Michigan’s Department of Environmental Quality (DEQ) has changed its recommended “action level” for public school districts to take measures to deal with lead detected in drinking water. (An “action level” is when action is recommended or required by regulations.) The new standard lowers the recommended action level from 15 parts per billion (ppb) to 5 ppb of lead in drinking water, and comes as a result of East Lansing residents Shari and Patrick Rose pushing lawmakers and regulators to modify lead action levels in schools.
The DEQ presented the new recommended action level for lead in schools and daycares of 5 ppb in the most recent guidance document released by the DEQ’s School Drinking Water Program. The U.S. Environmental Protection Agency (EPA) has long had an action-level standard for drinking-water treatment plants of 15 ppb.
Public health experts indicate there is no known safe level of lead in drinking water, in part because lead accumulates in the human body rather than being simply flushed out over time. Past research has revealed that children are more susceptible than adults to the neurotoxic effects of lead.
If administrators for East Lansing Public Schools opt to comply with the new DEQ guidelines, East Lansing will be among the first school districts in the country to adopt this revised standard. Administrators for the district have not responded to questions from ELi on this matter.
The Roses, who are also East Lansing Public Schools parents concerned about the issue, called and wrote to lawmakers, regulators from the local to the regional, and drinking water experts. They tried to understand the meaning of the 15 ppb lead action level and why a non-health standard was being used in schools and daycares.
Michigan’s DEQ ultimately granted the Roses’ request for a lower action level for lead in school buildings, with a significant addition to an DEQ guidance document on school water quality. In the August 1st revision of that guidance document, a paragraph has been inserted on page 10 reading:
“The regulatory level for lead [15 ppb] is not a health standard. For this reason, the MDEQ is recommending that schools take action to lower the lead in their drinking water if the test results are over 5 ppb, which is the bottled water standard.”
Susan Kilmer from the DEQ, who is the head of the Air Monitoring Unit of the DEQ’s Air Quality Division in Lansing, confirmed that this new paragraph (the only significant change to the third version of the guidance document) also applies to a later clause on the same page of the guidance document. That now reads: “MDEQ recommends that any fixture with a result above the action levels should be labelled as ‘do not use’ until corrective actions can be completed. Discuss if a flushing procedure is an option based on sample results.”
The DEQ’s School Drinking Water Coordinator position was created in March of this year in response to requests from Michiganders worried about water quality in their public schools in the wake of the Flint water crisis. Kilmer was the interim School Drinking Water Coordinator for the DEQ at the time the new document was drafted. The DEQ is currently hiring a full-time staffer for the position.
My conversation with Kilmer suggests that DEQ’s most current recommendation to schools is to label all faucets that have lead readings over 5 ppb with “Do Not Use” signs until “corrective actions” are taken to reduce lead levels. But DEQ’s guidelines are voluntary. Schools can decide to follow them or not.
There is also no requirement for districts that are on community water systems, like East Lansing, to test their water, says Kilmer. Such testing, like that which ELPS did in March and April, May, and July of this year, would also be voluntary.
Additionally, inconsistencies currently exist between Michigan DEQ’s guidelines and the EPA’s guidelines. For example, in EPA’s statement on “Testing Schools and Child Care Centers for Lead in the Drinking Water”, schools are told to take action when samples exceed 20 ppb of lead. This document “needs to be revised,” Kilmer told me.
In general, Kilmer says, the issue of lead in drinking water is “an evolving learning curve for everyone,” and an issue that, at Michigan’s DEQ, was “not being looked at before.” However, the newly-minted School Drinking Water program believes that with enough investment, lead levels in schools “can go down to zero” with corrective measures such as fixture replacement, flushing, and point-of-use filters.
Measurement of lead can pose challenges. In an exchange with Shari Rose earlier this year, Miguel del Toral, drinking water regulations officer from EPA Region 5, pointed out that the high lead levels at ELPS were from particulate (or non-dissolved) lead. He said this implies that measured lead levels will fluctuate over time, and, as testing will only show a “snapshot” of the system at a particular moment in time, tests may show inaccurate numbers in either direction.
According to the Roses, this suggests that it is even more important to err on the side of caution and take corrective actions on faucets that have measured in excess of 5 ppb. Faucets would be marked “do not use” in accordance with MDEQ guidelines until those actions are taken.
The letter sent home to ELPS parents by Superintendent Robyne Thompson on September 1, 2016, which ELi reported previously, says that faucets exceeding 15 ppb of lead have been taken out of service. Brian Reeve, Supervisor of Operations and Maintenance for ELPS and the press contact listed in the Superintendent’s letter, has not returned phone calls from ELi seeking additional information.
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