More must be done to protect children and school staff from lead
A lead-in-water testing program is now underway in Philadelphia’s 218 District schools.
On Oct. 7, when the School District provided results and information from the lead testing completed so far, we saw that in about 50 drinking water outlets in 10 of the 22 schools for which data was available, lead levels above the current “Action Level” of 15 parts per billion (ppb) were found. In fact, 45 percent of results exceeding the Action Level did so by two to 18 times.
Many of the thousands of drinking water outlets in our schools are acknowledged to be in substandard condition. The current round of testing for lead in school drinking water was undertaken because concerns that came to light in Flint, Michigan; Newark, New Jersey; and other places raised questions about what was happening in Philadelphia and because Philadelphia City Council members held public hearings in March to look into the lead situation.
District representatives testified at those March hearings, and they made clear that they believed our school drinking water to be safe based on a round of testing conducted many years earlier. They also testified that they considered the previously in-place 20 ppb Action Level for lead in school drinking water still to be sufficiently protective of public health.
The District reported on the testing of about 30,000 drinking-water outlets between 1999 and 2010, concluding that all drinking water outlets were acceptably safe from lead and that additional testing was unnecessary. As we now know, that has turned out not to be the case. In fact, we believe that a detailed analysis of the information from that testing will show thousands of samples that were above the current Action Level of 15 ppb and for which no actions have been taken. This is an extremely concerning situation, one that should be immediately remedied by analyzing the 1999-2010 data now and removing from service all the outlets that were measured at levels above 15 ppb and that were not removed from use at the time.
When City Council members questioned District officials and recommended that all 218 schools be tested, the District agreed to again test drinking water, but only in 20 buildings. District managers also decided to collect only one sample – called a “first draw,” which is a sample collected after an outlet has been inactive for at least six to eight hours – from each school outlet tested. They began testing in March and April at H.A. Brown Elementary and then at Parkway Center City in May. An additional 20 schools have now also been tested between July 21 and Sept. 1.
Until late on Friday, Oct. 7, no public announcement had been made about results at the schools being tested, and no other information was made generally available.
As director of environmental science and occupational safety and health for the Philadelphia Federation of Teachers Health & Welfare Fund & Union for many years, I, too, testified at those City Council hearings in March. I then participated in Lead Task Force meetings with representatives of the School District, Environmental Protection Agency and Philadelphia Water and Health Department between March and June.
I supported the need for additional testing in all schools, highlighting the public health expert consensus that there was no safe level for lead exposure, and I recommended that the District use a 10 ppb Action Level, as is being done in Seattle schools.
I argued that the testing approaches and details needed to be quickly discussed and decided upon, including the collection of multiple, sequential samples and sampling at least a small percentage of hot water outlets. I recommended using a “Best Practices-Precautionary Principle” approach, in which we should err on the side of being overprotective rather than underprotective in establishing protocols and standards, especially because we are talking about the health of our children. I also called for much greater transparency and open data sharing.
As of late July, School District officials had supposedly decided to expand the number of tested schools to 40, although they were still reportedly planning to use the 20 ppb Action Level. However, when sample results from the 20 schools evaluated between July 21 and Sept. 1 were received, District representatives were apparently surprised and alarmed at the number of elevated samples and by some of the lead levels detected.
It is likely that this first set of results, our previously provided recommendations, and the City Council recommendations regarding universal testing resulted in the District embarking on its current program of testing all schools and now using a 15 ppb Action Level. These are positive steps, but more is required to better protect our children, and additional information is still needed.
Results have been reported for only 10 percent (22) of Philadelphia’s schools, but already 60 of the 390 samples – 15 percent – have been found to be above the latest Action Level of 15 parts per billion. Three samples above 150 ppb, more than 10 times the Action Level, were reported, along with one sample result of 279 ppb, more than 18 times the Action Level.
A very preliminary review of the data available on the District website revealed some issues of serious concern:
1) About 390 samples have been collected from 22 schools, and 60 samples (15 percent) are above the Action Level of 15 ppb.
2) 45 percent of the elevated sample results were at least twice the Action Level, with three samples more than 15 times the Action Level.
3) Twelve of the schools had no drinking water outlets with elevated lead levels. The 10 other schools, therefore, had an average of six outlets per school with elevated lead levels.
4) At two schools, Cramp Elementary and Ben Franklin High School, 50 percent or more of the outlets tested and reported had lead levels above the District’s standard. At Cramp, four sample results were above 100 ppb (more than six times the Action Level).
These numbers reflect a preliminary and initial analysis of published and available School District data – modification may be required once the District provides additional information, data and detail.
More now needs to be done to protect our children and our school staff from lead exposure, including:
1) Accelerated testing of outlets in all schools. The District’s 18-month timeframe is simply too long to wait.
2) Implementing a “Best Practices-Precautionary Principle” Action Level of 10 ppb.
3) Analyzing the sampling data from the testing conducted between 1999 and 2010 and identifying outlets that tested above 15 ppb at that time and taking immediate action to restrict student access to drinking water from those outlets.
4) Collecting multiple, sequential samples from tested outlets. This is an established “Best Practices-Precautionary Principle” approach being used by the Chicago School District, among others.
5) Collecting some samples from hot water outlets, as part of a “worst case” type of evaluation.
6) Implementing transparent, timely and open data-sharing approaches to promote improved credibility, trust, and accountability with the public, parents, and school staff.
7) Immediately providing all underlying data, including from the 1999-2010 testing.
8) Immediately reconvening the Lead-in-Water Task Force Working Group, with participation of all original members, in order to quickly develop a comprehensive testing and remediation plan.