WASAwatch

May 20 Congressional Hearing Will Address Flawed and Deceptive CDC Study of Lead in DC Drinking Water

2010-05-18T23:55:00.034-04:00

On Thursday, May 20, 2010, the Subcommittee on Oversight and Investigations of the US House Committee on Science and Technology will hold a hearing titled "Preventing Harm -- Protecting Health: Reforming CDC's Environmental Public Health Practices." The hearing will be from 9-11 am at 2318 Rayburn House Office Building and will also be accessible online via Webcast.

Why should you care?

Have you ever found yourself in those spirited debates with friends or colleagues or online communities about highly sensitive health issues -- like, for example, childhood vaccinations, alternative therapies, pesticides, autism -- and just before rising blood pressures give way to physical violence, someone invokes an authoritative conclusion supported by the Centers for Disease Control and Prevention (CDC)? So, the conversation comes to a screeching halt? Case closed? Truth spoken? As if Moses had descended from Mount Sinai rendering a stone-engraved verdict from the highest possible authority? One side slinks away with their tail between their legs and the other gloats with a victorious smile?

The CDC, the nation's premier public health agency, has the mission to help improve the health of the people of the United States by promoting disease prevention and control, environmental health, and health education. It is the agency to which we have been conditioned to turn for clear and scientifically sound information on matters of health. With an almost 70-year history of addressing public health problems, it inspires the public's trust. In fact, the CDC's authority is so strong that when its representatives speak, most of us -- including those with medical expertise -- unquestioningly suspend our own judgment and allow our understandings about matters of health to be replaced with the understandings of the CDC.

Our relationship with the CDC is symbiotic. We, on the one hand, desperately need to depend on the agency for reliable information that we can embrace unthinkingly and confidently, especially in times of crisis. The CDC, on the other hand, depends on us for its effectiveness. If our trust in the CDC were to erode, the agency's authority would diminish, its ability to shape public understandings and behaviors would be reduced, and the symbiotic whole would revert to its much-weakened parts.

This week's scheduled hearing sends a clear message of Congressional concern about the CDC's ability to fulfill its mission. It is the second hearing on the CDC's environmental public health practices that Congress is holding in 14 months. The first, in March 2009 (see our 3.22.09 WASAwatch entry), was accompanied by a scathing staff report about the agency's systemic and repeated failures to prevent human harm from toxic environmental substances, and was followed by the demotion of Howard Frumkin, MD, MPH, DrPH, former Director of the CDC's Agency for Toxic Substances and Disease Registry (ATSDR) and its National Center for Environmental Health (NCEH).

Witnesses at Thursday's hearing will include the Government Accountability Office (GAO); Stephen Lester, Science Director from the renowned nonprofit organization Center for Health, Environment & Justice that has been at the forefront of the struggle to address problems with the CDC; and Marc Edwards, PhD, Professor of Civil and Environmental Engineering at Virginia Tech, internationally recognized lead corrosion expert, and 2007 MacArthur Fellow, who has devoted the last 6 years of his career on a voluntary investigation of the multi-agency and multi-year public health fiasco of lead in Washington DC's drinking water.

Mention of the DC "lead-in-water crisis" usually evokes memories of the 2001-2004 historic contamination about which the DC Water and Sewer Authority (WASA), DC Department of Health (DOH), and US Environmental Protection Agency Region III (EPA RIII) knew of, but failed to inform the public for years. To our knowledge, the CDC did not play much of a role in causing this incident. As unbelievable as it may sound, however, the 2001-2004 fiasco was followed by two equally damaging chapters of reckless government behavior in which the CDC's Lead Poisoning Prevention Branch starred.

The first chapter centers on the influential and now infamous 2004 CDC report about the public health impact of the crisis. The second chapter concerns two unconscionable periods of "silence" during which the CDC has failed to disclose to the public its knowledge about public harm from lead in Washington DC's drinking water. Both of these periods extend to the present day.

Chapter 1

Here we'll be brief (ok, as brief as we can!), since we have written extensively about the CDC report in previous WASAwatch entries. If you have time for a quick but relatively comprehensive overview of the issue, we recommend you take a look at this:
4.20.09: How the CDC Failed Our Children and Its Own Mission
Other relevant entries are:
3.15.10: The 2009 Study that Found Health Harm from DC's Lead-in-Water Contamination Wins Best Science Paper Award
8.29.09: It is Time for the CDC to Stop the Spin, Retract its 2004 Report, and Apologize to DC
5.3.09: What the CDC Can Learn from the National Research Council and the Public
3.22.09: A New Congressional Inquiry Into Scientific Integrity Highlights Lead in DC Drinking Water
2.25.09: Bad Science, Conflicts of Interest, and Misuse of Professional Authority: A "Crash Course"
2.5.09: Contemplating the "Slight" and the "Subtle"
In summary, the CDC report titled "Blood Lead Levels in Residents of Homes with Elevated Lead in Tap Water -- District of Columbia, 2004" erroneously concluded that the District's historic 2001-2004 lead-in-water contamination "might" have contributed only to "a small increase in blood lead levels (BLLs)." According to the report, no DC children were identified with BLLs equal to or above the federal lead "level of concern" (10 micrograms of lead per deciliter of blood) from exposure to the contaminated water, even in homes with lead-at-the-tap concentrations twenty times the federal lead action level of 15 parts per billion (ppb) or greater.

The report's message -- that two and a half years of water-lead concentrations far above the allowable federal standard, and in some cases as high as "toxic waste" levels, did not result in significant health harm -- contradicted decades of prior scientific research establishing a clear link between lead-contaminated drinking water and blood lead elevations above the CDC's level of concern, especially for infants dependent on reconstituted formula, toddlers, and young children. The CDC report's deceptive conclusion was reiterated clearly in an accompanying CDC "Talking Points" memo that said:
"There is no indication that DC residents have blood lead levels above the CDC levels of concern of 10 micrograms per deciliter for children 6 months - 15 years old and 25 micrograms per deciliter for adults as a result of lead in water."
Three and a half months after the publication of the CDC report -- when DC WASA, the Washington Aqueduct, and EPA were still trying to decide how to best control the contamination, and the Washington Post was printing almost daily revelations about the multi-agency corruption and incompetence that had led to the historic two-and-a-half-year contamination -- Mary Jean Brown, ScD, RN, Chief of the CDC Lead Poisoning Prevention Branch and principal author of the report, wrote to her DOH coauthor Lynette Stokes, PhD, MPH, then-head of DC's blood lead screening program, that the CDC's research had successfully put the lead-in-water issue to rest. Dr. Brown's letter opened with the following statement:
"Now that there is a better understanding of the public health impact of lead in the drinking water in the District, I hope we will be able to focus on the issue of lead-based paint hazards."
Since its publication, officials across the United States and Canada have repeatedly invoked the CDC report to allay public fears about discoveries of elevated lead in local drinking water. In DC, the paper's no-significant-harm conclusion was used by government officials to justify the virtual exclusion of drinking water as a potentially significant source of lead from both the city's childhood lead poisoning prevention efforts and first-ever lead poisoning prevention bill of 2008.

Further reinforcement of the CDC's message came from a WASA-funded paper written in partnership between the water utility's George Washington University consultants and DOH, and published in the prestigious journal Environmental Health Perspectives (EHP). This bizarre "study" supposedly recounted the city's lead-in-water crisis, but it had so many inaccuracies and omissions that no DC resident who actually lived through the events would recognize it. Wildly applauding each and every action of our city's "heroic" WASA and DOH employees (and ignoring every illegal or embarrassing mistake), the paper concluded 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." In June 2009, an independent review panel requested that the lead author, Tee L. Guidotti, MD, MPH, retract and apologize for his unfounded conclusion (for more information see our 6.16.09 WASAwatch entry). Guidotti et al. continues to be under investigation. You can read the complete list of concerns regarding this paper in a March 2009 letter from Dr. Edwards to EHP:
3.20.09: Possible Undisclosed Conflicts of Interest and Other Concerns Related to a Publication in Environmental Health Perspectives
Following the publication in January 2009 of an award-winning peer-reviewed scientific study by Virginia Tech and the Children's National Medical Center, which found that in fact hundreds, if not thousands, of District children were harmed from the 2001-2004 lead-in-water crisis, Dr. Brown admitted to the Washington Post that the CDC report was "clearly" not scientific. To date, however, the agency has not only refused to retract its pernicious publication, it has even failed to take such basic corrective measures as disclosing the errors, limitations, and conflicts of interest that mar it. For example, facts that all readers of the CDC report deserve to know include that:
The absence of a link between "worst case" lead-in-water levels and elevated blood lead among District children was based on an analysis of only 17 children, none of whom were consuming unfiltered tap water at the time of their blood test.
The no-significant-harm conclusion was derived from an analysis that inexplicably omitted over 4,500 blood lead tests from 2003, of which almost 300 exceeded the CDC's "level of concern."
Eight of the report's coauthors were employees of the DOH, an agency that had early knowledge of the 2001-2004 lead-in-water crisis and that was being sued together with WASA for causing health harm.
Concerned about the CDC's flawed and deceptive no-significant-harm message, as well as the zeal with which this message was being used to downplay the health risks of lead-contaminated drinking water in communities across the US and internationally, in 2007, Dr. Edwards submitted to the CDC two letters detailing concerns about the report's scientific integrity:
1.17.07: Possible Fabrication and Falsification of Data Used in a CDC Publication
9.18.07: Possible Scientific Misconduct by CDC Scientists and Officials
Although it is unclear if the CDC ever conducted an investigation, it summarily dismissed all of Dr. Edwards' allegations.

In the meantime, DC residents and specifically the parents of the approximately 42,000 children who are today between 5 and 10 years old, have still not received an honest appraisal of the harm that may have been done to their fetuses, infants, and toddlers in the past, especially if they were using unfiltered tap water for mixing infant formula, drinking, and cooking. Moreover, to date, largely due to the CDC report, no government official in any agency -- local or federal -- has acknowledged the true public health impact of the District's historic 2001-2004 lead-in-water contamination.

Chapter 2

Silence 1: Undisclosed evidence of harm from the 2001-2004 crisis

Serious questions about the validity of the CDC report's no-significant-harm message first surfaced in the media in September 2006 when news broke that, contrary to all official claims, numerous 2004 environmental risk assessments at the homes of children with elevated BLLs had pointed to contaminated water as the key source of lead exposure. In her response to this revelation, Dr. Brown told WAMU that the CDC was planning a follow-up study, which would include a review of the District's environmental risk assessments, to determine whether the agency's 2004 finding was correct:
"We're going to do the same sort of analysis on the data that we did [for the 2004 CDC report], just to ensure that the picture that we believe we see, or that we think - we think everything's safe - just to ensure that in fact is the case."
Seventeen months later, in February 2008, the CDC had still not released such an analysis. But representatives from the agency's Lead Poisoning Prevention Branch flew all the way from Atlanta to attend two of several community meetings organized by WASA about the utility's accelerated lead service line replacement program. WASA called these meetings to make the case to DC residents that it was time to abandon mid-way the "remediation" program it had began in 2004. WASA's ambitious program had originally aimed at replacing every single WASA-owned lead service line in the District by 2010. It had been the highlight of the water utility's 2004 "Community Water Pledge" to engage in "a series of activities, well beyond regulatory requirements, to mitigate the elevated lead levels found in the drinking water" of many - if not most - DC homes. The program had also been WASA's desperate public relations attempt to calm the public's wrath about the two-and-a-half year cover-up of the contamination and prove the agency's commitment to public health. Indeed, WASA's determination to "make good" with DC residents was so convincing that two weeks after the announcement of its pledge, a class-action lawsuit against the agency was dropped.

Four years later, aware that it needed compelling reasons to back out of its "remediation" program without jeopardizing its new image as guardian of the public's health, WASA told residents that the majority of DC's lead service line replacements had been "partial" (i.e., only the publicly-owned portion of a home's lead service line was replaced, while the privately-owned portion was left intact), and that partial replacements were "not as effective" at reducing lead-in-water levels as the utility had wished. WASA did not reveal, however, what its data actually showed: that the partial lead service line replacements in the 9,000+ DC homes that had received them often resulted in increases in water lead levels of an undetermined duration.

As part of its presentation at the community meetings, WASA featured Dr. Guidotti who, faithful to the CDC message, assured residents that "water is a small source" of lead exposure, and that there was "no evidence of an adverse effect" from the historic two-and-a-half year contamination. The CDC officials sat through the presentation silently. When asked by a member of the public if they still stood by their 2004 report, all they said was that they were "analyzing some more data" -- that indeed they had "a lot more data" in their possession now -- and would be putting out "a revision for clarification" sometime in the future. In response to a second question about whether the CDC's new analysis was leading the agency to "back off" of its no-significant-harm finding, the CDC representatives said that they were not prepared to make a public statement on the health effects of the 2001-2004 crisis. The questioner, struck by the CDC's refusal to shed any light whatsoever on the question of harm, made the following final remark:
"The way silence is understood sometimes about data is that you [the CDC] are affirming what the word is that the public agencies are putting out. WASA has been very clear that there are no health effects. So I just want to put that out from a public perspective."
Astonishingly, three months prior to this meeting, the CDC Lead Poisoning Prevention Branch had presented data at the annual conference of the American Public Health Association (APHA), which showed that many children in Washington DC actually did experience elevated BLLs from the 2001-2004 lead-in-water contamination. Even though Dr. Brown herself was the study's co-investigator, the CDC chose not to publicize the findings or post the PowerPoint presentation on its website (we discovered that the presentation is available on the APHA website for a fee). Nor did CDC inform DC government agencies or the public. Here are some of the presentation's conclusions:
DC children with BLLs equal to or greater than 5 or 10 micrograms per deciliter were significantly more likely to have lived in a house with a lead service line, as compared to children with lower BLLs, even after adjusting for confounders.
The proportion of children tested with high BLLs (equal to or greater than 5 or 10 micrograms per deciliter) was significantly higher during 2001-2004 -- when DC used the disinfectant chloramine without a corrosion inhibitor.
When in 2004 the use of chloramine alone was stopped (and a corrosion inhibitor was added into the drinking water) there was a dramatic reduction in elevated BLLs in DC children under 6.
These findings, which contradicted the 2004 CDC report, 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 Virginia Tech/Children's National Medical Center paper that found serious public health harm (for more about the 2007 CDC presentation see our 5.3.09 entry).

To date, the CDC has published no study revising or updating its 2004 report.

Silence 2: Only partly disclosed evidence of harm from DC's partial lead service line replacements and undisclosed evidence of harm from intact lead service lines

In January 2010, the CDC posted online an "Important Update," alerting managers of CDC-funded childhood lead poisoning prevention programs nationwide that:
"... when lead service lines are partially replaced children are more likely to have blood lead levels greater than or equal to 10 ug/dL, compared to children living in housing with either undisturbed lead service lines or service lines that are not made of lead."
This preliminary finding, we have learned, comes from a study the CDC conducted on water lead levels and blood lead levels in DC homes with lead and non-lead service line material. It is unclear to us whether this is the study the CDC has been alluding to since 2006 that reassesses the agency's 2004 no-significant-harm conclusion. What we do know, however, is that this new study entered the publication process at least ten months ago, and that the CDC has been aware about lead elevation problems with DC's partial lead service line replacements since at least November 2007.

In a November 2009 meeting that several local and national organizations requested with the CDC, Dr. Brown agreed to share with us further details of the agency's findings. Specifically:

A child's risk of developing elevated BLLs increases twofold when the child lives in a home with an intact lead service line, and fourfold when the child lives in a home with a partial lead service line -- as compared to living in a home with no lead service line. This strong correlation between lead service line and blood lead levels was detected after accounting for confounding factors and even when the District's water met the federal lead safety standard.

Simply put, those of us who live in homes with a lead service line or partially replaced lead service line have something to worry about! In fact, we've had something to worry about for years!

Amazingly, it looks like the CDC will broadcast the "details" of its findings only if and when its manuscript hits the press. In the meantime, DC residents -- and residents in other parts of the US -- who live in high-risk homes will remain in the dark about the potential serious and irreversible health hazards in their tap water.

Other government agencies will have to do the same. It is our understanding that the CDC has not shared its complete study either with the DC Department of the Environment (DDOE), which houses the city's childhood lead poisoning prevention program, or with WASA, which knows where many of DC's 30,000+ lead service lines are and is continuing to conduct some 200 partial lead service line replacements a year.

According to WASA General Manager Hawkins' 4/30/10 testimony to DC City Council:
"So far, DC WASA has not been afforded the opportunity to review a preliminary draft of the CDC study, although we have cooperated in all CDC requests for information on this subject."
Exposure to lead-contaminated drinking water is by and large easily preventable. Yet the CDC's reckless and unethical management of this environmental health threat has needlessly placed hundreds of thousands of children at risk of irreversible harm. How much longer are we expected to embrace the CDC's "knowledge" unquestioningly and confidently, when doing so might hurt us?

Changes in the CDC's Lead Poisoning Prevention Branch are needed urgently. As we have said before, they ought to start with the immediate retraction of the agency's deceptive 2004 report.

We urge Congress to intervene immediately and decisively.

The 2009 Study that Found Health Harm from DC's Lead-in-Water Contamination Wins Best Science Paper Award

2010-03-15T16:53:00.015-04:00

Last week, the prestigious chemical and environmental research journal Environmental Science & Technology announced its selection of best papers of 2009.

The journal gave its top award to the paper "Elevated Blood Lead in Young Children Due to Lead-Contaminated Drinking Water: Washington, DC, 2001-2004," coauthored by Virginia Tech Professor of Civil and Environmental Engineering and MacArthur Fellow Dr. Marc Edwards, Virginia Tech doctoral candidate Simoni Triantafyllidou, and Children's National Medical Center pediatrician Dr. Dana Best.

The journal considered 1,400 peer-reviewed studies in total. It awarded the Edwards et al. paper for being "of the highest caliber" and for its anticipated "significant and long-lasting impact on the field."

WASAwatch wrote about the Edwards et al. paper in a previous blog and offered a summary of the study's methodology and findings. It is worth restating that the research contradicted years of public assurances by WASA, WASA's paid consultants at the George Washington University School of Public Health, DC government, the Environmental Protection Agency (EPA), and the Centers for Disease Control and Prevention (CDC) that exposure to almost three years of astronomical levels of lead in drinking water resulted in no measurable public health harm and that cases of elevated BLLs during that time were consistently linked to lead paint and dust. The Edwards et al. paper also prompted two still active investigations -- one by Congress and the other by the DC Office of the Inspector General -- into possible negligent or intentional wrong-doing by city and federal agencies.

Here are the Edwards et al. key conclusions:

In 2002 and 2003, the total estimate of elevated blood lead level (BLL) cases (i.e., equaling or exceeding 10 micrograms of lead per deciliter of blood) from high water lead levels for children 2 1/2 years old and younger is 859 (this number is probably much lower than the actual for reasons highlighted in the paper).
The greatest health impact from the city's 2001-2004 contamination was in the second half of 2001, when lead-in-water levels rose suddenly and dramatically and the incidence of elevated BLLs increased 9.6 times, as compared to the first half of 2001 (when the lead problem was just beginning).
The incidence of elevated BLLs did not return to levels observed in 2000 (before the contamination) until about 2005, when WASA once again met EPA lead-in-water standards.
The screening guidelines of the CDC, which recommend testing children for elevated BLLs at around 1 and 2 years of age, are not designed to detect lead exposure in infants and thus provide only limited insight to the effects of lead at the tap on the under-12-months age group.
The public health impact of the 2001-2004 Washington DC contamination was consistent with decades of research in the US and Europe linking lead-contaminated drinking water to elevated BLLs.

The Environmental Science & Technology award is a dramatic measure of the highest level of respect the environmental science community has for the Edwards et al. research.

When the paper was originally published, numerous officials from the relevant government agencies and their allies made pejorative private and public statements questioning the study's methods and validity (none of these officials, by the way, had similarly questioned the "no significant harm" conclusions of two earlier papers, authored by government representatives and WASA-paid consultants with clear conflicts of interest).

It has been over a year since the paper's publication and, despite assurances by WASA, DC government, and EPA Region III that they were going to evaluate carefully the merits of the study, to date no agency has made public any such evaluation. More importantly, no agency has ever acknowledged the harm done to DC children in 2001-2004, nor have they once apologized for the role they played in the fiasco. Given the active $200 million class action lawsuit against WASA, maybe this silence is understandable from a legal and economic perspective. From a public health and social justice perspective, however, it is unethical and unconscionable.

Some readers might wonder why we are opening old wounds. After all, the 2001-2004 lead-in-water crisis purportedly ended 5 years ago. Moreover, WASA now has a new, charismatic, highly skilled, and trustworthy General Manager. What's the point of revisiting this controversy from the past?

It's a valid and important question.

Even though positive changes have been made since the publication of the Edwards et al. study, there are three main reasons why the question of health harm from the 2001-2004 crisis continues to matter:

1. DC residents, and certainly the parents of the approximately 42,000 children who are today between 5 and 10 years old, deserve an honest appraisal of the harm that may have been done to their fetuses, infants, and toddlers in the past, especially if they were using unfiltered tap water for mixing infant formula, drinking, and cooking. To date, no government official has acknowledged the public health implications of the city's historic lead-in-water contamination.

2. Critical nodes of the intricate, multi-agency web that created the lead-in-water crisis, and that for five subsequent years misled DC residents and communities around the country about its health consequences, are still firmly in place. Specifically:

Several employees at WASA, EPA Region III, and the CDC with a documented history of misleading the public continue to control information and make decisions about drinking water safety in DC or childhood lead poisoning prevention nationwide. None of these employees have been held accountable.

The flawed 2004 CDC report -- currently under Congressional investigation -- that found no cases of elevated BLLs due to DC's contaminated drinking water still sits on the agency's website. Seven months ago, Congressional investigators revealed that the CDC analysis had omitted thousands of blood lead measurements, including hundreds of elevated BLL data points, which led WASAwatch to call for the report's full retraction. To date, the CDC has shown no inclination to publicly correct their flawed study, even though its principal author, the chief of the CDC's lead branch, now admits that the work was "not scientific."

The WASA-funded paper that was published in the peer-reviewed journal Environmental Health Perspectives (EHP) in 2007 and claimed "no measurable harm" from the 2001-2004 contamination still sits on EHP's website. Serious questions about undisclosed financial conflicts of interest, possible data fabrication, and the scientific integrity of this study, authored by former George Washington University professor Dr. Tee L. Guidotti and his colleagues, are laid out in detail in a March 2009 letter from Dr. Edwards to EHP and have been discussed on WASAwatch and the newsletter of the American Association for the Advancement of Science (AAAS). You may be also interested in Dr. Guidotti's response letter to the AAAS editor, which studiously avoids a factual response to key points of the allegations, and the reporter's reply. Although EHP has not disclosed this publicly, the Guidotti et al. paper continues to be under investigation.

3. Although DC's 2001-2004 lead-in-water contamination was unique in its severity, lead-in-water problems around the country may be more serious and widespread than presently believed. We know, for example, that:

Lead service lines, lead-containing solder, and leaded brass fixtures -- which are all sources of lead in water -- are widespread around the country.

Even though water utilities may still underreport lead-in-water problems, every year at least some utilities exceed the federal lead-in-water standard.

Water utilities that meet federal lead regulations can still have lead-in-water problems in up to 9% of the homes they monitor.

The number of documented states affected by lead-contaminated drinking water in schools is at least 39 (including DC). There is no scientific or practical reason to believe that the problem does not extend to schools in all 50 states.

Children living in homes with partially replaced lead service lines are at a significantly higher risk of experiencing elevated BLLs than children living in homes without lead service lines, and such replacements have been performed in numerous locales in the US and Canada during the past 20 years.

30% or more of current elevated BLLs do not have an immediate lead paint source, and studies suggest that lead exposures result from multiple environmental sources.

The detection of lead-in-water contamination requires a proper testing protocol that not all utilities use. Moreover, the detection of lead particles (i.e., small pieces of detaching lead solder or lead rust that can contain excessively high concentrations of lead) is difficult, even with the use of a proper testing protocol.

Despite these facts, and the high incidence of elevated BLLs among children in cities like Providence, Milwaukee, Chicago, and Philadelphia that are known to have high concentrations of lead service lines, the US approach to childhood lead poisoning prevention focuses almost exclusively on lead paint and dust hazards, and tends to downplay risks of lead-contaminated drinking water.

The Edwards et al. paper points to the need for a serious national reexamination of lead poisoning prevention laws, protocols, and programs to prevent fetuses, infants, and children from being needlessly harmed by lead at the tap.

Breaking News

2009-09-25T18:33:00.003-04:00

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.

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

2009-09-10T20:57:00.013-04:00

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

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

2009-08-29T09:39:00.012-04:00

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:

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."
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.

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

2009-06-16T03:41:00.025-04:00

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).

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

2009-05-03T11:35:00.008-04:00

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.]

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U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

How the CDC Failed Our Children and its Own Mission

2009-04-20T09:58:00.020-04:00

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

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

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.
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.

WASA GM Jerry Johnson Steps Down

2009-04-02T23:56:00.012-04:00

The departure of General Manager Jerry Johnson from WASA may very well mark a new chapter in our water utility's history. We hope that in this chapter, WASA will turn a new leaf, leaving behind forever a culture of deception, secrecy, and disregard for public health, and replacing it with a commitment to honesty, transparency, and constructive steps forward that will elevate the safety of DC's drinking water to the top of the agency's agenda.

In the last five years, many community, lead advocacy and environmental organizations, including ours, called for Mr. Johnson's resignation on several occasions. We did so because we found Mr. Johnson's handling of the 2001-2004 lead-in-water crisis and his response to subsequent concerns about the safety of our water persistently irresponsible, deceitful, and divorced from disturbing and irrefutable facts. We did so because the water utility Mr. Johnson led consistently circled its wagons in public relations defensive crouch, instead of reaching its hand out to make common cause with the people of the District and address the pressing public health crisis that was gripping our city. Needed candor and leadership was replaced by fixing the facts to desired outcomes and finger pointing when things got too hot in the kitchen.

Having said this, however, it is necessary to put today's encouraging development into perspective. Obviously, an agency's decision to let go of its head is difficult, both for the agency and the individual employee who is let go. Moreover, Mr. Johnson's departure does not, in and of itself, make our water safe again, nor does it answer our questions about the levels of lead currently flowing out of our taps. Although a central figure in this seven-and-a-half year fiasco, Mr. Johnson is only one thread in the intricate fabric of bureaucrats, politicians, agencies, and news organizations that allowed the 2001-2004 cover up of the unprecedented lead-in-water contamination, and continues to perpetuate the preposterous falsity that no measurable harm was done to infants and young children in our city.

Sadly, as reported in earlier entries of this blog, the falsities to which we have been subjected have led many in DC and around the globe to believe that hundreds, and even thousands, of parts per billion of lead flowing from DC's taps had no discernible negative health effects. Mr. Johnson's departure ought to be just the first step toward unraveling this dangerous fabric of deceit and denial. We await the results of the DC Office of the Inspector General's investigation into WASA, because we know that Mr. Johnson was not the only wrongdoer within his agency.

The Environmental Protection Agency -- both EPA Region III (DC's de facto state oversight agency) and EPA Headquarters, the Centers for Disease Control and Prevention (CDC), the DC Department of Health, and WASA's consultants at the George Washington University School of Public Health must also be held accountable for the role they have played in enabling (and even supporting) WASA to misrepresent facts about the safety of our water and mislead ordinary people, here in DC, nationally, and internationally, about the health effects of hazardous levels of lead at the tap.

Today we call on all local and federal authorities with oversight on DC's drinking water to strengthen their work on correcting the wrongs and putting things right. We are proud of our efforts and the support of the people of DC who came out to meetings, wrote letters, testified, organized, marched in the street in front of City Hall and the US EPA, and who refused to be cowed by the official line that everything was okay and that it was time to go to sleep. We stayed vigilant and now have a taste of accountability with the firing of Mr. Johnson, but we must remember to keep our eye on the prize -- we must solve the lead-at-the-tap problem that is still ongoing in our community and make sure that this tragedy, or one like it, is never allowed to happen again.

As the late and great DC environmental justice activist Damu Smith reminded us over and over again, "We have to get out of the back of the bus, get up front, and drive it."

This ride is not over.

Yanna Lambrinidou
President
Parents for Nontoxic Alternatives

Paul Schwartz
National Policy Coordinator
Clean Water Action

Is WASA's Definition of "Accurate and Useful Information" Different from the Public's?

2009-03-31T10:42:00.004-04:00

On February 10, 2009, DC Council Members Mary Cheh and Jim Graham held a joint public hearing to address new revelations about the harm that was done from the District's lead-at-the-tap contamination of 2001-2004, and the quality of our drinking water today. In his testimony, WASA General Manager Jerry Johnson mentioned the intense scrutiny to which WASA has been subjected since 2004, and assured the DC Council that all past investigations into his agency's handling of the lead-in-water problem have helped WASA "continue" its efforts to provide "accurate and useful information" to the public.

One of the eight investigations Mr. Johnson mentioned was a 2005 audit by the DC Office of the Inspector General (OIG) that was carried out in response to a 2004 request by then DC Council Member Carol Schwartz for an "independent corroboration" of WASA's lead-in-water data. Written on February 27, 2004 -- only weeks after DC residents learned that for two and a half years the city's drinking water dispensed hazardous levels of lead -- Ms. Schwartz's letter to the DC OIG explained that such corroboration was necessary because the public had "lost faith" in the utility's credibility. In contrast to the other seven investigations -- which exposed gross breaches of responsibility and management deficiencies -- the DC OIG's 2005 audit seemed to redeem WASA. In the words of Mr. Johnson, it "affirmed [the] Authority's lead water sample findings."

Indeed, the DC OIG report stated that only 6% (as opposed to 21% in 2004) of 272 homes had lead-in-water concentrations above the Environmental Protection Agency (EPA) action level of 15 parts per billion. These findings were hailed by WASA as proof that its much questioned water sampling methodology was sound, and that its claim about declining lead-in-water levels due to the new chemical "orthophosphate" were correct. "Report Supports Integrity of DC WASA Testing Program," declared WASA's press release of June 20, 2005, days after the announcement of the DC OIG findings.

The water utility's press release quoted Mr. Johnson saying:

"We're extremely pleased with the Inspector General's findings, as it validates the hard work that this agency and its partners have done to address this issue. [...] Moreover, this report affirms our recent announcements of declining lead levels, as well as the integrity of our test sampling process."

Turns out this wasn't the last we were going to hear about the DC OIG audit. WASA brought it up again on February 20, 2009, this time at a DC Department of the Environment (DDOE) meeting about the District's latest effort to evaluate independently our drinking water for lead. At this meeting, a WASA board member asserted that WASA's lead-in-water monitoring practices -- which continue to be questioned by independent experts as well as public health and environmental organizations -- were validated by the DC OIG in 2005. This validation, the board member suggested, freed the DDOE of any need to focus its current investigation on the integrity of WASA's monitoring methods.

In our work on lead in the District's drinking water we have learned that you cannot trust WASA's statements without triple-checking the facts. Prompted by the assertions of WASA's board member, we decided to take a closer look at the DC OIG 2005 audit.

The DC OIG 2005 audit, which was supposed to detect the presence of lead in DC's drinking water by re-sampling "high risk" homes in WASA's own testing pool, used a water-sampling methodology that departs significantly from the standard EPA protocol and, by design, is not able to capture normally available lead at the tap. The methodology is rendered useless by the following inexplicable instructions:

1. No first-draw samples. A first-draw sample represents the water that is collected immediately after a minimum stagnation period of 6 hours. Compliance with federal regulations necessitates that 90% or above of first-draw samples at "high-risk" homes measure below 15 parts per billion of lead.

2. "Second-draw" samples after 4 minutes of flushing. Second-draw samples are not required for compliance with federal regulations, but they can provide useful information about lead that is released from lead service lines outside many homes. For single-family residences EPA suggests collecting second-draw samples by "allowing the water to run until there is a significant change in temperature which would be indicative of water that has been standing in the lead service line." Water corrosion expert at Virginia Tech and 2007 MacArthur Fellow Marc Edwards says that, in practice, EPA's guidance translates to a flush of approximately 30 seconds to 1 minute. A 4-minute flush, Dr. Edwards told us, "is completely worthless in assessing any aspect of corrosion control, water safety, or veracity of prior EPA monitoring data. Whoever wrote that instruction guaranteed that the results obtained would be favorable to DC WASA, because the collected samples had no chance of detecting a lead hazard even if it were present."

What DC residents have painfully learned in the last few years is that there are sampling protocols that find lead problems when they exist, and there are sampling protocols that miss lead problems when they exist. The DC OIG 2005 audit, which comprised the first independent evaluation of DC's drinking water for lead following the two-and-a-half years when WASA kept the contamination under wraps, used a sampling protocol that misses lead problems. It is noteworthy that the DC OIG findings directly contradicted concurrent research in Washington DC by a University of California, Berkeley team, which in the Fall of 2005 reported that:

"Despite reports that lead levels have fallen significantly over the past year, 63% of all homes tested during the second year of our study [2005] still contained lead levels that exceeded the EPA limit. In addition, drinking water collected from a well-used fountain at an elementary school site that a local government reported as lead free contained lead concentrations greater than 5 times the EPA action limit two years in a row."

Indeed, the fact that 16 of the 272 homes sampled for the DC OIG investigation were found to have elevated levels of lead after 4 minutes of flushing (and during cold months of the year, when lead-in-water levels are not at their peak) suggests that in 2005 DC had a much more serious lead-in-water problem than the DC OIG data revealed. Contrary to WASA's claims, therefore, the DC OIG audit affirmed neither declining lead levels, nor the integrity of WASA's sampling methods.

One, of course, has to wonder how the DC OIG came up with the flawed sampling protocol. The DC OIG told us that it was given the impression that this protocol was what WASA was using at the time and that it complied with EPA requirements. If this is what the DC OIG was told, then it was led astray.

The protocol WASA was using in 2004 included a first draw sample, as EPA requires for compliance with federal regulations and the DC OIG report's comparison table demonstrates (pp. 10-16). Moreover, to our knowledge, it instructed homeowners to take a second draw sample after feeling a significant change in the temperature of the water, which is the language recommended by EPA. Excessive flushing prior to second draw sampling does not meet EPA requirements, and WASA knew this long before DC OIG began its investigation.

Although we haven't yet confirmed who exactly gave DC OIG the flawed sampling protocol, we know that improper flushing prior to testing -- either on the eve of sampling or immediately before collecting a sample -- is one of WASA's signature practices:

Prior to July 2003 and as part of its water monitoring program for compliance with federal regulations, WASA did in fact instruct homeowners to run the water for five minutes before collecting a second draw sample (Covington & Burling report, p. 108). In July 2003, however, WASA realized that excessive flushing prior to second-draw sampling was not included in EPA's guidelines. As a result, it changed its protocol to reflect EPA's language (i.e., allowing the water to run until there is a significant change in temperature). But it did not tell EPA that 400+ lead-in-water measurements below 15 parts per billion it had submitted for compliance with federal regulations had been obtained with the illegal sampling method. EPA Region III learned about WASA's erroneous methodology from a different investigation one year later. In January 2005, the federal agency issued an administrative order requiring WASA to, among other things, notify the residents in those 400+ homes about the unreliability of their 2004 water test results and the need to use lead-removing water filters.

In February 2004, two weeks after the Washington Post broke the story about the two-and-a-half year contamination, WASA tested DC public schools (DCPS) by running all taps for 10 minutes immediately before collecting first draw samples -- another version of the flushing practice that lowers lead at the tap and goes against the standard EPA protocol. The water utility's press release declared that "the vast majority of the DCPS and facilities have extremely low levels of lead in the water." Indeed, 98.94% of the taps tested measured below 15 parts per billion for lead. Following complaints by safe water activists and an official admission by WASA that 10 minutes of flushing gets rid of much of the lead, then Mayor Anthony Williams pressed WASA to repeat the school testing without the 10-minute flush. Lead-in-water levels this time came back markedly higher. Later, however, it was discovered that this time again WASA had recommended another pre-sampling flush. Rather than letting the water run immediately before sampling, WASA advised DCPS to flush all buildings for 10 minutes the night before. "If I did not want to find a lead problem where a serious problem existed, this is the protocol I would write," said Dr. Edwards. Another engineer commented, "They flushed the devil out of those schools." Three years later, in 2007, WASA instructed DCPS to flush all schools for 45 minutes and all taps for 5-15 minutes the night before sampling. Still, results showed that 3/4 of DC schools had at least one tap with lead levels that exceeded 15 parts per billion.

Similarly, from 2005-2008, WASA instructed homeowners in its water monitoring pool to flush their taps for 10 minutes the night before sampling for compliance with federal regulations, and refused to admit this to inquiring members of the public until asked by the Washington Post in mid-2008. Despite the objections of public health and environmental organizations and EPA's September 2008 determination that flushing on the eve of sampling goes against the intent of the law, WASA continues to recommend running the tap on the eve of sampling, albeit now for 2 minutes instead of 10. This, despite data from Virginia Tech that a 2-minute flush on the eve of sampling eliminates almost as much lead as a flush that lasts for 10 minutes.

When a water utility makes claims about water quality or the integrity of their data they have an obligation to base their statements on good science and verifiable facts. The 2005 DC OIG audit is yet another example of the type of deception we have come to expect from WASA. "Accurate and useful information" is nearly always just "smoke and mirrors" when the issue is lead in DC's drinking water.

A New Congressional Inquiry into Scientific Integrity Highlights Lead in DC Drinking Water

2009-03-22T17:05:00.011-04:00

On Thursday, March 12, 2009, the US House Subcommittee on Investigations and Oversight held a hearing on the federal Agency for Toxic Substances and Disease Registry (ATSDR) -- an agency under the aegis of the Centers for Disease Control and Prevention (CDC). The staff report for this hearing -- which argues that ATSDR is doing an abysmal job of fulfilling its mission to prevent human harm from toxic substances through reliable science, proper public health actions, and accurate information -- discusses, among other cases, lead in DC's drinking water. In its introduction, the report paints a grim picture of ATSDR:

"[A]cross the nation local community groups believe that ATSDR has failed to protect them from toxic exposures and independent scientists are often aghast at the lack of scientific rigor in its health consultations and assessments. The studies lack the ability to properly attribute illness to toxic exposures and the methodologies used by the agency to identify suspected environmental exposures to hazardous chemicals are doomed from the start. [...] [T]ime and time again ATSDR appears to avoid clearly and directly confronting the most obvious toxic culprits that harm the health of local communities throughout the nation. Instead, they deny, delay, minimize, trivialize or ignore legitimate concerns and health considerations of local communities and well respected scientists and medical professionals" (pp. 1-2; emphasis added).

One might wonder what ATSDR has to do with the District's lead-in-water problems.

Think CDC 2004. Actually, think CDC 2004-2009.

On March 30, 2004, exactly two months 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 lead, the CDC's National Center for Environmental Health (NCEH) published a report with the DC Department of Health (DOH) that flew in the face of prior scientific knowledge about the health effects of lead in drinking water on the most vulnerable populations: infants and young children (see, Edwards et al. 2009 and our 2/25/09 blog entry). CDC/DOH's conclusion was the following:

"The findings in this report, indicate that although lead in tap water contributed to a small increase in BLLs [blood lead levels] in DC, no children were identified with BLLs [equal to or greater than] 10 ug/dL, even in homes with the highest water lead levels."

10 ug/dL is the CDC's "level of concern" for children aged 6 months-15 years. The report's take-away message was that two and a half years of exposure to lead-contaminated drinking water resulted in no measurable harm.

The CDC/DOH report was quoted ad nauseam by local and federal government officials (see select quotes). WASA, which used it in its 2008 campaign to convince the public that it was time to terminate its accelerated lead service line replacement program, cites the CDC/DOH findings on its website even today (e.g., 2006 news release, 2008 press release & fact sheet). The relief that the CDC/DOH publication brought to all those responsible for the safety of DC's drinking water was most powerfully expressed at a 9/22/04 oversight hearing on WASA by then City Council Member Carol Schwartz, Chair of the Committee on Public Works and the Environment. Responding to the assertion by Lynette Stokes, PhD, MPH, a DOH employee and one of the report's co-authors, that even those residents in homes with the worst lead-in-water levels were left essentially unscathed by the contamination, Ms. Schwartz rejoiced: "That is a marvelously, enormously, encouraging thing" (see video excerpt below).

Dr. Stokes was a former employee of the ATSDR (see our 2/25/09 and 1/31/09 blog entries). NCEH, the Center at the CDC that co-authored the CDC/DOH report is a sister agency to ATSDR. NCEH and ATSDR are managed by the same director, Howard Frumkin, MD, MPH, DrPH. According to the US House Subcommittee on Investigations and Oversight, Dr. Frumkin (and his predecessors) has displayed a persistent lack of concern about the scientific integrity of the reports produced by ATSDR. The Subcommittee's staff report for the March 12, 2009 hearing says:

"[T]he local communities that the ATSDR was created to help protect often believe the agency does more harm than good by offering them reassuring but unfounded and unsound advice and analysis which simply creates an artificial perception of safety to the public that is not supported by scientific inquiry or independent examination" (p. 4).

Today we know that the 2004 CDC/DOH report contradicted not only previous scientific research, but also evidence based on data collected in Washington DC. In April 2004, the Environmental Protection Agency's (EPA) National Center for Environmental Assessment used biokinetic modeling, which when extrapolated to the DC population predicted at least 600-700 cases of elevated blood lead levels (equal to or greater than 10 ug/dL) for children under 6 in 2003 (Edwards et al. 2009, Supporting Information). In 2004 and 2006, media reports featured cases of individual children who experienced elevated blood lead levels from DC's lead-contaminated water. In 2006, Virginia Tech water corrosion expert and MacArthur Fellow Marc Edwards, PhD discovered that -- contrary to public claims by DOH -- several WASA-funded environmental assessments at the homes of children with elevated blood lead levels pointed to drinking water as the sole or a contributing source of lead in 2004. In January 2009, Virginia Tech and the Children's National Medical Center showed that, consistent with the EPA models, in 2001-2004 hundreds if not thousands of DC infants and toddlers experienced elevated blood lead levels (equal to or greater than 10 ug/dL) as a result of high lead at the tap (Edwards et al. 2009).

The true facts about the harm done to DC residents from the 2001-2004 lead-in-water crisis were neither "marvelously" nor "enormously" encouraging. They were not encouraging at all.

The CDC's NCEH and DOH arrived at their misleading conclusions through some of the same flawed research methods characterizing many of ATSDR's reports:

Posing the wrong questions: The CDC/DOH study asked whether DC residents as a whole were harmed from chronic exposure to lead-contaminated water, rather than whether infants and toddlers were harmed from this exposure. By asking the broader question, CDC and DOH failed to look carefully at the age groups known to be most vulnerable to adverse health effects from lead at the tap. Infants are especially prone to harm from high lead in water due to their small body weight and heavy reliance on water as a major component of their diet via consumption of reconstituted formula.

Relying on inadequate or flawed data: The CDC/DOH study relied on blood lead data from DOH. According to Dr. Edwards, DOH's 2003 dataset was riddled with errors and inaccuracies, and thousands of blood lead records are unaccounted for.

Overlooking exposed people: The CDC/DOH study did not take into account individual cases of DC children whose elevated blood lead levels were linked to lead-contaminated drinking water. The story of at least one such case was featured in the Washington Post almost 4 weeks before the report's publication.

Diluting exposed populations with unexposed populations: The CDC/DOH study lumped all blood lead measurements from DC together (i.e., infants, toddlers, children under 6, children over 6, and adults) and conducted a citywide analysis, an approach that can mask population groups or geographical areas disproportionately affected from a given exposure.

Using inappropriate comparisons: In the CDC/DOH study there was a delay of months to a year between the time residents in homes with the worst lead-in-water problems were informed that their water was contaminated (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, blood lead levels tend to drop relatively quickly when the exposure source is eliminated. Moreover, all 17 children included in this analysis were using bottled or filtered water at the time of their blood test. As a result, this study had no chance of detecting the harm done to DC residents from excessively high lead-in-water levels, contrary to the public presentation of the data as "worst case."

In 2007, Dr. Edwards submitted to the CDC two 20-page letters detailing possible scientific misconduct in connection with the 2004 CDC/DOH report. The CDC dismissed his allegation without rebutting any of his specific facts. Then, in January 2009, when the Virginia Tech/Children's National Medical Center study contradicting the CDC/DOH report made front page news in the Washington Post, Dr. Frumkin publicly defended his agency's misleading report and minimized the seriousness of the new revelations (see the US House Subcommittee staff report, science reporter Rebecca Renner's 1/29/09 blog entry, and our 2/5/09 blog entry). In February 2009, Parents for Nontoxic Alternatives and our colleagues at the Alliance for Healthy Homes and Lead Safe DC wrote to Dr. Frumkin to suggest that he correct the record with a letter to the Washington Post stating clearly and accurately what the new findings actually mean. Here's what we suggested as one example of a more appropriate message:

The recent study demonstrates that the 2001-2004 lead-in-water crisis had many more adverse impacts and affected far more children than previously believed. There is no medical intervention that can help children already exposed, but we can and must continue working to understand the causes and extent of this problem and prevent further exposures. We know that exposure to lead at the levels reported are likely to cause a population decrease in IQ and educational performance. The presence of this toxin in our water supply has a negative impact on children in DC.

Since questions remain about the quality of DC water, we encourage residents, particularly those with children or who are pregnant, to carefully follow the advice issued by DC WASA, the DC Department of Health, and the Centers for Disease Control and Prevention. This includes never using hot tap water for cooking or drinking and running the tap for 2 minutes before use for cooking and drinking, if water has been stagnant for several hours. Commercially available water filters recognized by the National Sanitation Foundation for filtering lead are also effective. These precautions are even more important when tap water is used for mixing infant formula, powdered milk, or juices.

In his response, Dr. Frumkin did not address our suggestion. Instead, he remarked that WASA's "persistent misstatement" that CDC/DOH identified no harm from the 2001-2004 lead-in-water crisis was "regrettable." And he closed with one last defending statement about his agency's misleading report: that it concluded with the clear message that "public health interventions should focus on eliminating all lead exposure in children."

What a marvelous truism...

Video excerpt: 9/22/04, former DC Council Member Carol Schwartz, then Chair of the Committee on Public Works and the Environment that oversaw WASA, responds with jubilation to the news that none of the residents living in homes with the highest lead-in-water levels were harmed from the 2001-2004 contamination. Today we know that this CDC/DOH "study" had no chance of detecting harm from the years of high lead. Its first author, Mary Jean Brown, ScD, RN, Chief of the CDC's Lead Poisoning Prevention Branch has now admitted that the work was "clearly" not scientific.

Four Things WASA Misled Us About on the Kojo Nnamdi Show

2009-03-15T09:24:00.002-04:00

On March 2, WASA's General Manager Jerry Johnson was featured on WAMU's Kojo Nnamdi Show to answer questions about the safety of our drinking water. Mr. Johnson made several statements that require correction, because they give false assurances about the safety of our drinking water:

Misstatement #1: Lead in your drinking water could be a problem only if you have a lead service line.

Mr. Johnson argued and implied repeatedly -- and his co-guest, Mr. Tom Jacobus, General Manager of the Washington Aqueduct, made the point too -- that unless you have a lead service line (that's the pipe that carries water from the water main on the street to your home), you do not have to worry about lead in your drinking water. This is not true.

Building on the same erroneous premise, Mr. Johnson also asserted that health authorities recommend precautions against lead in water only for pregnant women, nursing mothers, and infants living in homes with lead service lines. This is also not true.

In reality: Although lead service lines are an important source of lead in DC's drinking water, and about 30,000 DC homes have them, lead solder and leaded brass fixtures can leach hazardous concentrations of lead as well. One thing to remember is that DC public schools are free of lead service lines, but they have a long history of lead-in-water problems. Virtually all DC plumbing systems have leaded brass, and lead solder was very common in homes built before 1987. This means that the majority of District homes have some lead in their plumbing. If you are concerned about lead at the tap you might want to take precautions, whether your home has a lead service line or not.

The Centers for Disease Control and Prevention (CDC) states clearly that "for homes with children or pregnant women and with water lead levels exceeding EPA's action level of 15 [parts per billion], CDC recommends using only bottled water for cooking, drinking, and baby formula preparation." Neither the CDC, nor any other agency of which we are aware limits this advice to populations with lead service lines.

An interesting note:

Through Freedom of Information Act requests, water corrosion expert and 2007 MacArthur Fellow Marc Edwards traced WASA's exclusive focus on lead service lines back to February 2004. Days after the Washington Post broke the story about the unprecedented lead-in-water levels in the District's drinking water, the director of the DC Department of Health water quality division e-mailed his colleagues that presenting the problem as isolated to homes with lead service lines would help calm down the public. The reasoning was that the majority of District homes do not have a lead service line. WASA embraced the idea, despite their own data that showed serious lead-in-water problems in many non-lead-service-line homes. Science reporter Rebecca Renner wrote, "A day later, WASA mailed an information letter on the lead crisis, which emphasized the problem of lead service lines, briefly mentioned lead solder, and ignored brass plumbing components." WASA proceeded to offer special health warnings, bottled water, and lead filters only to the 23,000 households known at the time to have a lead service line. Their outreach excluded not only non-lead-service-line homes, but also over 12,000 residences with a lead service line that WASA did not know about at the time. According to Edwards et al. (2009), simple predictive modeling suggests that in 2003 more DC children experienced elevated blood lead levels from contaminated water in homes without a lead service line than in homes with a lead service line (Supporting Information, p. 22).

Misstatement #2: If you want to prevent exposure to lead at the tap, and your water has been sitting unused for more than 6 hours, flush for 2 (or more) minutes any tap in your home prior to drinking or cooking.

These were Mr. Johnson's words:

"We do offer some advice, and that advice is: if the water has been stagnating, if it's been sitting in the house, inside the pipes, for more than 6 hours, we recommend a person comes home, when they come home, you should have some water use that involves about 2 minutes of flushing. You can come in and use the bathroom, you can wash a load of clothes, you can run the water for 2 minutes, and that then removes that stagnant water from anything that it's been in contact with over that period of time, and brings fresh water in from the water main in the street to the individual household."

This recommendation will not always protect you from high levels of lead in water.

In reality: Although running the water is a good way to reduce lead at the tap, flushing a tap other than the one you use for drinking and cooking (e.g., bathroom tap, laundry tap) will not always protect you from exposure to high lead in water. Here's why: the lead that ends up in your glass or cooking pot sometimes sits near or inside the tap you use to drink/cook, and is ready to flow out as soon as you turn on the water. It may have traveled from plumbing materials far from your faucet, or it may have leached from plumbing materials near or inside your faucet, but either way this lead will not go away by flushing a different tap. If you want to use flushing as a precautionary measure, make sure you also flush the tap you use for drinking and/or cooking. If you want to be especially cautious, flush routinely before every use.

Misstatement #3: The chemical "orthophosphate," which was added to our drinking water in 2004 and helps control the release of lead from plumbing materials, has solved DC's lead-in-water problem.

These were Mr. Johnson's words:

"What we found through a great deal of study and through significant research was that the orthophosphate addition that was mentioned by Tom [Jacobus] a little earlier has in fact worked. We have licked the lead problem with a chemical solution. Therefore the dollars that were originally slated for expenditure for replacing the public side of lead service lines has been primarily moved to other, more demanding needs within the system."

The unqualified statement that orthophosphate has addressed DC's lead-in-water problem, and that WASA can now turn its attention to "more demanding" issues is both false and irresponsible.

In reality: WASA assesses the state of lead in our drinking water through the agency's water-monitoring program that they carry out semi-annually for compliance with federal law. Since 2005, the first year after the 2001-2004 crisis that WASA claimed they met EPA requirements once again, WASA has been sampling DC's drinking water with methods known to miss lead at the tap. For example, they have been asking homeowners to run their tap for 10 minutes on the eve of sampling -- a practice called "pre-flushing" that temporarily reduces lead in water and that EPA Headquarters determined goes against the intent of the law -- and they have avoided sampling in the 7-8 weeks of the year when lead-in-water levels in DC are known to peak.

Even though everyone agrees that the District no longer faces the extreme lead-in-water problem of 2001-2004, the serious questions that remain about WASA's monitoring practices render unqualified statements about orthophosphate's success unsubstantiated. Additional evidence suggests that lead-in-water problems persist. For example:

In 2006, 2007, and 2008, an average of 4.2% of the homes monitored by WASA exceeded the EPA Lead Action Level (LAL) of 15 parts per billion in the 1st draw sample, and an average of 7% exceeded the LAL in the 2nd draw (or "flush") sample. Federal law regulates only 1st draw water samples. 2nd draw samples, which are more representative of the water we use to drink and cook, do not count. If 2nd draw samples counted, WASA’s 2006 and 2007 compliance monitoring data would have rendered the agency in exceedance of the LAL, and would have triggered public education, corrosion control, and lead service line replacement requirements. These data strongly suggest that lead in the water of thousands of District homes will frequently be elevated above the LAL.

According to WASA's own data, lead-in-water levels after partial lead service line replacement often spike for an undetermined duration. In 2008, WASA tested the water at 75 homes that had undergone partial lead service line replacement in 2006 and found a 1st and/or 2nd draw LAL exceedance in 13% of cases. This percentage of long-term problems is conservative, because in this testing round WASA once again instructed homeowners to pre-flush their taps for 10 minutes on the eve of sampling. WASA has conducted over 9,000 partial lead service line replacements throughout DC. This means, that well over 1,000 homes might have hazardous levels of lead at the tap today, as a result.

In 2006-2007, testing at DC Public Schools (DCPS) showed that 3/4 of the buildings had lead-at-the-tap problems. In several schools more than 60% of the sampled taps dispensed water with over 15 parts per billion lead. In a couple of cases, the water measured over 5,000 parts per billion, which qualifies as "hazardous waste." In 2008, Parents for Nontoxic Alternatives, in collaboration with Virginia Tech, the Washington International School, Cesar Chavez Public Charter School, and DCPS, sampled 6 high-risk schools. Overall, lead-in-water levels showed a dramatic drop from 2006-2007, probably due to the new coolers, fountains, and lead filters that were finally installed system-wide as part of Mayor Fenty's school Safe Water Initiative. Problems, however, remain in some taps without filters. This data proves that the orthophosphate is far from the cure it is professed to be, and that filters and/or other protective measures are still necessary for drinking water safety in DC.

From 2007 to the present, drinking water has been implicated as either the only or a contributing environmental source of lead for 9% of DC children under 6 who had elevated blood lead levels and whose home tap water was analyzed. No water samples were even collected in 30% of cases, and the sampling protocol used did not ensure a 6-hour stagnation prior to water collection, which can miss normally available lead at the tap. In 2006 and 2007, the parents of 5 of these children with elevated blood lead reported that WASA had done a partial lead service line replacement at their home in 2005. In 2008, independent testing by Parents for Nontoxic Alternatives and Virginia Tech at the home of another child with lead poisoning revealed that 3 out of the 9 taps dispensed excessive levels of lead. One of the 3 taps, which is used by the child for drinking, measured at 947 parts per billion for the 1st draw, and 51.99 parts per billion for the 2nd draw. This too was a residence with a recent partial lead service line replacement. Although the interior was also severely contaminated with lead dust, regular consumption of the water alone could have easily caused lead poisoning.

Misstatement #4: Pre-flushing pipes on the eve of sampling for federal water-monitoring requirements is a necessary practice that has been approved by EPA.

These were Mr. Johnson's words:

"Until several months ago we had used a protocol that called on people using a 10-minute flush. The 10-minute flush was to give us an apples-to-apples comparison. So we're asking everybody to do the same thing before they participate in the testing program. This is a program where we call on individual residents in the city to fill up liter-bottles of water and leave them for us to do certain kinds of testing. The [federal Lead and Copper] Rule calls for a 6-hour stagnation period, and in order to accomplish that, some people may have been out of the house for a week, some people may have been gone for a day, others may have just come home that evening, so that was the effort -- and it was an approved method by the US Environmental Protection Agency. They have since instructed us to come back to something that's more common to regular use within the household, so what we've been advising people now is doing a 2-minute flush. We must have a 6-hour stagnation period."

In reality: This is the third year in a row that WASA is claiming publicly that they obtained EPA's approval for pre-flushing pipes on the eve of sampling for lead in DC water. WASA made this claim in 2007, when Parents for Nontoxic Alternatives uncovered that the agency had instructed DC public schools to flush all buildings for 45 minutes and every tap for 5-15 minutes the night before sampling for lead, and again in 2008, when residents finally got a hold of WASA's 2005-2008 sampling protocol for compliance with federal standards and learned that it included a 10-minute pre-flush at every sampled home.

EPA Region III, the agency that oversees DC's drinking water, has repeatedly said on the record, both to Parents for Nontoxic Alternatives and to the Washington Post, that they never actually "approved" WASA's pre-flush. Moreover, in September 2008, EPA Headquarters determined that pre-flushing goes against the intent of the law, because it alters homeowners' normal water use patterns. A month later, at EPA's long-term issues stakeholder meeting, EPA Headquarters also confirmed that pre-flushing artificially caps stagnation time (which is not supposed to be capped) and removes particulate lead at the tap (thus missing "worst case" lead-in-water levels, which is precisely what a water utility's monitoring is supposed to capture).

Contrary to Mr. Johnson's statement, federal law requires a minimum 6-hour stagnation prior to sample collection, but there is no upper bound to stagnation time. The intent of the law is to determine the effectiveness of corrosion control measures and assess public safety in a set of "worst case" for risk of lead homes, based on actual resident water use. It is not to compare one home to another under artificially controlled conditions.

In November 2008, when we heard that WASA was negotiating with EPA to replace their 10-minute pre-flush with a 2-minute pre-flush, rather than give up pre-flushing all together, a member of WASA's Board of Directors e-mailed us a quote from Mr. Johnson saying, "DCWASA is not negotiating with the EPA to allow a 2-minute pre flush on the instructions used for LCR [federal Lead and Copper Rule] testing. WASA accepted the changes from EPA Region 3 in their entirety based on EPA Headquarters response to Ralph Scott's letter."

We do not know why WASA's revised 2009 sampling protocol continues to recommend a pre-flush. We have asked both EPA Region III and Mr. Johnson and are waiting to hear back.

"All Ok": WASA's Hazardous Public Messages

2009-03-08T20:33:00.012-04:00

There is a strange thing about WASA's public messages on lead in our drinking water. Often completely divorced from reality, these messages are dumped on us in reassuring sound bites and give a disincentive to take simple actions that would protect fetuses, infants, and young children from exposure to lead at the tap. To many of our leaders and to WASA's Board of Directors, WASA's confident messages that the city's water is unequivocally lead-safe seem to have a comforting effect, even when WASA's own data (and that from independent sources) show just the opposite.

Here are some examples of the hazardous public messages to which we have been subjected in the past:

In June 2003, while in the middle of an unprecedented lead-in-water contamination, the cover page of WASA's 2002 Water Quality Report to customers declared, "Your Drinking Water is Safe" (WASA has since removed this page of the report from their website). The truth is that in October 2002, the Environmental Protection Agency (EPA) had officially deemed WASA in exceedance of the federal Lead Action Level. This means that the tap water in over 10% of DC homes monitored by WASA dispensed more than 15 parts per billion lead. In actuality, WASA's data showed that 49% of homes had a lead-in-water problem. This exceedance had triggered public education, lead pipe replacement, and corrosion control requirements that are built into federal law to protect public health from lead-in-water hazards (see Eric H. Holder, Jr. Report, 2004, p. 76).

In February 2004, just weeks after the Washington Post broke the story about excessively high levels of lead at the tap throughout the District, WASA declared that drinking water at DC public schools had "extremely low levels of lead" -- only 7 of 154 schools had a problem. Soon after, it was discovered that WASA had flushed school taps for 10 minutes immediately before collecting samples, a practice that goes against EPA sampling standards, and that WASA later bragged was a good protective measure that residents could use to eliminate 95% of the lead at their tap. In April 2004, WASA conceded to public pressure and went back to test schools again. This time, 29 of 137 schools had a problem. Several taps dispensed lead concentrations that exceeded EPA's Lead Action Level of 15 parts per billion by hundreds and thousands of times. Free blood lead testing was offered only to students at those 29 schools. The message to the public was that children in other schools were safe. What was discovered years later was that WASA's second round of tests included the removal of aerators and flushing all schools for 10 minutes the night before sampling. Both of these actions hide lead at the tap. Testing in 2006-2007 showed some "hazardous waste" levels of lead in school water, 3/4 of schools with lead-at-the-tap problems, and several schools with more than 60% of the sampled taps dispensing over 15 parts per billion lead. Always at least a year or two behind WASA's innovations to hide lead-in-water problems, it took until 2006 before EPA essentially banned aerator removal, and until 2008 to determine that flushing on the eve of sampling for lead goes against the intent of federal regulations. In the end, we will never know how many DC children were needlessly exposed to lead in school drinking water between 2001 and 2007, when lead filters were finally installed system-wide as part of Mayor Fenty's school Safe Water Initiative.

In January 2008, WASA initiated a series of community meetings to try and begin reneging on their 2004 pledge to replace quickly all the lead service lines they own in the city. In their factsheet, and at their first public presentation of the issue in Anacostia, WASA declared that the partial lead service line replacements they had conducted in over 9,000 DC homes between 2004 and 2007 had shown "only small decreases in lead levels at the tap." What WASA failed to mention was that their data actually showed lead-in-water spikes for weeks and months after partial replacement in many homes. As shown in the video below, participants at the Anacostia meeting who had obtained WASA's data previously and knew about the spikes demanded answers. After intense questioning, WASA finally admitted that the spikes can last "for weeks" but could not recall how severe they are. Subsequently, DC Council member Jim Graham ordered WASA to conduct testing that would shed light on the long-term duration of post-partial-replacement spikes. In July 2008, WASA reported to Council member Graham that all was good: they tested homes that had their lead pipe partially replaced in 2006 and confirmed that the lead-in-water spikes following partial replacement were only a "short-term occurrence." In truth, 13% of the homes WASA tested continued to have lead-in-water problems in 2008 (i.e., they had a 1st and/or 2nd draw lead level over 15 parts per billion). This percentage is conservative, because in this testing round WASA once again instructed all homeowners to flush their taps for 10 minutes on the eve of sampling.

Today we know that despite WASA's repeated reassurances that our water is safe, in 2001-2003 hundreds, if not thousands, of DC infants and toddlers experienced elevated blood lead levels as a result of lead-contaminated drinking water. Moreover, in the last 3 years, children with elevated blood lead levels were identified in homes with a recent partial lead service line replacement.

WASA's public messages about lead in our water can be hazardous to our health. Unfortunately, correcting these messages, or erasing the misperceptions is extremely difficult. Because WASA rarely responds to Freedom of Information Act requests, it often takes years to discover what unethical manipulations went behind their latest "all ok" message.

***

Video excerpt: 1/30/08 "public education" meeting in Anacostia where WASA officials presented the utility's lead pipe replacement program. At this meeting, WASA was unprepared to discuss with the public the lead-in-water spikes that, according to WASA's own data, often follow partial lead pipe replacement for an undetermined duration. To date, WASA has done a partial lead pipe replacement in over 9,000 DC homes.

Are You Concerned About Lead in Your Drinking Water? Here's Some Things You Can Do

2009-03-01T11:53:00.041-05:00

This entry was updated on May 23, 2010:

DC drinking water should be lead-free (or close to it) if your plumbing has no lead-bearing components. But if you have:

A lead service line (full or partial)
Lead solder connecting your pipes
Leaded brass fixtures, or
Galvanized iron pipes (and your home has or had a full or partial lead service line)

your tap water may dispense lead. Virtually all DC plumbing systems have leaded brass. Lead solder was very common in homes built before 1987. And more than 30,000 DC residents have lead pipes (intact or partially replaced) in front of their homes.

The lead in our drinking water can come in two forms:

Soluble (like dissolved sugar), and
Particulate (small pieces of lead solder or detaching lead rust)

Orthophosphate, the chemical treatment that was added in DC water in 2004 to control lead leaching, helps control soluble lead, but its effect on lead particles is uncertain.

For children or pregnant women, the Centers for Disease Control and Prevention (CDC) recommends using only bottled water for cooking, drinking, and baby formula preparation, if water lead concentrations exceed 15 parts per billion.

If you are concerned about lead in your drinking water, you can:

1. Have your water tested by an independent EPA-accredited lab

Look for an NLLAP lab that does water testing.

Make sure that the test kit sent to you includes two bottles, for both a 1st and 2nd draw sample. The bottles should be large enough (1/4 of a liter) and their opening should be wide enough to allow sampling at a flow rate that resembles the way you usually fill a glass of water or a pan for cooking. Water corrosion expert at Virginia Tech, Marc Edwards, recommends that when you mail bottles back to the lab, you request that they use 2% nitric acid in the first step (prior to the mandatory holding time of the acidified bottles), instead of the specified 0.15% nitric acid (pH less than 2). Use of a stronger acid is allowed by EPA and makes it more likely that lead particles will not be missed.

One thing to keep in mind: the release of lead particles tends to be erratic. If your plumbing releases lead particles, you may or may not capture any in the two samples you take for analysis. This means that if you are really concerned about lead in your water, you may want to take precautions even if your test results indicate water lead levels below 15 parts per billion.

2. Take precautions

To reduce lead in water, EPA recommends the following:

When a tap has not been used for several hours, run the water until you feel the temperature change before cooking, drinking, or brushing teeth
Use only cold water for cooking and drinking
Never cook or mix infant formula with hot tap water

Additionally, you can use bottled water, or a water treatment device that is certified by the National Sanitation Foundation to reduce lead. NSF Standard 53 certification for lead reduction means that the certified device reduces 150 parts per billion lead to 10 parts per billion or less for the product's stated service cycle in gallons. For lead reduction, NSF certifies three different types of devices:

Distillation
Filtration
Reverse osmosis

At this time, the only pitcher-style filter certified by NSF to remove both soluble and particulate lead is ZP-001 by Zero Technologies. The Zero Technologies website says that this filter is sold at Target and Walgreens. It costs approximately $40.

Bad Science, Conflicts of Interest, and Misuse of Professional Authority: A "Crash Course"

2009-02-25T17:21:00.026-05:00

This week the independent radio program "Living on Earth" is airing a 7-minute interview with Dr. Marc Edwards, Professor of Civil and Environmental Engineering at Virginia Tech, about lead in the District's drinking water. Dr. Edwards, an internationally renowned water corrosion expert and 2007 MacArthur Fellow, is the first author of a new peer-reviewed study revealing that DC's 2001-2004 lead-in-water crisis caused elevated blood lead levels in hundreds, if not thousands, of infants and toddlers.

Dr. Edwards has stated in numerous presentations that his study does not prove the harmful effects of leaded drinking water. These effects were established decades ago. Indeed, in 2004, Dr. Ellen Silbergeld, Professor of Environmental Health Sciences at Johns Hopkins University testified in Congress that the ability of lead in water alone to cause toxicity, especially in infants, was established in the 1960s (several key studies confirming this finding came out afterwards as well).

The Edwards et al. 2009 study merely confirms prior scientific knowledge. It also reveals the serious flaws of the two government-sponsored papers -- published in 2004 and 2007 -- claiming that "no harm" was done from the unprecedented contamination. For the last 5 years, these two studies have been used repeatedly both in DC and internationally to downplay contaminated drinking water as an important source of exposure to lead. The first study was authored by the Centers for Disease Control and Prevention (CDC) and the DC Department of Health (DOH), and the second, by George Washington University (GWU) and DOH.

If you are wondering about the role of DOH in the 2001-2004 debacle, here's some quick background:

DOH learned about the lead-in-water contamination in October 2002, when WASA approached them with an urgent request for assistance. An independent report later revealed that WASA's calls for help "were met with slow response time from DOH or were not met with any response at all." In February 2004, two weeks after the Washington Post broke the story about excessively high levels of lead in our water, DOH sought the help of CDC to "assess" potential health effects from the contamination. Here's what's key about this partnership: Dr. Lynette Stokes, co-author of the ensuing CDC/DOH report that claimed that no harm was done, oversaw the DOH lead screening program at the time, but was also a former employee of the Agency for Toxic Substances and Disease Registry (ATSDR) -- an agency under the aegis of CDC (for more on Dr. Stokes, see our 1/31/09 blog "5 Year Anniversary").

Almost immediately after she called for CDC's assistance, Dr. Stokes announced on WAMU's Kojo Nnamdi Show that:

"We've found that 34 children have elevated blood lead levels amongst those screened, and we wanted to make sure that we tried to identify all sources of lead. [...] When we did the environmental assessments we determined that every child had a [lead] dust or a soil level that exceeded EPA or HUD guidelines."

This claim, that every child with elevated blood lead levels in the first half of 2004 lived in a home with a non-water lead hazard (and the implication that this hazard was the primary cause of the elevated blood lead levels), was repeated consistently -- even in official documents to the US Senate and the DC Office of the Inspector General -- by government officials and their expert consultants for the next four years. GWU and DOH included a version of it in their 2007 study, and WASA featured it in their public education factsheet even as late as 2008 (see point 7 on the factsheet).

Research by Dr. Edwards, however, revealed that in actuality many of these environmental assessments at the homes of children with elevated blood lead levels pointed to drinking water as the sole or contributing source of exposure to lead. Dr. Edwards talks about both the CDC/DOH study and the GWU/DOH study in this week's "Living on Earth." We contacted him with three follow-up questions.

Here are his answers:

PNA: In the interview with "Living on Earth" you said that you "went to the CDC, asked them for details about their study, and they refused to give [you] any." Can you say more about this? What kind of information did you ask for? Was it proprietary? Is it within a federal agency's legal right to not share information about a study with the public? Do you have any thoughts as to why they didn't give you the information you asked for?

Dr. Edwards: We initially asked for very basic information about how/when their paper was published, how the data was collected, whose blood lead was tested -- the simple information that scientists are supposed to freely share to defend the validity of their work. For the first time in my career, the scientists of a paper would not answer a single question that I posed. I later figured out why they would not answer my questions. The Freedom of Information Act requests revealed their "study" was not at all what it was presented to be. I believe that the people involved in the CDC MMWR [Morbidity and Mortality Weekly Report] are guilty of gross misconduct. These authors refused to correct the scientific record, which was being twisted to suggest that drinking water with even 300 parts per billion lead (20 times the federal limit of 15 parts per billion) would not harm anyone. Someone would have to ask them why they refused to answer my questions or to correct the record.

PNA: What has CDC said about your finding that DC residents' blood lead levels were tested long after they knew not to consume the lead-contaminated water? Have they accepted it as a fact, or are they disputing your claim?

Dr. Edwards: They have flatly refused to answer any questions that I have posed about their work. They admitted to freelance reporter Rebecca Renner a few years ago that I was correct about the months to a year gap between the time residents were told of the high lead in water and the time their blood lead was tested. By the way, their refusal to answer questions and to defend their work is also completely contrary to written CDC policy regarding publications in MMWR. But as far as I can tell, following their own written guidelines does not seem to concern those at CDC who are working on this issue. A few hours after my own work was published, lead author Mary Jean Brown admitted to the Washington Post that the CDC MMWR was "clearly" not scientific. I agree with that statement. First and foremost, the CDC MMWR has been a public relations coup for DC WASA. I don't know why CDC is in the business of publishing work that is "clearly" not scientific, or why they would sit by while DC WASA continued to mis-represent what happened.

PNA: You said that "the data that was presented to the public, much of it was just completely fabricated." Can you say more about this? What are some of the key fabricated data we should know about?

Dr. Edwards: Fabrication involves "making up data out of thin air," as well as knowingly presenting data as if it is something that it is not. Failure to disclose the months to a year that DC residents in the "300 parts per billion" study were not drinking water, and telling everyone in DC that those who were tested represented the "worst case," is an example of fabrication. There was another study of "65 children" who supposedly had elevated blood lead, and whose homes were tested by DC DOH, and it was claimed by DC WASA that "in every case" they found lead paint and lead dust over federal standards. This was even cited to the US Senate in written testimony by DC WASA's General Manager Jerry Johnson. The fact of the matter is that this "study" never existed. The data were made up of thin air. There are many more examples, but I do not have time to discuss them all.

Does WASA's Compliance with Federal Regulations Mean that Your Water is Safe to Drink?

2009-02-20T21:24:00.048-05:00

Recent revelations about the harm done to hundreds, if not thousands, of DC's infants and toddlers from the 2001-2004 lead-in-water contamination have raised new concerns about the safety of our drinking water today.

Public officials responded with a new wave of assurances. On Jan. 27, WASA told the Washington Post that "the most recent tests of the city's water show lead levels in the safe range." On Jan. 28, in a web alert, WASA's General Manager Jerry Johnson said, "I want to assure the public that District drinking water is safe and meets or exceeds every federal standard." Mr. Johnson delivered the same assurance on video (see below). On Feb. 1, the Chairman of WASA's Board of Directors wrote to the Washington Post that, "What people should know first and foremost is that DC drinking water is safe and meets or exceeds all federal safety standards." On Feb. 14, DC Attorney General Peter Nickles "warned against panic because officials have found the drinking water to be safe."

The question we have to ask is this: does WASA's legal compliance with the federal Lead and Copper Rule (LCR) mean that the drinking water in every resident's home and every child's school does not contain concentrations of lead that can pose a health risk?

The answer is "no," and this is why:

Even though the District no longer faces the extreme lead-in-water problem of 2001-2004, serious questions remain about the methods by which WASA monitors our water for compliance with the LCR. It is because of these questions that the DC Department of the Environment is currently conducting independent testing of the District's water for lead. In other words, we are not yet sure that our drinking water actually meets federal lead safety standards, as WASA claims (we will write more about this issue later).

But even if WASA monitored our water properly and results showed that they were in compliance with the LCR, DC residents would still have no guarantee that the drinking water in their individual homes and schools is not lead-contaminated.

Here's the reason:

The LCR allows for 10% of homes in a water utility's monitoring pool to have lead-in-water problems of any magnitude. In 2006 and 2007, for example, 4.5% of the homes monitored by WASA had elevated levels of lead in the 1st draw sample, and 9% had elevated levels of lead in the 2nd draw (or "flush") sample. These high lead-in-water concentrations were obtained despite WASA's use of a protocol that required 10 minutes of flushing the night before sampling, a practice known to hide lead.

According to the EPA, the level of lead in drinking water below which there is no known or expected risk to health is zero parts per billion. The Centers for Disease Control and Prevention states that “for homes with children or pregnant women and with water lead levels exceeding EPA’s action level of 15 parts per billion,” only bottled water should be used. WASA’s 2006 and 2007 compliance measurements show numerous 1st draw samples in the hundreds of parts per billion. These measurements represent lead-in-water levels citywide. The small number of homes with excessively high levels of lead in WASA’s targeted sampling could translate into potentially thousands of District residences with elevated levels of lead at the tap.

EPA law regulates only 1st draw water samples. 2nd draw samples, which are more representative of the water we use to drink and cook, do not count. If 2nd draw samples counted, WASA’s 2006 and 2007 LCR compliance monitoring data would have rendered the agency out of compliance with EPA regulations. Specifically, WASA’s July-December 2006 compliance data show that 13 of the 106 2nd draw measurements exceed the EPA action level of 15 parts per billion. Similarly, the agency's July-December 2007 compliance data show that 13 of the 101 2nd draw measurements also exceed 15 parts per billion. These data strongly suggest that lead in the water of thousands of District homes will frequently be elevated above the action level following an initial draw.

EPA's LCR does not cover drinking water in schools. This means that neither sampling, nor remediation of lead-contaminated school water is required by law. Schools that test the water do so voluntarily. Although lead-in-water levels at DC Public Schools are dramatically lower today than they were in 2007 due to the installation of water filters, some problems remain (see the 2008 PNA/Virginia Tech report).

DC government data in 2007-2008 show that contaminated drinking water continues to be either the sole or a contributing lead source for 9% of DC children with elevated blood lead levels whose water was tested for lead. This percentage is based on a sampling method that does not follow the standard EPA protocol and can miss lead.

If you want to be sure that lead in your drinking water is below 15 parts per billion, we recommend that you have your water tested by an independent EPA-accredited laboratory. Make sure that you take both a 1st and 2nd draw sample. Mail bottles back to the lab, requesting that they use 2% nitric acid in the first step (prior to the mandatory holding time of the acidified bottle), instead of the specified 0.15% nitric acid (pH < 2). Use of a stronger acid is allowed in the EPA protocol, and makes it more likely that lead particles will not be missed.

A premier water testing lab is the Environmental Quality Institute, at the University of North Carolina, Asheville (we have no ties to EQI, but it has been recommended highly by independent scientists, public health advocates, and government officials alike).

Video: WASA's General Manager Jerry Johnson assures DC residents that the water meets or exceeds federal lead safety regulation standards, 1/28/09.

The Real Cost of 25 Words That Sold for $750,000

2009-02-13T21:00:00.017-05:00

Today's front page Washington Post article "Agency's Role Probed in DC Water Report" is the fifth in a series that is slowly but surely lifting the wool from DC's eyes about the harm done to our children from lead in the city's drinking water during 2001-2004.

The article focuses on the paper "Elevated Lead in Drinking Water in Washington, DC, 2003-2004: The Public Health Response," written by WASA consultant and former chair of the Department of Environmental and Occupational Health at the George Washington University School of Public Health, Tee L. Guidotti, MD, MPH. This paper concluded with the following 25 words: "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."

Dr. Guidotti and his client repeated this "no harm done" mantra again and again, in one form or another, at City Council hearings, as well as WASA community meetings and educational factsheets. The claim is contradicted not only by prior scientific knowledge, but also by the new Environmental Science & Technology study, which found that DC's 2001-2004 lead-in-water crisis caused elevated blood lead levels in hundreds, if not thousands, of infants and toddlers.

The WASA/George Washington University contract paid Dr. Guidotti and his colleagues over $750,000 in a 3-year period (as far as we know, this contract is still active). That's a lot of ratepayer money for what we got in return: a rogue water utility that seems answerable to no one, and a public that is in the dark about the real health risks from lead at the tap. Just in the last year, for example, WASA managed to walk away unscathed from wasting around $100 million on 9,000+ partial lead service line replacements, which can at times make lead-in-water levels worse for an undetermined duration. At the same time, many WASA customers remain unaware of and unprotected from the health risks from such replacements.

The real cost of Dr. Guidotti's 25 words was the disbelief it reinforced in us about the toxicity of lead in water. DC Council member Jim Graham echoed the thoughts of many in DC when he told the Washington Post that, "The paper's assurance that drinking water was safe 'was used over and over and over again.'" Indeed, WASA had Dr. Guidotti present his "no harm done" thesis at multiple forums, including a series of community meetings between January-May 2008, and a WASA Board of Directors' meeting in June 2008.

Today a colleague and I got a call from someone we had contacted some time ago to report WASA's water sampling irregularities at DC public schools. At the time, this person was in a position to help, but decided against getting involved. Now, this person said, they too felt partly responsible for the mess we're in. "I thought it was just lead paint...," the caller confessed.

This is what we got for our $750,000: inaction about a serious public health risk, and now guilt by people who are caring and conscientious and would have done something had they known the truth. Tragic.

Contemplating the "Slight" and the "Subtle"

2009-02-05T21:09:00.008-05:00

What did you think about Saturday's Washington Post article on the public health implications of the 2001-2004 lead-in-water crisis?

We were perplexed by it.

"Experts View Public Health Impact as Slight," declared the subtitle. The article said:

"The effects [of the harm on children when lead levels in the District's water spiked in 2001-2004] could include the loss of two to three IQ points and a higher risk for behavioral problems, even in children whose bloodstream lead stayed below the threshold of concern set by federal health officials [i.e., 10 micrograms per deciliter]. But at the exposure levels experienced by the District's children, the public health consequences are likely to be very slight, even under the most pessimistic assumptions, according to several experts as well as published studies."

Very slight, even under the most pessimistic assumptions?!

Then the article quoted the Director of the National Center for Environmental Health at the Centers for Disease Control and Prevention (CDC) as saying that at blood lead levels below 10, "the effects are subtle."

"Slight" and "subtle" were the big takeaways.

You do not have to be an expert to suspect that only one part of the story was emphasized here. First of all, "the exposure levels experienced by the District's children" very likely included hundreds, if not thousands of cases, of blood lead levels at or above 10, the CDC's "level of concern." The scientific literature is absolutely clear that blood lead levels far below 10 are associated with loss of IQ and learning difficulties. In the case of DC, the "slight" and "subtle" characterizations reflect precisely the rhetoric of diminishment that has guided official government statements about lead at the tap since 2004.

Let's briefly revisit the Edwards et al. findings:

The study notes that Environmental Protection Agency models of the harm done from DC drinking water in 2003 predicted that hundreds of DC children's blood lead levels would be raised to 10 or above. Moreover, that thousands more would be elevated to lesser levels (5-9, which are now also associated with health harm), because of exposure to lead through drinking water. That estimate was conservative. Indeed, blood lead data collected from Children's National Medical Center showed a much higher incidence of blood lead over 10 in 2001-2003 as compared to previous years, in keeping with the EPA model and prior scientific research on the subject. In 2001, the incidence of elevated blood lead levels for children under 16 months increased by a whopping 9.6 times.

If this many children were affected and, on average, now perform even a little less well in school and have even a little more difficulty focusing on tasks, wouldn't we want readers of the Washington Post to understand the known adverse health effects of childhood lead exposure and the societal costs of such exposure on a citywide scale? From a family's perspective, aren't symptoms like delayed growth, learning impairment, behavioral problems, and difficulty focusing often coupled with extra needs and costs (let alone worry)? Moreover, isn't the public health impact of thousands, if not tens of thousands, of affected children with high (5-9) and elevated (10 or greater) blood lead levels significant?

On Monday, Dana Best, MD, MPH, a nationally recognized expert in pediatric environmental health and co-author of the new study told listeners of WAMU's Kojo Nnamdi show that "we need to stop trying to diminish the effects of lead and what happened. It's happened. We can't undo that. But we can look forward and make sure that we get clean water, clean lead-free housing, and that our schools are the most well run schools that we can give our children. That's the one way that we can actually reduce some of the harm caused by the lead levels..., by providing a very enriching environment. That can help overcome the loss of 3-5 IQ points."

Dr. Best also explained that it is very difficult to ascertain the "most pessimistic" circumstances, mentioned in the Washington Post. "It is very hard to say what is the worst case," she said. "One of the things that is a concern is that these elevated blood leads due to elevated water lead occur in a background of other sources. So if your child is exposed to lead through other sources plus the water lead level then we get something that can be higher than it would have been otherwise. [...] If you have a child who's already at some risk because they had some other problem that caused them to have lower IQ, or some behavioral problems and then on top of that you add lead, you can be ending up with a child who needs special schooling or is unable to develop into a fully functioning independent adult. These are real issues that we are now facing."

The District's now revamped lead poisoning prevention program takes high and elevated blood lead levels very seriously. It sponsors a service that allows any DC family with a child under 6 years of age to request a home visit by trained staff who offer information about lead poisoning prevention and take a few dust samples for lead analysis. If the analysis shows high environmental lead, the program includes a second visit that teaches parents how to properly eliminate the hazard. When a child has blood lead levels of 10 or greater the city sends trained risk assessors to the child's home to identify potential lead exposure sources. The focus of these assessments is on paint, dust, and soil (water is now beginning to be sampled properly as well). When such sources are identified as contaminated, property owners are required to correct them. If they fail to do so, the city has the legal authority to take them to court. And it does.

On average, DC serves about 90 families annually who are identified with blood lead levels 10 or greater for risk assessments and follow-up care. If the number of children harmed from the 2001-2004 lead-in-water crisis is in fact in the thousands, will the city characterize the impact -- in terms of school performance, socially, and economically -- as "slight"? And will all affected families perceive the burden as "subtle"?

Written with input from Ralph Scott, Alliance for Healthy Homes

WASA's Damage Control: New Face, Old Rhetoric

2009-01-31T11:35:00.028-05:00

Isn't it deliciously ironic that exactly 5 years after District residents found out about WASA's two and a half year cover-up of the historically unprecedented contamination of our water, our water utility chose to respond to this week's news about the harm done to hundreds of infants and children with the same old recycled and misleading rhetoric that they have been using since 2001?

In "Our Pledge to Keep the District's Water Safe" (Letter to the Editor, Washington Post, 2/1/09), William M. Walker, President and Chief Executive Officer of two real estate financial service firms in Bethesda, MD, and the newest member -- and Chair -- of the WASA Board of Directors, gave us the following assurance:

"What people should know first and foremost is that DC drinking water is safe and meets or exceeds all federal safety standards."

The desire to comfort an angered public, and cast doubt on the merits of a study that just exposed the serious harm to which your agency's actions led is understandable. But acting on this desire is not, when the facts contradict your assurances. Here are some points, Mr. Walker, you probably ought to have considered before raising your wing to fold us back into WASA's deceptive, soporific nest:

Even though the District no longer faces the extreme lead-in-water problem of 2001-2004, serious questions remain about lead at the tap in our city. Because of these questions, in Feb. 2008, Councilmember Jim Graham proposed that DC government conduct independent testing to determine the quality of our water vis-a-vis lead. This testing has still not begun.
DC government data in 2007-2008 show that water continues to be either the sole or a contributing lead source for some DC children with elevated blood lead levels. If the parents of these children were to visit you, Mr. Walker, would you be able to look at them in the eye and repeat the assurance you wrote in your letter to the Washington Post?

WASA has never proactively alerted the public about lead-in-water problems. Since 2001, such problems have been uncovered either by the media or by independent investigators. During the height of the contamination (in 2001-2003), the agency kept proclaiming that "Your Drinking Water is Safe" in various public education documents. But even after the cover up was made public, and residents finally began protecting themselves from continued exposure to lead at the tap, former Chair of WASA's Board of Directors Mr. Glen Gerstel emphasized under oath that the city's water was safe (see video clips below).

Given your agency's history of false and misleading reassurances, Mr. Walker, what weight do you expect DC residents to give to your comforting, but unsubstantiated, words?

By now, we all need to know that the question "Is DC's water safe to drink?" is by definition misleading. Lead-in-water levels in individual homes depend on many factors, including service line material, solder and fixture material, neighborhood, water use patterns, and time of year. At any given time, one home's (or neighborhood's) water might be safe to drink, while another home's (or neighborhood's) might not. Moreover, the federal water standards you mention in your letter, Mr. Walker, allow for 10% of homes to dispense high lead at the tap. Even when a water utility complies with federal lead safety standards -- and there are serious questions about whether WASA really does -- a significant number of residents might still be exposed to lead-contaminated water.

While we trust that the independent experts you have consulted will be able to explain to the WASA Board the discrepancies between the CDC 2004 paper -- which found no relationship between elevated water lead levels and blood lead levels, and the Edwards et al. 2009 paper -- which found that hundreds of infants and toddlers were harmed as a direct result of the contamination, we will close with some publicized quotes about these two studies:

Statements about the CDC study:

"...a quick and sloppy study to address public health concerns," "...if this article were submitted to a journal to 'prove' that lead in water wasn't an important source, it would have been rejected."
Bruce Lanphear, pediatric epidemiologist and internationally renowned researcher on the effects of lead on children (quoted in Salon, 11/27/06).

"The CDC's director of lead poisoning prevention, Mary Jean Brown, said in a prepared statement yesterday that it was unfortunate that the CDC study was repeatedly cited by government officials as proof of no problem. 'It may have been helpful to more clearly state and explain the limitations of CDC's involvement, particularly the limitations of the health consultation,' she said. 'In retrospect, some people have misinterpreted the intent and scope of the health consultation, including characterizing it as a scientific study, which it clearly was not.'" (quoted in the Washington Post, 1/28/09).

"If people are walking away from this [CDC study] and saying there's no problem with drinking water, I don't know how to respond to that." "We were under some constraints . . . working as quickly as we could."
Mary Jean Brown, Director of Lead Poisoning Prevention, CDC (quoted in the Washington Post, 1/27/09).

Statements about the Edwards et al. study:

“This is the first paper about the D.C. lead crisis to get it right. The authors really show quite convincingly that the lead in the drinking water resulted in lead poisoning in some children.”
Michael Shannon, pediatrician, Harvard Medical School, expert in childhood lead poisoning (quoted in Lead in DC's Drinking Water blog, 1/27/09).

"'...on average, these children experienced elevations in lead exposure that are indicative of harm. So on average we might expect to see an increased risk in behavior problems — such as attention-deficit hyperactivity disorder or conduct disorders — and decrements in IQ.' How big an IQ drop might a three-year exposure to elevated concentrations of waterborne lead cause? 'Our best estimate is somewhere between 4 and 7 IQ points' if the lead levels in a child rose from nondetectable to 10 µg/dl.' [...] So on a population basis [...] 'the impact would be quite substantial, even though for any given child the change might appear subtle.' [...] Failing to protect young children from exposure to lead-tainted drinking water 'is one more crime against children.'"
Bruce Lanphear, pediatric epidemiologist and internationally renowned researcher on the effects of lead on children (quoted in ScienceNews blog, 1/27/09).

Written with input from Paul Schwartz, Clean Water Action

Video 1: Mr. Gerstel's reassuring testimony 5 days after the Washington Post exposed the agency's two and a half year cover up.
Video 2: Former Councilmember Carol Schwartz's reaction to Mr. Gerstel.

5 Year Anniversary

2009-01-31T07:58:00.007-05:00

After five years of official assurances that the city’s 2001-2004 lead-in-water crisis did not cause significant health harm, we now learn that hundreds, if not thousands, of infants and toddlers experienced blood lead levels above the Centers for Disease Control “level of concern,” as a result of the contamination. Those children are at risk of irreversible IQ loss, developmental delays, and behavioral problems.

Today marks the 5th anniversary of the Washington Post front page article informing District residents about a citywide contamination of our drinking water with lead. This article reported that in the summer of 2003, 4,075 of 6,118 homes tested dispensed high levels of lead at the tap. In over 2,000 of those homes, lead concentrations exceeded the Environmental Protection Agency's "action level" of 15 parts per billion by three times or more. Some water lead measurements were in the hundreds and even thousands parts per billion.

WASA had known about a lead-in-water problem since mid-2001, but did not begin notifying homeowners until November 2003. Lynette Stokes, MD, who oversaw the DC Department of Health lead screening program, told the Washington Post that lead dust and paint posed “a far greater risk” than contaminated water. Dr. Stokes’ statement did not take into account the following:

EPA’s estimate that in areas with lead-contaminated water like DC, “the total drinking water contribution to overall lead levels may range from as little as 5 percent to more than 50 percent of children’s total lead exposure. Infants dependent on formula may receive more than 85 percent of their lead from drinking water" (Federal Register, Vol. 56, No. 110, June 7, 1991, p. 26470). This statement was published at a time when lead sources other than water were more prevalent than they are now.

Numerous scientific studies showing that for formula-fed infants and young children contaminated drinking water can be a potent pathway of exposure to lead (see references in Edwards et al. 2009 study)

The concentrations of lead in DC’s drinking water were unprecedented in modern US history.