood; lead release from lead service lines can be very sporadic so it may not be detected by rare blood lead testing; and of course, once a child has elevated blood lead, it’s already too late. Lead can reduce children’s IQs, cause learning disabilities and hyperactivity, interfere with impulse control, and cause irreversible harm to the developing brain. We cannot wait for our kids to be poisoned by lead before taking preventative action. But if a health care provider finds a child with elevated blood lead, immediate urgent action is needed to reduce their lead exposure.

These provisions will help us meet our goal of getting the lead out faster and more equitably, which is a win-win for everyone. I look forward to attending the White House announcement today to celebrate this new partnership and our upcoming work to transform the country’s drinking water systems.