Response to Oct. 31 Notebook article, "Lead testing of water in schools taking too long, advocates say."
I have long been concerned about the conditions in our schools that affect the health and safety of our children and staff. Exposure to lead, whether in water or paint, is one of the most worrisome conditions. The World Health Organization, American Medical Association, and the American Academy of Pediatrics have concluded that there is no safe level of lead exposure in our drinking water and that, to the extent possible, all lead exposure should be eliminated.
The June 2016 policy statement of the American Academy of Pediatrics reported: “Water typically contributes to about 20% of a child’s blood lead concentrations if the water lead concentration exceeds 5 parts per billion [ppb]” (emphasis added). Also reported in this policy statement is the conclusion that despite the current Action Level of 15 ppb established by the U.S. Environmental Protection Agency as an “administrative tool” to evaluate exposure, “the maximum contaminant level goal, the value the EPA deems acceptable for health, is 0.”
I applaud the District’s agreement to test all schools and drinking water outlets for lead, but more action is still needed in four key areas:
- Lowering the action level from 15 ppb to 10 ppb.
- Shortening the 18-month timeframe for sampling and reporting data from all schools.
- Reviewing and upgrading sampling practices and approaches.
- Requiring real transparency and substantive participation of stakeholders.
Lowering the action level
Based on the widely accepted consensus that there is no safe level of lead in drinking water, we should be enforcing a standard “as low as reasonably achievable.” A lower standard of 10 ppb is certainly achievable, practical, and is already in place in other school districts around the country. In fact, the mayor of Washington, D.C., has stated that he intends to lower the action level for lead in water for D.C. schools to 1 ppb after the American Academy of Pediatrics June 2016 report.
The Jefferson County Public School District, with 156 schools, is the largest district in Kentucky. It has been enforcing a 10 ppb standard for the last five years. St Louis, with 72 schools, also has a 10 ppb standard, as does Seattle in its 93 schools. Its superintendent stated: “The Seattle Public Schools considers student health and safety as a top priority.” Should we accept anything less in Philadelphia?
Timeframe to complete sampling
We should not allow children to continue to drink water that could have elevated levels of lead for 18 more months. This is simply too long, especially given the number of elevated lead results found so far and the potential health-related impacts.
Chicago has more than 560 schools, New York City has over 1,000 school buildings and the Los Angeles Unified School District had more than 750 schools when they tested the water for lead. All of these districts were able to test schools' water for lead in much less time than 18 months – ranging from about three to 10 months – to test roughly two to five times as many schools.
We should easily be able to test all of our school buildings in less than 18 months – at the worst, we should insist on completing all testing by the end of the current school year. In the meantime, the data from the 2000-2010 sampling should immediately be made public and all drinking water outlets that were measured to have exceeded 15 ppb but were less than 20 ppb and have therefore been left “in service” should immediately be turned off as a preventive and protective measure.
Better sampling practices and approaches
Details of the lead-in-water sampling protocols may be a bit technical to fully explore here, but there are concerns regarding the number of samples being collected by the Philadelphia School District (for example, Chicago collects five samples from every outlet tested while we are collecting only one); the number of outlets being tested (many fewer than were tested the first time testing was done in 2000-2010]; and the type (first draw, flush, etc.) of sampling being conducted. These issues must be examined in more detail to better evaluate the adequacy of the testing procedures.
Increased transparency and participation
Without fully accessible and comprehensive data, including a full explanation of the rationale for protocols used and the terminology found in data tables and reports, it is impossible to adequately evaluate and fully understand the current situation, risks, and necessary responses. The District’s 2000-2010 lead sampling data has never been made publicly available. This information may provide critical detail to inform how we proceed. It needs to be shared and looked at now.
The Lead-in-Water Task Force/Working Group that was established (on which I was invited to participate, until about five months ago) should be immediately restarted. School-building staff, parents, and the organizations representing them, particularly those with expertise in public health and safety in schools, should be included as the District drafts an improved Lead-in-Water testing plan.
Lead is a dangerous toxin that can result in long-term, irreversible neurological, behavioral, and other health damage to our children. We know that some of our schools have too much lead in the drinking water. We can do better with setting our standards, improving our sampling procedures, speeding up our testing, and living up to our stated goals and objectives about transparency, participation, and stakeholder collaboration, as other Districts have. We should take immediate steps to implement a more protective, transparent and stakeholder-engaged approach. Do our children deserve anything less?
Jerry Roseman, MScIH, is director of environmental science and occupational safety and health for the Philadelphia Federation of Teachers Health & Welfare Fund & Union.