Friday, September 25, 2009

** Breaking News **

Take a look at these important stories:

1. "School Drinking Water Contains Toxins": The Associated Press just published a story about lead and other contaminants in school drinking water. It makes the point that this is a largely unrecognized, national problem with serious public health implications.

2. "Troubled Waters Part II: On the Trail of the Lost Data"
: Today, the newsletter of the American Association for the Advancement of Science (AAAS) published a feature story by science writer Rebecca Renner about CDC's controversial 2004 report, which claimed that DC's historic lead-in-water contamination of 2001-2004 had no significant public health impact. This report is currently under Congressional investigation.

Part I of "Troubled Waters" appeared in the Spring issue of the AAAS newsletter and raised serious questions about the scientific integrity of a different paper that shares some authors with, and covers some of the same questionable data as, the CDC report. Published in 2007 in the journal Environmental Health Perspectives, this paper also claimed that the health harm from DC's two-and-a-half year lead-in-water crisis was insignificant (see our 6/16/09 blog entry).

3. Letter: You may also want to read a letter to the AAAS editor in response to Part I of Ms. Renner's "Troubled Waters." It is written by Dr. Tee L. Guidotti, the first author of the 2007 Environmental Health Perspectives paper and WASA's health advisor from 2004 to 2008. In July 2009, at the request of an independent review panel, Dr. Guidotti withdrew from his paper, and apologized for, the key conclusion that, "There appears to have been no identifiable public health impact from the elevation of lead in drinking water in Washington, DC, in 2003 and 2004. This may reflect effective measures to protect the residents, as 153 reported compliance with recommendations to filter their drinking water."

A few weeks later, Dr. Guidotti defiantly told the Washington Post that his study "showed no identifiable correlation between increased lead in D.C. drinking water and elevated blood lead levels" and that "the suggestion that our conclusion was published by mistake does a great disservice to me and risks creating panic in the community when none is warranted." He further asserted that he stands by his paper, which features "many" additional sentences reiterating the same no-identifiable-harm conclusion.

Serious questions about the Guidotti et al. paper remain. The letter in the AAAS newsletter is Dr. Guidotti's latest defense, which to us seems like a nonsensical setting up and knocking down of straw men that utterly fails to refute the problems discussed in Ms. Renner's "Troubled Water" piece.

Ms. Renner will be given the opportunity to respond in the next issue of the newsletter.

Thursday, September 10, 2009

Our Vision for a New WASA, with George Hawkins at the Helm

The news is encouraging. WASA has picked Director of the DC Department of the Environment (DDOE) George Hawkins as its new General Manager. Mr. Hawkins has been at DDOE only two years, but has made a name for himself as one of the most respected members of the Fenty administration. He is expected to start his new job in October.

Following the announcement of his selection, Mr. Hawkins told the Washington Post that his focus at WASA will be "all about the quality of the water and the quality of the environment." If that's the case, George Hawkins' WASA will be a welcome change from the WASA created by Jerry Johnson. Under the leadership of Mr. Hawkins, we can hope to see our water utility finally break out of its bunker mentality and into the 21st century. This evolution will necessitate a new, integrated and holistic vision, where drinking water quality, storm water runoff, sewage treatment, and environmental protection are no longer viewed as in competition with one another, but are recognized as interdependent and fundamental, and where thoughtful, innovative infrastructure and environmentally sustainable solutions are used to increase the safety of our tap water and decrease our environmental footprint at the same time.

Mr. Hawkins can certainly lead WASA in this direction.

In his short tenure at DDOE, Mr. Hawkins oversaw a vast restructuring of DC's childhood lead poisoning prevention program: fixing significant problems that made the city's management of lead and lead exposure ineffective in prior years; chairing a task force charged with coordinating and improving the work of multiple District agencies that address lead poisoning; hiring seasoned and progressive senior staff; and supporting smart changes in policies and procedures that are helping shift DC's approach on lead poisoning from reacting to poisoned children one by one toward preventing childhood lead exposure in the first place.

From his two years at DDOE Mr. Hawkins has also acquired rapid fluency in matters of lead at the tap. He served very thoughtfully as an alternate member of WASA's Board of Directors and helped push the agency to be more responsive to the public about numerous environmental concerns, including lead in drinking water. He also chaired the city's Water Quality Task Force, which was created in 2008 to conduct the first ever independent evaluation of DC's drinking water for lead. Although the task force has moved at the pace of a wounded snail, it has at least developed a sound proposal for a study that is comprehensive and avoids WASA's long-standing lead-hiding techniques. That's good news and nothing to take for granted in DC. We only hope that Mr. Hawkins' replacement at DDOE advances this important work with the same clarity of thought and scientific rigor.

Mr. Hawkins' DDOE took another long-overdue step. Five years after the city's unprecedented lead-in-water crisis, which was recently reported to have harmed hundreds if not thousands of infants and toddlers, DDOE finally checks the homes of all children under 6 with elevated blood lead levels (EBLLs) for lead-contaminated drinking water. DDOE can do better on this front with a tighter testing protocol, but it deserves great credit for its work so far.

That said, we might single out one development that disappointed us. In 2008 Mr. Hawkins, representing Mayor Fenty, officially opposed several basic and sensible provisions aimed at addressing lead in drinking water in a supposedly "comprehensive" lead poisoning prevention ordinance, over the strong objections of local and national lead poisoning prevention advocacy organizations. His stated reasons for the Administration's position were weak and, in our opinion, indefensible. However, Mr. Hawkins did support the idea of a separate bill focusing exclusively on lead at the tap. Such a bill is a good idea and direly needed.

In light of his overall record, the selection of Mr. Hawkins as WASA's new General Manager brings us hope that the day will come when WASAwatch is no longer needed. Mr. Hawkins' new appointment also challenges us to envision what a reasonable approach to lead at the tap would look like. WASA has always claimed that safe drinking water is one of its highest priorities. Yet its persistent failure to proactively protect public health, and its propensity to cover up its past misdeeds with misinformation has proved that the agency we depend on for clean and safe drinking water views the public as a nuisance worthy of little more than manipulation and deceit.

If WASA wants to restore consumer trust in its alleged commitment to safe drinking water, we urge it to consider the following actions:

1. Acknowledge the mounting evidence that in 2001-2004 many DC children were harmed by WASA's failure to properly notify the public about excessive levels of lead in our water.

2. Declare lead-contaminated drinking water a public health concern and develop a comprehensive plan to address it properly. In this plan include:
  • The replacement of those individuals across all echelons of WASA who, since 2001, have played an active role in hiding lead-in-water problems and deceiving the public about the associated public health risk. As we have stated before, former General Manager Jerry Johnson was not the only wrongdoer within WASA who helped weave the dangerous fabric of deceit and denial that exposed the public unnecessarily to hazardous levels of lead at the tap. If the other co-conspirators are not dismissed, Mr. Johnson's accomplices will continue to stand in the way of restoring the public's trust in WASA.
  • The restoration of WASA's lead-in-water monitoring program. WASA must make a public commitment to abide by the intent of the federal Lead and Copper Rule (LCR), which requires measuring worst-case lead-in-water levels in high risk homes under customers' normal water use conditions. As Mr. Hawkins knows, the method by which WASA has been checking the city's tap water for lead since 2001 is replete with trickery designed to miss worst-case lead-in-water levels. Until these problems are corrected, WASA's platitudes that our water is safe vis-a-vis lead will remain meaningless.
  • The implementation of a transparency policy that makes all WASA materials, meetings, data, contracts, studies, correspondence, and decision-making pertaining to lead at the tap accessible to the public. This includes fulfilling all outstanding Freedom of Information Act requests and erring on the side of disclosure whenever possible. Such a program must also commit WASA to online posting, in real time, of all information pertaining to the agency's lead-in-water monitoring program, including sampling and analytical protocols, home selection process, sampling instructions to residents, home addresses in the sampling pool, and lead-in-water test results with street numbers redacted only when residents explicitly request this option.
  • The implementation of a health-protective lead service line replacement program. WASA must once and for all make a public commitment to abandon a) the practice of counting a home's lead service line as replaced when tests in that home show lead-in-water levels below 15 parts per billion, and b) the partial replacement of lead service lines because, according to the utility's own data, such replacements can result in lead spikes of an undetermined duration. WASA must contact all 10,000 or so DC residences with partially replaced lead service lines to inform them about the possible long-term health uncertainties involved in such replacements and encourage them -- with clear information and financial incentives -- to replace the remaining portion of their lead pipe or protect themselves from lead spikes.
  • A clear separation of WASA's public health education program from the agency's public relations program. WASA must commit to delivering regular, clear, complete, and accurate information about lead in DC's drinking water to all its customers in residences, nursing homes, educational institutions, health care facilities, nursing homes, public recreational spaces, food service establishments, businesses, and government offices. This commitment should apply both when WASA meets the LCR lead action level of 15 parts per billion in over 90% of homes, and when it does not.

    WASA's outreach must include a description of the overall quality of DC's water vis-a-vis lead based on the agency's monitoring data, and must always explain that compliance with federal standards does not guarantee low lead-in-water levels at every home (see our 2/20/09 blog entry). WASA must emphasize that the LCR requirements do not cover day care centers, schools, food service establishments, offices, or commercial buildings, and must explain to the public that sources of lead in water include not only lead service lines, but also lead solder and leaded brass fixtures (i.e., plumbing components that exist in most DC buildings).

    WASA must routinely remind customers of the steps they can take to prevent exposure to lead at the tap in their specific environments. In its outreach, WASA must emphasize that the Centers for Disease Control and Prevention (CDC) advises children and pregnant women in homes with over 15 parts per billion of lead at the tap to use bottled water.

    To residents in high-risk homes participating in the agency's water monitoring program, to guardians of children with EBLLs, and to residents in homes with partial lead service line replacements, WASA must offer additional information that explains the meaning (and limitations) of lead-in-water test results.

    For advice on risk communication to the public, WASA should consider hiring a health professional who is nationally renowned for his/her expertise in childhood lead poisoning, has demonstrated knowledge about and research experience in the health effects of lead in drinking water, and has no record whatsoever of downplaying the significance of lead at the tap. As a first step, however, WASA must immediately retract all statements suggesting that lead in water is not a significant public health concern.
  • The facilitation of regular contact between WASA and the public, in order to improve communication and strengthen the city's lead poisoning prevention efforts as they relate to lead at the tap. For example, WASA ought to become a regular participant in all official meetings about lead poisoning elimination and dedicate at least one position on its board of directors for a representative from the city's lead advocacy community. With public health at the top of its agenda, WASA must ensure that its board members become vigorous and proactive overseers of all matters related to lead at the tap, while shedding their traditional role as the agency's largely uninvolved and uninformed apologists.
We are committed to helping Mr. Hawkins in the gigantic, but critically important, task ahead of him.

Yanna Lambrinidou
Parents for Nontoxic Alternatives

Ralph Scott
Alliance for Healthy Homes

Saturday, August 29, 2009

It Is Time for the CDC to Stop the Spin, Retract Its 2004 Report, and Apologize to DC

Remember back in April when Salon alleged that the Centers for Disease Control and Prevention (CDC) covered up harm from DC's 2001-2004 lead-in-water crisis through a highly influential, but also scientifically questionable, report? This report, coauthored by the DC Department of Health (DOH), claimed no significant public health impact from two and a half years of excessively high levels of lead at the tap, even among young children. The reassuring conclusion contradicted numerous prior research studies about the health effects of lead in drinking water as well as common sense.

Remember also that only hours after the online appearance of the Salon article, CDC issued a media statement characterizing Salon's claims as "inaccurate" and offering supposed rebuttals to them (for more information, see our 5/3/09 blog entry)?

We now have confirmation that, indeed, the CDC misled the public both in 2004 -- when it reported that the worst lead-in-water contamination in modern US history "might" have contributed only to a "small increase in blood lead levels," and in 2009 -- when it assured us publicly that Salon's criticisms of its 2004 no-significant-harm conclusion were unfounded. Shockingly, it looks like the CDC was actually aware of gross deficiencies in its data and analysis prior to the publication of its 2004 report, but failed to take simple steps to correct them.

The new revelations, covered in the Washington Post and the Public Radio International show Living on Earth and discussed in Congressional letters to the US Department of Health and Human Services and Mayor Fenty, came from the US House Subcommittee on Investigations and Oversight (of the Committee on Science and Technology). This Subcommittee has been looking closely at CDC's role in DC's 2001-2004 lead-in-water crisis (for more information, see our 3/22/09 blog entry). The Subcommittee's preliminary investigation, which sheds light on the data behind the CDC's 2004 report, supports Salon's allegations.

Here's some background:

To assess the public health impact of DC's 2001-2004 lead-in-water contamination, in early 2004 the CDC compared the percentage of DC residents (children and adults) with elevated blood lead levels (EBLLs) (i.e., equal to or above 10 micrograms per deciliter for children and 25 micrograms per deciliter for adults) for the years 1998-2003. They found that this percentage kept decreasing, despite the elevation of lead in the city's tap water, and concluded that if any harm had been done from the water crisis it was "small" and involved blood lead levels under the CDC's "level of concern" (i.e., 10 micrograms per deciliter).

But the CDC's dataset for children under 6 -- the age group most vulnerable to the effects of lead -- had an enormous hole. For 2003 -- the third full year of the city's lead-in-water contamination, when the public was still unaware of the problem and not taking systematic precautions to prevent exposure to high concentrations of lead at the tap -- the dataset included a significantly smaller number of blood lead test results as compared to the previous three years. The numbers of children tested per year as listed by the CDC are:

2000: 14,040 [175 children with EBLLs, or 1.2%]
2001: 16,042 [156 children with EBLLs, or 0.9%]
2002: 15,755 [122 children with EBLLs, or 0.8%]
2003: 9,229 [193 children with EBLLs, or 2%]

Since there was no apparent reason for a dramatic drop in blood lead testing in 2003, it looked like the CDC's database -- which came from the DOH -- was missing approximately 5,000 children's test results from a crucially important time period. By 2003, according to a peer-reviewed scientific paper in the journal Environmental Science & Technology (Edwards et al. 2009), some DC children were into their second or third year of exposure to high levels of lead in water. A thorough examination of blood lead levels from that time could have revealed health impacts that may not have been detectable at shorter exposure times and offered valuable insight into the true impact of DC's two and a half year lead-in-water contamination for the most vulnerable age group. If the missing test results included blood lead concentrations above 10 micrograms per deciliter -- which Salon alleged was the case -- their omission would have skewed the CDC's analysis by concealing harm.

In April 2009, the CDC admitted to Salon the absence of thousands of 2003 blood lead results from its study. However, it defended its no-significant-harm conclusion by claiming that all the missing results were below 10 micrograms per deciliter, and thus the missing data introduced no bias in the agency's analysis (on the contrary, the CDC suggested that the absence of these results probably exaggerated the percentage of children with EBLLs).

The CDC based its unsubstantiated assertion on information it allegedly obtained from DOH. The CDC's official story is that during the writing of its report, it asked DOH about the thousands of missing blood lead tests for 2003, and was told that the missing data had resulted from the failure of one commercial laboratory to report blood lead levels below 10 micrograms per deciliter (an omission that laboratories are not supposed to make).

To date there is no evidence that the CDC took any steps to confirm DOH's explanation before publishing its 2004 report or issuing its 2009 misguided media statement in response to the Salon article.

The CDC's lackadaisical approach to the missing data is especially troubling in the face of the following facts:
  1. The CDC was aware of serious problems with DOH's management of blood lead test results prior to the publication of its 2004 report. According to the Subcommittee, this knowledge "should have set off warning bells that CDC could not rely on the numbers being provided [by DOH] for public health statements."
  2. The DOH had known about the excessive levels of lead in DC's water since 2002, but had failed to take measures to protect the public until the Washington Post broke the story in 2004. Because of this history, the conclusion of the 2004 report -- which was supposed to determine whether the two-and-a-half year contamination had harmed DC residents -- would either incriminate or exonerate the DOH. By definition then, the DOH had walked into its partnership with the CDC with a clear conflict of interest, which may have compromised the integrity of the data it provided for the 2004 report.
Following the issuance of the CDC's 2009 media statement, WASAwatch posted a series of questions about the CDC's supposed rebuttal to Salon's allegations. Thanks to the US House Subcommittee on Investigations and Oversight, we now have answers to some of these questions:

Contrary to the CDC's claims, it looks like there was no one negligent lab that failed to report 5,000 blood lead levels under 10 micrograms per deciliter for 2003. After obtaining from the CDC the name of this alleged lab, the Subcommittee contacted it and learned that it "had continuously reported only elevated BLLs from 1999 until April of 2004," so there was no sudden change in its reporting practice for 2003.

Additionally, the Subcommittee did precisely the kind of data-checking that the CDC should have done before publishing its 2004 report. It requested all the 2003 data from all District labs that analyzed blood lead levels for DC children under 6. The Subcommittee found that the labs had reported to DOH several thousand more test results (i.e., at least 13,758 rather than 9,229) and several hundred more EBLL cases (i.e., at least 486 rather than 193) than the CDC included in its analysis. The Subcommittee's examination of this more comprehensive dataset revealed that at least 3.5% of DC children who were tested in 2003 had EBLLs, not 2%, as the CDC claims to this day. Shockingly, some of these children had blood lead concentrations more than 600% as high as the CDC's "level of concern."

The CDC, it thus seems, based its 2004 no-significant-harm conclusion on an analysis that omitted a majority of the children with EBLLs in 2003. In other words, the nation's premier public health agency allowed itself to compromise the integrity of its report and the soundness of its health message by embracing DOH's "negligent lab" theory unquestioningly. Moreover, it disclosed none of the problems with the missing data and DOH's conflict of interest in its report.

In its 8/3/09 letter to the US Department of Health and Human Services, the House Subcommittee stated that "CDC's inability or unwillingness to validate and verify the data it was being provided by [DOH] raises serious questions about the ability of the CDC's lead program to ensure the integrity of the data provided to it for other years [i.e., in addition to 2003] by DC as well as from other CDC cooperating states and cities."

More grave flaws in the CDC's 2004 no-significant-harm report that we outlined in our 3/22/09 blog entry raise additional questions about the ability of the CDC's lead program to ensure the trustworthiness of the public health information it provides to the public.

So what do the Subcommittee's new findings mean for DC?
  • During the third year of the city's unprecedented lead-in-water contamination, it is likely that more than twice as many cases of EBLLs among children under 6 were identified than the CDC and DOH claim. There is a distinct possibility that at least some of the unacknowledged cases did not receive necessary interventions to eliminate the lead exposure source(s) in the child's home and offer treatment when warranted.
  • In light of the fact that the number of children who were tested in 2003 (to the best of our knowledge, about 13,758) was far smaller than the number of children who lived in DC at the time (approximately 39,356), it is likely that many untested children also experienced EBLLs, but their condition went undetected.
  • The CDC's claim that there was no significant rise in EBLLs from DC's lead-in-water contamination is utterly unsubstantiated and, in the context of a 2009 peer-reviewed scientific study and an unpublished 2007 CDC analysis that did find harm, most likely false.
  • Had the CDC's 2004 analysis not excluded thousands of crucial blood lead test results, it may have revealed significant harm from DC's lead-in-water contamination. In that case, the CDC's 2004 report would have presented a very different conclusion than the one published, and DC may have taken measures it still has not taken to educate the public about the hazards of lead at the tap and protect children from future exposures. Other cities in the US and internationally that have used the CDC's report to downplay the health risks of lead-contaminated water may have also responded to their own lead-in-water problems in a more appropriate and health-protective way.
The CDC is supposedly the nation's premier public health agency whose statements have great influence over personal behaviors and public policy. Yet its 2004 report about DC's historic lead-in-water contamination reveals a severely botched response to a serious public health crisis that reflects gross governmental irresponsibility and negligence. Not only were DC residents exposed to two and a half years of astronomical levels of lead at the tap but, thanks to the CDC, we were also misled into believing that our children survived the contamination essentially unscathed and that elevated levels of lead in water pose practically no health risk.

Even worse, the CDC continues its no-significant-harm spin to this day, despite the fact that it has been unable to refute any of the serious allegations against the integrity of its report or say why a study using such a severely compromised dataset should be considered credible at all. In response to the 8/7/09 Public Radio International story, the CDC lamely re-asserted that its 2004 analysis identified no children "with BLL 10 ug/dL, even in homes with the highest water lead levels."

This statement is outright inaccurate because for every year between 1998 and 2003, the CDC did identify children with EBLLs -- it just didn't identify a dramatic rise in EBLL cases in 2003. Second, this statement fails to address the problem of the missing blood lead test results, which was the sole focus of the Public Radio International piece. Third, this statement does nothing to refute the apparent fact that the CDC's 4/10/09 assertions have now been shown to be as flawed as the agency's original report. Fourth, this statement does not disclose the disturbing detail that the CDC looked only at 17 children who resided in homes with the highest water lead levels, and these children had stopped drinking unfiltered tap water months to a year before their blood was tested for lead (for more information, see our 3/22/09 blog entry). Because blood lead levels tend to drop quickly after exposure is stopped, the chance of finding high lead in the blood of these children from high lead in water was minuscule to non-existent.

It is deeply worrisome that five years after the publication of its misleading report the CDC is still disseminating deceptive information about the health impact of lead-contaminated water, while at the same time refusing to answer simple questions from the public about its report's validity (for more information on CDC's stonewalling, see our 2/25/09 blog entry). It is equally disturbing that the CDC has failed to release all the information requested by the US House Subcommittee on Investigations and Oversight (see p. 5 of the Subcommittee's 8/3/09 letter to the US Department of Health and Human Services).

Congressional hearings about the CDC's involvement in DC's 2001-2004 lead-in-water crisis are likely to take place in September.

In the meantime, the CDC's Lead Poisoning Prevention branch would be well-advised to show a modicum of respect for sound science and public health by stopping its destructive spin, retracting its 2004 report, and apologizing to DC for downplaying a serious -- and in some cases ongoing -- public health risk.

Tuesday, June 16, 2009

WASA's Health Advisor to Apologize for "No Identifiable Harm" Claim in Study about DC's Lead-in-Water Crisis

Today's Washington Post focuses once again on the controversial 2007 study in the journal Environmental Health Perspectives (EHP) titled "Elevated Lead in Drinking Water in Washington, DC, 2003-2004: The Public Health Response." The study erroneously concluded that the District's historically unprecedented lead-in-water contamination a few years ago had no identifiable public health impact.

In February of this year, questions were raised in the media about the principal author's financial and contractual ties to WASA, and whether he complied with EHP's conflict of interest disclosure requirements. Specifically, the contract between WASA and Tee L. Guidotti, MD, former department chair at the George Washington University School of Public Health and WASA's health advisor, stated that:
Publication or teaching of information specific to DCWASA, specifying DCWASA by name and directly derived from work performed or data obtained in connection with services under this Agreement, must first be approved in writing by DCWASA.
According to a review panel that was convened to investigate the matter, Dr. Guidotti was found not to have been constrained in what he wrote by WASA, and the panel concluded that Dr. Guidotti neither attempted to deceive readers nor to subvert the publication process. However, Dr. Guidotti agreed to issue an apology for, and correction of, his paper's "no identifiable harm" conclusion. This crucial and objectionable conclusion mysteriously managed to get printed despite the directive of EHP to remove it from the final draft.

"How many lawyers did it take to produce this whitewash?" asked a seasoned lead poisoning prevention advocate today when the subject of the panel's findings came up at a meeting about childhood lead poisoning in DC.

The question seems justified. Internal e-mails in our possession show that Dr. Guidotti was in regular communication with WASA about his manuscript. Moreover, the WASA/George Washington University contract paid $750,000 over 3 years (2004-2006), and remained active into 2009.

In our opinion, if one is paid handsomely to "advise" a utility about the health effects of lead-contaminated water that the utility delivered to the residents of a major city for an extended period of time without disclosing the problem, they really don't need to be told by their client what their public statements about health effects ought to be, or that they should do anything in their power to minimize their client's legal liability.

Dr. Guidotti reinserted into his manuscript for EHP the sentence, "There appears to have been no identifiable public health impact from the elevation of lead in drinking water in Washington, DC, in 2003 and 2004," after having removed it to satisfy reviewer criticisms and get the paper accepted for publication. This statement was highly favorable to Dr. Guidotti's client, WASA, which had been criticized severely for placing DC residents at risk of exposure to excessive levels of lead in drinking water for two and a half years during 2001-2004. In fact, the controversial sentence was virtually identical to words in a 2006 press release issued by WASA itself claiming that testing confirmed "no identifiable public health impact from elevated lead levels in drinking water" during the city's lead-at-the-tap crisis.

With or without conclusive evidence that WASA told Dr. Guidotti what to write, Dr. Guidotti published a statement about health effects that was not supported by facts and that helped exonerate his client.

We thank EHP for requesting an apology for and correction of the misleading statement from Dr. Guidotti, especially since Dr. Guidotti seemed intent on defending his paper's conclusions even as recently as a few months ago:
  • On 2/13/09, Dr. Guidotti told the Washington Post that he "did not recall a disagreement" with EHP on the controversial sentence.
  • On 2/17/09, Dr. Guidotti wrote a "To my colleagues" e-mail stating that his paper's conclusions were "agreed upon by the Department of Health, EPA, and CDC." That same day, George Washington University's Hatchet (the school's student newspaper) reported him saying that his paper's conclusions were "accurate."
  • On 2/20/09, Dr. Guidotti wrote to Washington City Paper that he stood by his paper's conclusions.
Clearly, these earlier statements seem to contradict the new claim that Dr. Guidotti's reinsertion of the "no identifiable harm" conclusion was inadvertent.

Thankfully, however, this latest development provides a fitting end to a harrowing public relations campaign by WASA, which tried to convince DC residents that our water's unprecedented contamination in 2001-2004 caused no significant health harm. Dr. Guidotti will no longer be able to repeat publicly the "no measurable impact" mantra, unchallenged.

We take the forthcoming apology and correction as a retraction of Dr. Guidotti's key conclusion from the scientific record, but how does one retract an erroneous, misleading, and falsely reassuring statement about health risk from the public sphere? Over the years, Dr. Guidotti's EHP paper was disseminated to many DC residents at WASA's community meetings, and Dr. Guidotti himself made numerous public presentations recapitulating his EHP paper's presumed main points (see, for example, the 2008 video clip below).

We consider EHP's intervention only a first step toward addressing the remaining -- and, unfortunately, even more serious -- questions about the scientific integrity of the oft-cited Guidotti et al. paper.

On February 25 of this year, Marc Edwards, PhD, environmental engineer and lead corrosion expert at Virginia Tech, told WASAwatch that the featured study in the EHP paper never existed (i.e., the 65 children who had elevated blood lead levels, whose homes were supposedly tested by the DC Department of Health and always contained significant sources of lead other than water). Dr. Edwards made the same statement on February 3 in a meeting that included one of Dr. Guidotti's EHP co-authors, who didn't refute it. For obvious reasons, it troubles us that Dr. Edwards' assertion may be correct.

We are aware that EHP has in its possession an 80+ page letter of concerns from Dr. Edwards regarding the scientific integrity of the controversial Guidotti et al. paper. We hope and trust that EHP will address these concerns with complete and cogent responses, in a timely fashion.

After two and a half years of exposure to excessively lead-contaminated drinking water, and another five years of misleading assurances about the health effects of this exposure, DC residents -- and the world community at large -- deserve to know unequivocally which of the published claims about the DC lead-in-water crisis are based on real and valid data.

Yanna Lambrinidou
Parents for Nontoxic Alternatives

Ralph Scott
Alliance for Healthy Homes

Paul Schwartz
Clean Water Action

Video clip: Dr. Guidotti talks to DC residents about lead at WASA's February 4, 2008 community meeting at the Old Naval Hospital in Capitol Hill. He asserts that the health impact of DC's lead-in-water crisis was studied extensively and, contradicting recent revelations of significant harm, that there was no evidence of a detectable health effect on DC's children. Echoing his EHP paper, he posits that:

a) Lead in drinking water is a minor source of exposure, without offering evidence that this is the case even when lead-in-water levels are as high as the levels in DC in 2001-2004, and without addressing the well-established vulnerability of infants dependent on formula and young children;

b) DC residents probably received an additional layer of protection from exposure to high lead in water due to WASA's flushing and filtering recommendations, without revealing that these recommendations were issued in 2004, after the media broke the story and many members of the public had already consumed contaminated tap water for two and a half years (the EHP paper erroneously states that WASA's flushing and filter-distribution program was launched in 2003).

This talk was attended by representatives from the Centers for Disease Control and Prevention (CDC), who expressed no objection to Dr. Guidotti's claims (for more information about the CDC's involvement in DC's lead-in-water fiasco see earlier WASAwatch blog entries).

Sunday, May 3, 2009

What the CDC Can Learn from the National Research Council and the Public

In 2008, the National Research Council (NRC) -- a nonprofit institution under the auspices of the National Academy of Sciences that works to improve government decision making and public policy -- published the book "Public Participation in Environmental Assessment and Decision Making." NRC defined "public participation" as "organized processes adopted by elected officials, government agencies, or other public- or private-sector organizations to engage the public in environmental assessment, planning, decision making, management, monitoring, and evaluation." NRC's goal was to determine how public participation in environmental decision making affects the assessment of environmental problems and the development of public policy relating to these problems.

NRC concluded that:
"When done well, public participation improves the quality and legitimacy of a decision and builds the capacity of all involved to engage in the policy process. It can lead to better results in terms of environmental quality and other social objectives. It also can enhance trust and understanding among parties."
The central premise behind NRC's thesis was that, by its nature, environmental decision making is complex because it involves choices that are political, social, cultural, and economic, at least as much as technical and scientific. NRC straightforwardly acknowledged that, "There typically are multiple perspectives regarding the relative importance of issues, the best courses of action, and even the right questions to ask, with strong demands from those who may be affected by policy choices to have their voices heard."

In other words, delegating too much decision-making authority exclusively to technical experts and government officials amplifies narrow interests and understandings, while drowning out public knowledge, needs, and definitions of what constitutes an "appropriate" response to an environmental problem. According to NRC, since the 1960s, US environmental policies that left out public views have often been criticized as "bad" and "out of touch" by the communities they affected. Today public participation theorists and practitioners generally agree that good environmental policy decisions incorporate the goals and concerns of all stakeholders, including the public.

NRC's findings help elucidate a central problem with the Centers for Disease Control and Prevention's (CDC) latest move in relation to DC's lead-in-water fiasco:

On April 10, CDC issued a media statement in response to a Salon article, which alleged that CDC withheld evidence of childhood lead poisonings from DC's 2001-2004 lead-in-water contamination. Salon revealed new information about thousands of missing blood test results from the influential 2004 CDC report that found that two and a half years of astronomically high levels of lead in DC's drinking water did not cause significant harm. The CDC report misled communities around the country into believing that lead in water does not constitute a serious health risk. Salon also exposed that in 2007, CDC presented data at the annual meeting of the American Public Health Association (APHA) showing that, in fact, in 2001-2004, many DC children experienced blood lead levels (BLLs) above the CDC's "level of concern" due to the city's lead-in-water contamination. CDC chose not to publicize these findings (CDC's 2007 presentation is available on the APHA website for a fee; for additional discussion on CDC's 2004 report, see our 2/25/09, 3/22/09, 4/20/09 blog entries).

CDC's media statement was posted online hours after the publication of the Salon article to purportedly address "inaccuracies" in the Salon piece and reassure the public of CDC's commitment to lead poisoning prevention. CDC focused on the following six issues:
  • The conclusions of its 2004 report
  • The missing blood test results from its 2004 analysis
  • Allegations of scientific misconduct in relation to the 2004 report
  • CDC's communication (or lack thereof) of its 2007 findings to appropriate city and federal officials
  • CDC's decision not to publicize its 2007 findings
  • The relationship between the 2004 report and a January 2009 study, which found that hundreds if not thousands of DC infants and toddlers experienced BLLs above the CDC's "level of concern" due to the 2001-2004 lead-in-water contamination.
A close reading of CDC's media statement makes it obvious that CDC, unable or unwilling to refute the serious questions raised by Salon, chose to stay on the path of deception and obfuscation in order to try and salvage its reputation, at the expense of public health. CDC's responses to the above six issues were strikingly elusive. They either avoided the questions completely, or they made assertions that lacked critical supporting evidence. Simply put, they made little sense, leaving one confused and frustrated. To add insult to injury, they were clumsily sandwiched between opening and closing statements of self-praise about CDC's exemplary work in protecting children from the dangers of lead.

Any parent of a young child in Washington DC would want to see the CDC ably, confidently, and cogently refute the Salon findings with credible evidence. Any parent of a young child in Washington DC would also want to know that CDC respects their intelligence and educates them about public health issues with direct, honest, and accurate information that addresses their worries about their child's health. Any parent of a young child in Washington DC would hope and expect that CDC cares more about the health of their child than the advancement of its own institutional interests. Yet the CDC's response to Salon failed miserably to satisfy any of these standards.

In contrast to NRC's findings about public participation in environmental decision making, one sees that CDC, in its latest attempt to defend itself against Salon, made a strategic decision that did not take into account the public. Specifically, CDC did not regard the DC public's acquired knowledge about the science and politics of lead in drinking water, and our grave concern about the implications of the long term exposure of thousands of fetuses, infants, and young children to astronomical levels of lead at the tap.

What happened to our city's children in 2001-2004, and how they may be harmed as a result is a profoundly serious matter to us. After 5 years of disinformation about the facts of lead in water, DC deserves answers that are based on strong science and solid evidence. We can no longer accept authoritative but unsubstantiated statements blindly. We have learned to tell truth from spin. And our patience for spin has ended. In addressing our concerns, CDC must understand that unscientific, inaccurate, misleading, or imprecise information has no place in its public health messages to DC, especially when those messages are delivered purportedly to "correct" allegations backed up by science and facts of CDC wrongdoing involving data, conclusions, and decisions that had and continue to have a direct impact on our children's health.

Given its shameless evasiveness, CDC's statement of April 10 appeared as a desperate attempt to pull the wool over the public's eyes, one more time. If CDC is truly concerned about protecting children from lead in water, it might want to consider alternative answers to the six questions it chose to address. Below, in red, are some recommendations for a more responsible, appropriate, and respectful statement (CDC's original text is in black).

***
Media Statement

CDC Responds to Salon.com Article


For Immediate Release: April 10, 2009
Contact: CDC Division of Media Relations, Phone (404) 639-3286

An April 10, 2009 article appearing on Salon.com inaccurately represents the Centers for Disease Control and Prevention's (CDC) 2004 public health response to a request from the Washington D.C. Department of Health for assistance concerning lead in water in District of Columbia neighborhoods (Blood Lead Levels of Homes with Elevated Lead in Tap Water -- District of Columbia, 2004 MMWR Dispatch Vol. 53., March 30, 2004).

CDC addresses these inaccuracies and reassures the public of our commitment to preventing harmful lead exposures. For three decades, CDC has been an international leader in calling attention to the fact that childhood exposure to lead causes adverse health effects including speech, behavioral problems, difficulty learning and hyper activity. Throughout this time, CDC has provided guidance and recommendations to parents, public health agencies, doctors, and community organizations about prevention of childhood lead exposure and suggestions to seek diagnostic testing when parents are concerned about their children's potential exposure.

[The specific issue addressed by the Salon article is health effects from excessive levels of lead in drinking water. In your opening statement, please cite specifics about if, or how, CDC has ever been an international leader in calling attention to the potential health risks of lead in drinking water, and in educating parents, public health agencies, doctors, and community organizations about preventing childhood exposure to high concentrations of lead at the tap. Without this information, the above statement reads like gratuitous PR that misses the entire point of the Salon piece.]

Characterization of CDC's 2004 MMWR Conclusions
Salon correspondent Rebecca Renner mischaracterizes the 2004 Morbidity and Mortality Weekly Report (MMWR). The MMWR states that "lead in tap water contributed to a small increase in BLLs in D.C." Now, as in 2004, CDC continues to stand by its MMWR statement that, "Because no threshold for adverse health effects in young children has been demonstrated, public health interventions should focus on eliminating all lead exposures in children. Lead concentrations in drinking water should be below the EPA action level of 15 ppb. Officials in communities that are considering changes in water chemistry or that have implemented such changes recently, should assess whether these changes might result in increased lead in residential tap water."

[Here please spell out how exactly Ms. Renner mischaracterized CDC's 2004 report. What did Ms. Renner write that contradicts CDC's statements in MMWR? It is telling that you fail to quote Ms. Renner's supposedly erroneous characterizations and juxtapose them with the corresponding MMWR statements. Please allow readers to see for themselves the gap between the Salon article and the CDC report. Although your response above implies that Ms. Renner's piece got facts wrong, it provides no evidence to support the claim. Again, as it stands, this looks like one more attempt to cloud the issue rather than shed light on it.]

Missing Test Results
Ms. Renner's article contends that missing laboratory test results undermined public health. As CDC has explained to Ms. Renner many times, in interviews and in written responses, public health surveillance data uses real world health information to support public health decision-making. It is dependent on health organizations to report data accurately. In 2004, a participating commercial laboratory stopped reporting test results that fell below the CDC level of concern of 10 ug/dL. CDC believes this failure of reporting accounts for the missing data because the laboratory continued to report BLLs greater than 10 ug/dL. To the extent "missing" data would have affected overall results, it would have exaggerated the apparent problem, not masked it. As a part of the 2004 public health consultation, the CDC encouraged the D.C. Department of Health Medical Director to remind all laboratories and health care providers of their obligation to report all blood lead level tests.

[The key question is the scientific validity of your 2004 report. If you are wedded to the "negligent laboratory" explanation, try to offer as much verifiable evidence as possible. For example:
  • Can you name this laboratory and attach an official letter from them acknowledging their mistake?
  • Can you attach a complete database from the laboratory (with children's identifying information redacted, of course) showing all the blood lead data points from 2003 that they did not report to the DC Department of Health (DOH)?
  • Can you post an official letter from DC DOH explaining if, when, and how they knew that the thousands of unreported blood lead levels from 2003 were all below 10 ug/dL, and what steps they took (if any) to obtain all blood test results, as they were supposed to?
  • Can you show what steps CDC took (if any) prior to publication of the 2004 report to confirm that only test results with BLLs below 10 ug/dL were missing?
  • Can you explain why neither CDC nor DC DOH ever simply asked the laboratory to supply the missing data in order to include them in the 2004 analysis?
  • Can you debunk the allegation mentioned in Salon that high blood test results (above 10 ug/dL) were omitted as well?
Is Salon correct in its statement that the "negligent laboratory" explanation originated at DC DOH? If not, please state how you heard of this explanation. If so, please consider disclosing DC DOH's conflict of interest in the 2001-2004 lead-in-water crisis. Specifically, please acknowledge publicly that:
  • DC DOH had direct knowledge of the 2001-2004 contamination, but had taken little action to address it.
  • Some of the CDC report's co-authors worked at DC DOH and coordinated the 2004 environmental risk assessments at the homes of children with elevated BLLs, which showed in several cases that drinking water was the sole or a contributing source of lead.
  • DC DOH was the source of all the data for the 2004 CDC report and had direct responsibility for the thousands of missing blood lead test results.
  • DC DOH was sued (along with WASA) for personal injury of a DC child with severe lead poisoning, and the lawsuit alleges that the child's exposure was at least partly from high lead in drinking water.
  • Two DC DOH employees were fired for their role in the lead-in-water fiasco.
Lastly, the sentence, "CDC believes this failure of reporting accounts for the missing data..." needs rewording. "Belief" in the "negligent laboratory" explanation does not constitute scientific evidence on which the public can rely. Your readers want to know what proof CDC has that thousands of missing blood lead test results from a critical year of the study (when DC's water was highly contaminated and most DC residents were not yet aware of the problem) did not skew the results, much less merit disclosure in the 2004 report.]

Alleged Scientific Misconduct
Scientific integrity is CDC's hallmark. Scientific misconduct has a precise definition, which is "fabrication, falsification, or plagiarism in proposing, performing, or reviewing scientific activities, or in reporting scientific results." CDC's Office of Science takes any such allegation very seriously; it thoroughly investigated this complaint and found no evidence of scientific misconduct. CDC acknowledges the fact of missing data; however this fact is unrelated to fabrication, falsification, or plagiarism on CDC's part.

[The third sentence refers to "this complaint." Consider naming the source of the complaint, for clarity. Presuming that the reference pertains to the 2007 allegations of scientific misconduct by Professor of Civil and Environmental Engineering at Virginia Tech and MacArthur Fellow Marc Edwards:
  • Can you post all documents pertaining to your thorough investigation of the specific allegations about falsified and fraudulent data used in the study? The statement, "...on CDC's part," leaves open the distinct possibility that there was fraud and fabrication in the paper by the report's non-CDC affiliated co-authors. From a practical perspective, it does not matter who originated the fraud and fabrication. What the public wants to know is whether or not fraud and fabrication occurred.
  • Can you also explain why you have failed to answer Dr. Edwards' 1/2/08 inquiry about whether CDC actually investigated his 2007 allegations, and whether your purported investigation followed CDC's written guidelines for addressing scientific misconduct concerns?
Please address all of Dr. Edwards' scientific misconduct allegations (e.g., regarding the 300-parts-per-billion study, the publication procedures behind the 2004 report, etc.). As written, the paragraph above implies that Dr. Edwards' reported concerns were limited to the missing data points, which can mislead readers to the false conclusion that no other questions about the integrity of the MMWR report have been raised.]

Communication of Findings
Since 2004, the CDC Lead Poisoning Prevention Program staff and CDC Division of Media Relations have responded to numerous press inquiries about the 2004 D.C. consultation. Moreover since the 2004 investigation information has been shared regularly and rapidly with other public health authorities, local and federal agencies, including the American Public Health Association, DC Water and Sewer Authority, D.C. Lead program officials, the George Washington University School of Public Health's Water Team, and representatives from U.S. Environmental Protection Agency.

Allegations by Ms. Renner that, "Scientists from other agencies, including EPA and HUD,...were never told about the results" are untrue or misleading. For example, CDC's Lead Poisoning Prevention Branch routinely consults with EPA water experts and solicits their review and comment on a variety of topics. HUD does not have jurisdiction over issues related to lead and water; CDC works closely with HUD on a variety of other issues related to healthy housing.

[To substantiate the claim that Ms. Renner's statement about CDC's non-disclosure of the 2007 APHA presentation was "untrue" or "misleading," please provide the following:
  • The names of all agencies and individual employees CDC informed about its 2007 findings, as well as the dates and methods by which this information was delivered.
  • Copies of any and all written documents (letters and/or e-mails) disclosing the 2007 findings to agencies/individuals outside CDC.
  • Any and all public health recommendations accompanying CDC's disclosure of the 2007 findings.
As written, your statement provides no actual evidence, only more unsubstantiated assertions, that Ms. Renner's reporting was untrue or misleading.]

Alleged Failure to Share New Information

In 2007, preliminary findings of the 2004 public health consultation were presented during the annual meeting of the American Public Health Association, and the abstract was published in annual conference program guide.

It is common practice in scientific circles to present preliminary findings at scientific meetings as a way for researchers to receive comment and advice from other experts. This presentation did not present complete data analysis nor did it include all the analysis that were planned and necessary for a scientific manuscript. Since that time CDC has obtained additional statistical analyses, undertaken additional peer review, and continued to strengthen the manuscript. We believe these aspects of the scientific process are essential to conducting and communicating the best quality science. The manuscript is expected to be published later this year.

[CDC's 2004 report concluded that:
"...although lead in tap water contributed to a small increase in BLLs in DC, no children were identified with BLLs [greater than] 10 ug/dL, even in homes with the highest water lead levels."
CDC's 2007 presentation concluded that:
"The association between exposure to lead service pipe and having a BLL [of 10 ug/dL or above] remained statistically significant after controlling for potential confounders."
The 2004 conclusion indicated that no significant harm was done from lead in DC's drinking water. The 2007 conclusion indicated just the opposite: that significant harm was done from lead in DC's drinking water. If the 2007 conclusion represented the preliminary findings of the 2004 report, as you state above, please answer the following: How did the "significant harm" preliminary finding that CDC presented in 2007 get translated into the "no significant harm" conclusion in CDC's 2004 report?

If CDC deemed it necessary to publish the 2004 report, with all its horrific flaws, in less than 12 days to reassure DC residents that no significant harm was done, why didn't CDC feel an even greater responsibility to publicize its 2007 findings, and to alert the public that the agency's earlier "no significant harm" conclusion was inaccurate and misleading?

Can CDC explain its decision not to disseminate its 2007 findings of harm, despite the fact that these findings agree with a) decades of prior scientific research about the health effects of lead in water on infants and young children and b) the 2009 peer-reviewed study by independent researchers?

Lastly, in the statement above, can CDC justify continuing to defend the 2004 report when you have publicly admitted that this report:
  • is not scientific,
  • is missing thousands of blood lead test results from a critical time period,
  • failed to focus on the populations most vulnerable to the effects of lead in water,
  • makes claims about the health effects of lead-contaminated water based on blood tests of residents who didn't drink this water, and
  • is apparently being "misinterpreted" by everyone who reads it, including several of the report's own authors?
With CDC's ardent and stubborn defense of its 2004 report as background, can CDC also provide your rationale for not publicizing your 2007 presentation on the basis that it does not meet CDC's standards for "best quality science"?

Your statement above raises more troubling questions than it answers. Please consider rewriting it with clarity and honesty.]


Other Scientific Studies

Ms. Renner alleges that "a new scientific study published in January ("Elevated Blood Lead in Young Children Due to Lead-Contaminated Drinking Water: Washington D.C. 2001-2004," Journal of Environmental Science and Technology, Vol. 43, No. 5, 2009) contradicts CDC's conclusion of minimal harm. In fact this study, reaffirms CDC's conclusions that lead in water contributed to elevations in BLLs and that lead concentrations in drinking water should be below the EPA action level of 15 ppb.

[CDC's 2004 conclusion was that although a small increase in BLLs was noticed in 2001-2004, no children were identified with blood lead above the CDC's "level of concern" due to the city's lead-contaminated drinking water. The 2009 study's conclusion was that hundreds if not thousands of DC infants and children experienced blood lead concentrations above the CDC's "level of concern" due to the city's lead-contaminated drinking water. If the latter conclusion agrees with the former, please explain clearly and rationally how.]

Since 1975, CDC has been a tireless advocate for childhood lead poisoning prevention. Our agency's commitment to preventing childhood lead exposure is as strong today as it has been since we released the first statement on lead poisoning and its effects on children.

[Given CDC's complete failure to refute the main points of the Salon article with specifics, it hardly seems the time or place for self-congratulatory verbiage on the "agency's commitment to preventing childhood lead exposure." Please refrain from such statements, at least while the integrity of your influential 2004 report is being questioned.]

####

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

Monday, April 20, 2009

How the CDC Failed Our Children and its Own Mission

The Centers for Disease Control and Prevention (CDC), the federal public health agency to which we turn for clear and scientifically sound information on matters of health, seems trapped in an unfortunate downward spiral. One unseemly act leads to another, and then a third and a fourth, until it becomes perfectly clear the agency has lost touch with the communities it is designed to serve and has abandoned its own mission: helping to improve the health of the people of the United States by promoting disease prevention and control, environmental health, and health education.

When it comes to lead in drinking water, the CDC first failed DC's children and then children in communities all across the country and the world.

What went wrong and how can the CDC begin to fix it?

It starts with the influential CDC report, published in March 2004, and titled "Blood Lead Levels in Residents of Homes with Elevated Lead in Tap Water -- District of Columbia, 2004."

In February 2004, two weeks after the Washington Post informed District residents that for two and a half years the drinking water in thousands of DC homes had been contaminated with astronomical concentrations of lead, the CDC teamed up with the DC Department of Health (DOH) purportedly to assess health effects from the contamination. DOH was about to be exposed for knowing about the lead problem since 2002 and helping WASA cover up its serious nature. In less than six weeks, the CDC published a study that contradicted decades of prior scientific knowledge about child retention of lead from lead-contaminated drinking water (see also our 2/25/09 and 3/22/09 blog entries).

The CDC's conclusion was that long-term exposure to astronomical concentrations of lead in water "might have contributed to a small increase in blood lead levels (BLLs)" (emphasis added). No children, according to the CDC report, were identified with BLLs equal to or above the CDC's "level of concern" (10 micrograms per deciliter) whose exposure was attributable to the water, even in homes with the highest lead-at-the-tap concentrations (i.e., greater than 300 parts per billion).

CDC's supposedly authoritative report -- which was written, reviewed, edited, and published in less than 12 days -- utterly contradicted the EPA's predictive models of lead absorption by infants and young children from water. Aware that lead concentrations in the District's drinking water were exceeded only at Superfund sites, EPA calculated that a high percentage of DC infants would experience lead poisoning from the tap. Despite its highly dubious conclusion, the new CDC report was cited by scientists, public health experts, and communities with lead-in-water problems across the United States (and internationally) as evidence that high lead at the tap does not pose a significant health threat, even to the most vulnerable age groups.

Subsequently, Washington state, New York, and Montreal have all downplayed local problems with lead in drinking water by prominently mentioning the CDC's conclusions based on the agency's "study" in Washington DC. Other communities, like Los Angeles, responded to parent concerns about contaminated school water with egregious misstatements that could have been easily refuted if the CDC had ever delivered clear and unambiguous information about the dangers from elevated lead levels at the tap (see video below).

In DC, the CDC report brought a collective sigh of relief. Officials from EPA, DOH, and WASA claimed that the city's two-and-a-half year failure to properly notify residents about the unprecedented lead-in-water levels had no significant public health impact. The city's childhood lead poisoning prevention community openly labeled drinking water a "minor" source of lead and a "distraction" from other, "more important" sources. For four years, DOH left out water testing during environmental risk assessments at the homes of children with elevated BLLs. DC public schools failed to publicize elevated levels of lead in fountains and coolers. And just last year, DC's Mayor and key members of the DC City Council insisted on removing from a supposedly "comprehensive" lead poisoning prevention ordinance several sensible provisions aimed at addressing lead in drinking water over the strong objections of local and national lead poisoning prevention advocacy organizations.

All the while, the CDC sat back and watched. CDC officials participated in regular meetings with WASA and EPA, monitored and guided the lead program at the DOH, attended the task force meetings of the District's lead advocacy community, but they never made an effort to change DC's interpretation of the CDC report or to put the lead-in-water issue back on the city's radar screen.

Yet when crucial facts about the CDC report began to surface, uncovering major scientific shortcomings and misleading conclusions, the CDC's reaction revealed institutional resistance to transparency and accountability, blatant disregard for scientific integrity, and a complete inability to provide clear, cogent, and consistent answers to simple questions from the public. In response to evidence that the CDC report was being used widely to downplay the risks of lead in water, the CDC denied responsibility for the "no significant harm" claim and instead blamed readers for "misinterpreting" its findings.

In 2005, Virginia Tech Professor of Civil and Environmental Engineering and 2007 MacArthur Fellow Marc Edwards began an investigation into the CDC report and raised multiple and serious questions about the data behind it. For over three years Dr. Edwards has attempted to obtain answers from the CDC, with little success.

The highlights below from Dr. Edwards' interactions with the CDC illustrate the federal agency's unresponsiveness to legitimate questions about the validity and application of its report.

As background, the CDC report comprises two studies: the "citywide population study," which found no significant increase in elevated BLLs among DC residents in 2001-2004, and the "300-parts-per-billion study," which found that none of the 201 residents in homes with water lead levels above 300 parts per billion experienced elevated BLLs.

November 2005

While researching the 300-parts-per-billion study, Dr. Edwards discovered that there was an unreported delay of months to a year between the time residents were informed that their water was contaminated with lead (and took measures to protect themselves from exposure) and the time their blood was tested for lead. Because the half-life of lead in blood is 28-36 days, BLLs can drop relatively quickly when the exposure source is eliminated. For this and other reasons, Dr. Edwards concluded that the blood lead samples for the CDC study were drawn from a subset of the DC population that had very low likelihood of elevated BLLs from drinking water. Thus, contrary to the public presentation of that data as "worst case," the CDC study had by design almost no chance of detecting any link between excessively high lead-in-water levels and elevated lead in blood. In July 2006, when confronted by reporters, the CDC admitted the undisclosed water/blood sampling gap, but to date it has failed to add a clear disclosure about this fatal limitation in its report.

December 2005

Troubled by the haste with which the CDC report was written, and aware that the DOH had featured the report prominently two days after its publication in sworn testimony at a City Council hearing about the agency's own role in the 2001-2004 crisis, Dr. Edwards sent a letter to the CDC asking whether the preparation and presentation of the report followed the journal's written publication guidelines (regarding clearance, review, and production). He followed up with dozens of e-mails and phone calls, as well as a Freedom of Information Act request. To date, the CDC has not answered Dr. Edwards' questions.

Dr. Edwards sent a second letter to the CDC requesting copies of all e-mails between the CDC and DOH concerning the CDC report. Four months later, with no e-mails in hand, Dr. Edwards wrote back to the CDC stating,
"By refusing to fulfill my [Freedom of Information Act] request and refusing to answer the simplest questions I have posed, CDC is helping to perpetuate flawed (or even fraudulent) science that directly impacts public health. [...] CDC's refusal to produce the documents in a timely manner, failure to produce the data behind this study, and complete lack of response to my earlier questions illustrates a callous disregard for principles that govern scientific inquiry. I am extremely disappointed that CDC is willingly sacrificing public health to hide data behind an obviously flawed study."
To date, the CDC has not released the requested e-mails, or answered questions about whether written CDC policies were violated in publishing the 2004 report.

April 2006
Dr. Edwards sent to the CDC questions related to his discovery that 2 of the 17 children in the 300-parts-per billion study had not consumed tap water for two years prior to collection of their blood. Later, documents obtained from DOH through Freedom of Information Act requests revealed that none of the 17 children tested in the CDC study were drinking unfiltered tap water. To date, the CDC has not answered Dr. Edwards' questions about this issue, nor has it added any disclosure to its report about this important fact.

May 2006
Dr. Edwards submitted to the CDC a request for all the scientific data behind the 300-parts-per-billion study. To date, the CDC has not sent him this set of data.

July 2006

After several cases of lead poisoning in North Carolina were tied to lead-in-water levels far below 300 parts per billion, the CDC contended that its 2004 report had never suggested that consuming water with 300 parts per billion lead is safe. However, the agency again did not disclose the errors behind the misleading conclusions of its 300-parts-per-billion study. To date, the CDC has still not explained what message readers ought to draw from this study, when nearly all of the residents who participated were drinking bottled and filtered water for months to a year before having their blood tested.

September 2006
Contrary to sworn testimony under oath by the CDC study's DOH co-authors, Dr. Edwards discovered that numerous 2004 environmental risk assessments at the homes of DC children with elevated BLLs found drinking water to be the sole identified lead exposure source or a contributing source of lead exposure. In response to this finding, the CDC told WAMU radio that it planned to conduct a follow up study to determine whether its 2004 conclusions were correct. As part of this new study, the CDC stated that it would review DC's 2004 often cited environmental risk assessments. The CDC estimated that a definitive follow up report would be published several months later. To date, the CDC has not published such a report (CDC recently announced that a paper will be published later in 2009).

November 2006
Directly contradicting its comments from two months earlier, CDC told Salon that it had decided against reviewing DC's 2004 environmental risk assessments.

January 2007
On 1/11/09, Dr. Edwards made yet another plea to the CDC for the release of information:
"For more than a year now, I have been trying to get simple answers to questions I have about the [CDC report]. [...] Unless I hear from you before next Tuesday at 5:00 pm (January 16), I have decided to document my concerns to the CDC Associate Director of Science. At present, lacking the innocent explanation that I have been trying to find for more than a year now, my report will document suspicions of scientific misconduct [...]. I regret that it has come to this. [...] I have been given a run-around for more than a year while the findings of this study have spread throughout the public health community and caused undeniable harm."
After a week of silence, Dr. Edwards submitted to the CDC a 27-page letter (available upon request) alleging possible scientific misconduct -- fabrication and falsification of data, based largely on information he had pieced together from the DOH, parents of young children in DC, newspaper reports, and official statements by government representatives. This letter reiterated very specific and highly credible problems regarding data inconsistencies and contradictions, the absence of thousands of critical BLL data points (including BLLs above the CDC's "level of concern"), biased inclusion and exclusion of residents into the 300-parts-per-billion study, and additional evidence that the sub-population selected for this study was by no means the "worst case," as had been stated repeatedly by authors of the study under oath.

On 1/23/07, the CDC sent Dr. Edwards the data he had requested for the first part of the report (the citywide population study), with critical information deleted that was necessary to reproduce the analysis (as well as conduct new analyses). It informed Dr. Edwards that if he wanted this information, he would have to pay an additional fee of $166.14. Dr. Edwards sent CDC a check for this amount, which was cashed in April 2007. To date, CDC has still not sent Dr. Edwards the data it promised him. As for the 300-parts-per-billion study, the agency stated that it does not have the data for it and referred Dr. Edwards to the Food and Drug Administration (several co-authors on the CDC report were affiliated with the FDA).

March 2007
Dr. Edwards sent the CDC two Canadian newspaper articles quoting Joe Schwarcz, PhD, a McGill University chemistry professor who cited the CDC study to reassure the public that widespread lead-in-water problems in Montreal were no cause for serious concern. The first article quoted Dr. Schwarcz as saying that DC:
"...got thousands of people to actually give blood and they found that although the water level was sometimes as high as 300 parts per billion, which is astounding, it didn't influence the blood levels."
The second article, again citing the CDC report, made light of Montrealers' rush to buy water filters:
"Joe Schwarcz, director of the McGill University Office for Science and Society, noted there must be 'glee in the Brita boardroom' this week. But he pointed out a 2004 study in Washington, DC, on residents who were exposed to lead levels in their drinking water that were 300 times Quebec's norms, showed no signs of lead poisoning in the blood, indicating that poisoning rarely results from drinking water."
In his introductory note to the CDC, Dr. Edwards wrote:
"...after reading this story, how many people in Montreal are going to take seriously the threat from lead in the water? How on earth can CDC sit by and do nothing to correct this horrific misconception? KIDS IN SCHOOLS ALL OVER THE US ARE BEING ENDANGERED, AS WE SPEAK, BY THAT CDC [REPORT]. NOT TO MENTION IN CITIES, LIKE MONTREAL, AND ELSEWHERE IN THE US, WHERE AUTHORITIES FEEL JUSTIFIED IN NOT EVEN TELLING PEOPLE ABOUT HIGH LEAD IN WATER. CDC's inaction on this issue over the last 14 months is completely inexcusable. It will take years to even get back to where we were on this issue before the DC blood lead fraud took place."
In response to these concerns, the Office of Science at the CDC's National Center for Environmental Health contacted Dr. Edwards to tell him that no one at CDC disputed that the residents in the 300-parts-per-billion study were probably not consuming tap water for months to a year before their blood was drawn. Stating that additional delays in clarifying the 300-parts-per-billion study would be "unconscionable," the Office of Science led Dr. Edwards to believe that the scientific record would be corrected "in no uncertain terms" within one week. The Office of Science also suggested that it could not investigate Dr. Edwards' scientific misconduct allegations, unless Dr. Edwards attributed the allegations to specific CDC employees.

June 2007
Still without the raw data he had requested about the 300-parts-per-billion study, Dr. Edwards wrote to the Office of Science:
"I hope that you all agree, that when the raw data for the study cannot be found and produced 20 months after I first asked for it, it raises scientific questions that go beyond a 'misunderstanding' that readers took from reading the work. I therefore request that when the 'clarification' to the [CDC report] is published, that it also explicitly state that either 1) CDC cannot find and produce the data used for the [report's] '300 ppb' study, or 2) CDC had nothing to do with the data, analysis or interpretation related to the '300 ppb' study. At least then I can stop people who refer to this horrible excuse for a scientific publication from invoking CDC's reputation to support their flawed conclusions."
August 2007
Over four months after stating that CDC would release a clarification about its 300-parts-per-billion study within days, the Office of Science informed Dr. Edwards that a correction had been posted online. At the bottom of CDC's Q&A page on lead in water, CDC wrote the following addendum:
"Following the release of the [CDC report] some reports have suggested erroneously that the Centers for Disease Control and Prevention has determined that lead in residential tap water at concentrations as high as 300 parts per billion is 'safe.' CDC would like to reiterate the key message from the 2004 article that because no threshold for adverse health effects in young children has been demonstrated (no safe blood lead has been identified), all sources of lead exposure for children should be controlled or eliminated. Lead concentrations in drinking water should be below the US Environmental Protection Agency's action level of 15 parts per billion."
The addendum, which is not posted on the actual report, offered no explanation about why the public's interpretation of the 300-parts-per-billion study was "erroneous," or what the CDC report actually concluded about the health effects of water with excessively high lead. The addendum also made no disclosure about the time gap between water and blood tests, or the fact that all the children in the sample group were reported as drinking bottled or filtered water. If the "key message" of the CDC report was the obvious truth that all sources of lead must be controlled and that water lead must be below 15 parts per billion -- facts that were known long before 2004 -- then the CDC report offered nothing new, especially about the health impact of astronomical levels of lead in the District's drinking water in 2001-2004.

By placing blame on the public and various officials for "misinterpreting" its report and by diverting attention away from the horrific flaws of its two studies (the citywide population study and the 300-parts-per-billion study), the CDC tried to evade any responsibility for the actual message of its work, which was that, contrary to all reasonable expectations, long-term consumption of water with lead levels even above 300 parts per billion had no significant health impact, even in young children (and that no one in DC showed evidence of harm from the years of high lead in water). CDC and DOH purposefully disseminated that very message in no uncertain terms (see for example, the video clip of DOH's 9/04 testimony to City Council).

September 2007
Dr. Edwards submitted to the CDC a second letter (available upon request) alleging possible scientific misconduct, this time by specific CDC employees. This letter, a continuation of the one he had submitted nine months before, focused on a) unusual circumstances related to the publication of the CDC report; b) purposeful omission of facts that confound the scientific analysis in the report; and c) CDC's refusal to properly correct the scientific record, even after acknowledging fatal flaws in the study.

The CDC sent Dr. Edwards a letter in response to his first allegations, stating that it had "examined CDC's role in the study and [had] found no evidence of misconduct." The letter offered no refutation or explanation in response to Dr. Edwards' specific allegations. Instead, it referred Dr. Edwards to the DC Office of the Inspector General (OIG). Dr. Edwards told the CDC that he had already contacted OIG, which had referred him to CDC, because the 2004 report was a CDC publication.

November 2007
A Salon article has just revealed that in 2007 the CDC presented data at the annual meeting of the American Public Health Association (APHA) which showed that many children in Washington DC experienced elevated BLLs from the 2001-2004 lead-in-water crisis. The CDC chose not to publicize these findings or post its PowerPoint presentation on its website (the presentation is available on the APHA website for a fee). Nor did CDC inform EPA, DOH, the DC Department of the Environment, or any of the residents in Washington DC about its finding.

March 2008
The CDC sent Dr. Edwards a response to his second scientific misconduct letter stating that it had "examined CDC's role in the study and [had] found no evidence of misconduct." CDC offered no explanation for, or refutation of, any of Dr. Edwards' allegations.

January 2009

When a new study by Edwards et al. showed that in 2001-2004 hundreds, if not thousands, of DC infants and toddlers experienced elevated BLLs, the CDC kept quiet the fact that it had already presented similar findings at the APHA annual meeting in 2007. CDC then sat and watched as WASA questioned the scientific merit of the Edwards et al. study and called for an independent investigation into the obvious disparity between the Edwards' et al. conclusions and those from the 2004 CDC report. CDC never disputed that there was an obvious contradiction between the Edwards et al. study results and their 2004 report. To the press, the CDC again affirmed that it found "no direct link" between the unprecedented lead-in-water contamination and DC children's blood lead levels and no "evidence of a public health crisis."

Today, the CDC continues to stand by its 2004 findings, without producing evidence to rebut Dr. Edwards' specific allegations of fabrication and falsification of data. Moreover, it refuses to straightforwardly acknowledge the "no significant harm" message of its report that was sent and received. Instead, CDC points to vague language in the paper about a possible "small increase in blood lead levels" from DC's lead-contaminated water and to a broad, standard warning that "public health interventions should focus on eliminating all lead exposures in children."

Five years after the CDC report's publication, CDC's position on the health risks from lead at the tap generates more confusion than clarity. Based on a compilation of CDC's rare comments to the press and DC lead poisoning prevention advocates, here's what the CDC is saying:
  • The 2004 report does not say that high lead in DC water caused no significant harm, and if anyone makes such a claim their motives ought to be questioned. The report notes concerns about a "possible health impact," but it found no direct link between elevated water lead and elevated blood lead. The health effects from DC's 2001-2004 contamination are likely to be "very slight."
  • The 2009 Edwards et al. publication, which found serious and widespread harm from DC's lead-in-water crisis, is essentially in agreement with CDC's 2004 report.
  • The 2004 report is not scientific. It is missing thousands of blood lead data points from a critical time period, it fails to focus on the most vulnerable populations, it makes claims about the health effects of highly contaminated water based on blood tests of residents who didn't drink this water, and is it being widely "misinterpreted." (Yet this completely discredited report continues to be displayed on the agency's journal and website, where it continues to be cited as evidence that high levels of lead in drinking water do not have significant health consequences, and where it can mislead anyone who would think that the CDC would never publish a report that was "not scientific").
  • The 2007 CDC presentation (which found highly significant proof of serious harm to DC residents from the high lead in water and agrees with conventional scientific knowledge about the health impact of lead at the tap) is not appropriate for public distribution or discussion because it does not meet CDC standards for "best quality science."
If you are thoroughly confused, join the club.

One thing we can probably all agree on is that we expect more from the nation's premier public health agency. In the last 5+ years, CDC's actions and public health messages about lead in drinking water have neither improved the health of the children of the United States, nor promoted health education that can help us prevent exposure to hazardous levels of lead at the tap. On the contrary, the CDC's 2004 report has done great disservice to our children. If the CDC does not retract it, it must immediately disclose its severe limitations. Here are our suggestions:

What the CDC must disclose about its 2004 report

Apart from acknowledging publicly, clearly, and fully all the flaws and limitations in its citywide population study and 300-parts-per-billion study as described by Edwards et al., the CDC must disclose:

I. Conflicts of interest
  1. Eight of the CDC report co-authors were employees of the DOH, an agency that had direct knowledge of the 2001-2004 lead-in-water crisis, but had taken little action to address it. Some DOH co-authors coordinated the 2004 environmental risk assessments at the homes of children with elevated BLLs, several of which showed drinking water to be the sole or a contributing source of lead, but they misrepresented these findings under oath. DOH was the source of all the data for the CDC report, and thousands of blood lead test results from 2003 have now been discovered to be missing. In July 2004, DOH was sued (along with WASA) for personal injury of a DC child with severe lead poisoning, and the lawsuit alleges that the child's exposure was at least partly from high lead in drinking water. Two DOH employees were fired for their role in the lead-in-water crisis.
II. Flaws in the presentation of facts about lead in water
  1. Lead service lines are not the only source of lead in drinking water. Lead solder and leaded brass are important sources as well, and the majority of homes in DC have them. In 2001-2004, contrary to WASA's frequent misstatements, over 15% of District homes with no known lead service line had lead-contaminated water. The CDC report's focus on lead service lines must not confuse readers into thinking that residents in homes without a lead service line are protected from lead-in-water problems. Indeed, a reasonable analysis indicates that in 2001-2004 more DC children were lead poisoned from high lead in water in apartments and homes without lead service lines (as in the case of a child where the likely lead source was contaminated water at Wilkinson Elementary School, which has no lead service lines), than in homes with lead service lines. In North Carolina lead poisoning from water occurred even though the city has no lead water lines.
  2. The report's characterization of lead paint and dust hazards as "high-dose lead sources" and the implication that lead-contaminated water is a "low-dose lead source" is inaccurate. Some lead paint, manufactured prior to about 1940, can contain 10-50% lead by weight, but lead pipes are 100% lead by weight. Lead solder, commonly used in homes prior to 1986, contains 50% lead by weight. According to Dr. Edwards, metallic lead is much more dense than lead compounds in paint, so a particle from lead solder or partly replaced lead service line will always have much more lead than an equivalent sized lead paint particle. Lead solder alone has been linked to childhood lead poisonings in North Carolina and Massachusetts.
CDC needs to come clean and admit to us all that it has utterly failed to describe accurately both:
  • what happened in DC in 2001-2004 specifically, and
  • the possible importance of drinking water as a potentially significant source of lead generally.
The agency must now set the record straight to restore its own credibility on this issue before it can begin to play a constructive role in shaping policies to address lead in water in the future. By failing to take this necessary step and continuing to obfuscate and spin, CDC only compounds its errors and dishonesty, ensuring continuation of an adversarial relationship with lead poisoning prevention advocates, instead of shifting to constructive cooperation for the promotion of public health.
Video clip: 10/30/08 NBC Los Angeles segment about highly misleading risk communication messaging to concerned parents at an LA school with high levels of lead in water.