Shared Responsibility for Risk?

Based on our discussion yesterday, I see a strong need for a health based standard not on water quality, but how water quality impacts people medically. The lead and copper rule (LCR) standard is necessary for water utilities to measure the content of water coming out of their plant and potentially through the distribution system. More discussion needs to happen around who is responsible for the water distribution once it leaves the plant. Every city is different and every city has citizens with different opinions on who bears the burden and the cost for pipe replacement. So how can we prevent lead poisoning of people through the water supply? What would be an effective health based standard that citizens impacted by the risk and those responsible for resourcing the fix, agree to. Blood lead levels (BLL) does not seem like a good metric to resolve this problem. As Dr. Simoni Triantafyllidou noted, BLL is contingent on so many different variables. How can governments or their contracted utilities agree to a standard with so many variables out of their control? Is it the governments’ responsibility in total to provide clean water with zero medical impacts? How would any institution be able to agree to that standard? How would a city or state budget for medical impacts on people? Where does the responsibility manifest today and what has resulted? I think we can see that the attempt or assumption of putting responsibility for medical impacts upon the government creates an environment where “risk” studies do not identify risk.

How can we bring those responsible for governing and those governed together in shared responsibility? I don’t think this idea can even be discussed in an honest and open way, unless the conversation can take place with full transparency without retribution. Science could be the mechanism where this takes place. A shared responsibility for science: data collection, research question development, monitoring, testing, loosening of definitive causality requirements for resourcing, analysis of risk – may create an environment where understanding of the science (trust of the information) becomes owned by all impacted. Could effective decisions on avoiding or mitigating risk and resourcing against that risk be prioritized or even accomplished if government and citizens through the shared mechanism of science, shared the responsibility for identifying and mitigating risks to include lead in drinking water?

 

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2 Replies to “Shared Responsibility for Risk?”

  1. These are critically important questions and at the center of many discussions about lead in water and the LCR. Currently, the LCR is a “shared responsibility” regulation in that a) it does not hold water utilities responsible for providing lead-free water at every tap, and b) it requires water utilities to keep consumers informed about the risks of lead in water and measures they can take to protect themselves from exposure at all times (i.e., when there is and isn’t a LAL exceedance). In my dissenting statement to the National Drinking Water Advisory Council (NDWAC), which issued recommendations to EPA for how the LCR should be improved, I argued that the LCR would be better able to provide the public health protection it was intended to provide if, at the very least, its gaps and loopholes were closed and its public education requirement were strengthened:

    https://www.epa.gov/sites/production/files/2015-11/documents/ndwaclcrstatementofdissent.pdf

    Today, the LCR’s public education component is so weak that most people lack the information they would need to assess their risk from lead in water and to take effective measures to protect themselves. How can there be an effective “shared responsibility” regulation that leaves one of the two responsible parties in the dark about their responsibility?

  2. Regarding a health-based standard: I am not sure how to process this question (although many do raise it and, as Dr. Triantafyllidou said, there is a proposal that was submitted to EPA for something named a health-based “household action level” — I, along with others, oppose this proposal because I am concerned that if implemented it would generate more false assurances than public-health protective action).

    The health-based standard for lead in water is zero. There is no debate about that. There certainly is debate about who is responsible for replacing lead-bearing plumbing materials (both LSLs and components inside the home) with lead-free plumbing, but until these debates are resolved (if they are resolved and it seems that solutions would be state-based rather than federal), what should happen to prevent additional exposures to lead at the tap?

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