Graham Sustainability Institute

Michigan's Revised Lead and Copper Rule FAQ

Frequently Asked Questions

            

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View a complete list of all FAQs with hyperlinks to individual questions and answers.

How can I be exposed to lead in drinking water?

Lead can move into tap water from water pipes and plumbing materials that contain lead, especially if the water supply is not properly managed to control for corrosion, as discussed here. This means that lead could be present in drinking water in property that has lead sources in household plumbing or in the water service line that connects the water main in the street to the property. Specific examples of household plumbing sources of lead in tap water are described here. The major concern for exposure is swallowing lead-contaminated water, whether as drinking water, other beverages prepared with water, food cooked with water, or rinsing after brushing teeth. Powdered infant formula should be prepared with bottled water or filtered water, as described here. Because skin does not absorb to any great extent the lead that leaches from plumbing into water, skin contact while showering, bathing, laundering, or washing dishes is considered safe.¹,² Exposure to water vapor from laundry, showering, etc.is also not a concern for lead from plumbing because the water-soluble lead does not easily evaporate from water into the air.² Additional information about steps consumers can take to reduce their risk of exposure to lead in drinking water can be found here and here.

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Lead can be present in drinking water where there is lead in plumbing or in the water service line. Water pipes, plumbing fixtures and plumbing materials that contain lead can release lead into tap water. Specific examples of household plumbing sources of lead in tap water are described here. In addition, galvanized service lines and plumbing can increase the risk of lead leaching into drinking water, as described here.

Corrosion is a chemical reaction that allows lead to move from the pipes into the water, either dissolved or as small particles. Corrosion increases significantly if the water is too acidic (low pH) and has low amounts of minerals.¹ Other factors that affect water corrosiveness include water temperature, the condition of the pipes, and the amount of time water resides in the pipes.¹ Effective corrosion control by the water supplier limits corrosion in pipes and can reduce lead release into drinking water, as discussed here. However, corrosion control does not eliminate all of the risk of exposure to lead in drinking water.

Swallowing lead-contaminated water is the major concern for exposure if lead is in the drinking water. In addition to drinking as plain water, you can be exposed by using the water to prepare other beverages, cooking food, or rinsing after brushing teeth.¹ Some children may swallow lead in water in the bathtub, during showers, or even by drinking from the garden hose because these plumbing materials may have higher lead content as described here. Powdered infant formula should be prepared with bottled water or filtered water, as described here, to avoid lead exposure. Do not use water from the hot water tap for drinking or food preparation because it can have elevated levels of lead. These and other steps to reduce the risk of exposure to lead in drinking water are described here.

Because skin does not absorb lead from water, skin contact while showering, bathing, laundering, or washing dishes is considered safe. Likewise, exposure to water vapor from laundry, showering, etc.is not a concern for lead exposure because lead does not readily evaporate from water into the air.

Further discussion of activities that are okay or should be avoided if lead is in the drinking water are described here.

References:

  • ¹ Lead in Drinking Water (2019, July 30). In Centers for Disease Control and Prevention. Retrieved September 22, 2019, from cdc.gov/nceh/lead/prevention/sources/water.htm.
  • ² Agency for Toxic Substances and Disease Registry. Toxicological profile for Lead (Draft for Public Comment). Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service; 2019.

Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Children, Lead Health Effects

What are the health benefits of lead service line replacement?

Full lead service line replacement brings a reduction in risk of lead exposure by removing the largest source of lead in contact with drinking water in homes and buildings. Reducing lead exposure can improve health outcomes for children and adults by reducing developmental disorders, attention deficit hyperactivity disorder-related behaviors, anemia, hypertension, and kidney and brain damage described in this FAQ Response.

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Replacing lead pipes with pipes that do not contain lead is a strategy to reduce lead exposure from drinking water.¹ Full lead service line replacement removes the primary source of lead in drinking water.² Lead pipe and plumbing material replacement are most effective when combined with educational interventions. However, it is important to note that lead in drinking water is typically one of several potential sources of lead in older homes. While there are benefits from lead service line replacement, other sources of lead exposure may also need to be removed.

The U.S. Centers for Disease Control (CDC) has determined that there is no safe level of lead in the blood.³ Eliminating lead service lines can reduce lead exposure from drinking water. This may have important health benefits, especially for pregnant women, fetuses, and young children who are at increased risk for lead exposure from drinking water. Reducing lead exposure can improve health outcomes for children and adults by reducing developmental disorders, attention deficit hyperactivity disorder-related behaviors, anemia, hypertension, and kidney and brain damage described in this answer.

Some economists have monetized the benefits of lead service line replacements, including decreased medical and education costs. Lead service line replacements may result in $1.33 in benefits for each dollar invested.4

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Lead Health Effects, Michigan Lead and Copper Rule, Compliance

Is it safe for me to cook, shower/bathe, do laundry, wash dishes, etc., using water with elevated lead levels?

If water has elevated lead levels, you should avoid swallowing the water.¹ You should not cook, prepare food and beverages, or brush your teeth with lead-contaminated water. You should avoid swallowing water while showering or washing your face if the water is known to have lead present. In addition, only use bottled water or filtered tap water to make powdered infant formula (more information can be found here). Lead in water is not readily absorbed by the skin.¹,² Likewise, lead does not readily evaporate from water into the air.² As such, lead-contaminated water is not a concern for exposure in the air or by contact with the skin while showering, bathing, laundering, or washing dishes.³ Also, dishes can be washed in water with an elevated lead level but should be dried right after rinsing.³

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Avoid drinking, cooking, preparing food and beverages, and brushing your teeth with water that is known to have lead present. Lead that is swallowed can be taken up into your body, as described here, and make you ill, as described here. Because of increased vulnerability of infants to lead (described here), always use bottled water or filtered tap water to make infant formula, regardless of water lead testing results.

The most abundant form of lead found in drinking water is not readily absorbed by the skin.² Because skin does not absorb water-soluble lead, skin contact while showering, bathing, laundering, or washing dishes is considered safe.¹ Although showering, bathing, laundering, washing dishes, and cooking can generate water vapor, exposure through the air is not a concern because lead does not readily evaporate from water into the air.² Also, lead will not be taken up by dishes made of glass, metal, or porcelain when washed in lead-contaminated water.³ However, dishes washed with lead-contaminated water should be dried right after rinsing to reduce residue that might contain lead.³

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Children, Lead Health Effects

What do results of blood lead testing mean?

Blood lead test results only indicate recent or ongoing exposure. There is no safe blood level of lead. However, federal health officials set a reference value of 5 micrograms per deciliter (μg/dL) of blood. Blood lead levels above 5 (μg/dL) are considered higher than expected in the general population. Parents should consult a pediatrician for medical advice if a child’s blood lead level is more than 5 μg/dL. If the blood lead level is at or above 45 μg/dL, the child should be seen by a doctor as soon as possible, and immediate steps should be taken to identify and minimize sources of lead exposure. An infographic by the Michigan Department of Health and Human Services on “What Your Child’s Blood Lead Test Means” is helpful for understanding a child’s blood lead test results.⁷

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Exposure to lead may not cause immediate or obvious symptoms in children. Thus, blood lead testing is often used as an indicator of environmental exposure. Blood lead screening is recommended for children who may be at higher risk for lead exposure. Some important factors that increase risk for lead exposure are age of the home, residential zip code, and parent’s occupation. In some states, all children are required to be tested for lead in blood. Blood lead testing is routinely part of “well child” visits to the pediatrician at the ages of 1 and 2 years. It is recommended at those ages because those children are more mobile and have more hand-to-mouth activity, behaviors that place them at greatest risk for household lead exposure from chipped paint, dust, soil, etc. Importantly, blood lead screening programs that target children 1-2 years of age are designed to detect peak exposure from household lead. However, they do not adequately capture exposure risk for lead in water. This is because pregnant women and infants are more vulnerable than toddlers to lead exposure in water.

Blood lead testing only indicates recent and/or ongoing exposure. The half-life of lead in adult human blood has been estimated at approximately 28 days, which means that after an exposure incident, it takes about one month for lead levels in the blood to decrease by one-half.² It is important to note that a low blood lead level result does not necessarily mean that a person has been without exposure to lead at an earlier time.

In addition, the amount of lead measured in the blood does not necessarily reflect the total amount of lead in the body. Lead that is inhaled or swallowed travels from the lungs and intestinal tract to the blood and organs such as liver and kidney, and then gradually moves from the blood and those organs into other tissues such as bones and teeth where it can be stored for several years before being released into the blood again.

The degree to which a particular lead level poses a danger depends on the age and health of the person, the amount of lead they are exposed to, and the amount of time they are exposed to lead.³ The Centers for Disease Control and Prevention (CDC) is the federal agency with the responsibility to protect Americans from health, safety, and security threats. Because of lead’s irreversible toxicity to the brain and other nervous tissue, the CDC has determined that there is no safe blood level of lead. Consequently, the CDC and other public health organizations recommend that efforts focus on primary prevention of lead exposure - detection of lead in the environment before children are exposed.

The CDC uses 5 μg/dL as the “reference level” for blood lead level measurement in children. This level of 5 μg/dL is based on the U.S. population of children ages 1-5 years who are in the highest 2.5% of children when tested for lead in their blood. This value is derived from the National Health and Nutrition Examination Survey (NHANES) that is part of the CDC’s National Biomonitoring Program. The current reference value is based on NHANES data from 2007-2008 and 2009-2010. The CDC will assess the reference value every 4 years using the two most recent NHANES surveys.

Sometimes blood is sampled using a capillary blood test (commonly known as fingerstick or fingertip prick), especially with young infants. This involves puncturing the the skin, usually a fingertip, to obtain a few drops of blood. It is called a capillary blood test because the blood is obtained from capillaries - the smallest blood vessels in the body - that lie just below the protective outer covering of the skin.8 On the other hand, venipuncture is collection of blood from a vein, usually from the inside of the elbow or the back of the hand. Venipuncture involves insertion of a needle into the vein and use of a syringe to withdraw blood.10 Because capillary blood tests are faster, less invasive, and require less blood withdrawal compared to venipuncture, capillary blood tests may be useful with small infants and for screening purposes. However, blood lead results greater than 5 μg/dL with a capillary blood test should be confirmed with a venous blood draw because of the greater reliability of blood lead results from venipuncture.

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Tags: Lead Exposure, Blood Testing, Children, Lead Health Effects

If I was exposed to lead in my drinking water, will it show up in my blood sample?

If a home’s water is contaminated with lead, the lead can enter the body and may be detected in the blood if the water is swallowed.¹ However, detection of lead in blood should not be relied on as an indication of lead contamination of drinking water. Likewise, it is not appropriate to wait until lead is measured in blood before taking action if lead is detected in the water. The ability to detect lead in blood depends on several factors that include the amount and duration of exposure, and the age, health, and diet of the exposed individual.¹,² Furthermore, blood lead testing only indicates recent or ongoing exposure.¹ Importantly, detection of lead in a blood sample will not tell you if drinking water is the source of the lead exposure. This is because any exposure to lead from any source may increase your blood lead levels. Additional information on blood lead testing can be found here. If lead is detected in your water or blood, consult with your physician and local health department to determine all possible sources of lead exposure.

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If lead-contaminated water is swallowed, lead can enter the body and may be detected in the blood.¹ However, the test does not tell how the person was exposed to lead. That is, detection of lead in the blood will not tell you if you were exposed to lead through drinking water.

Blood lead tests are used by public health and medical professionals to determine if lead exposure has occurred. However, the test has limitations. Several factors determine if lead will be measured in a person’s blood even if that person has consumed lead-contaminated water.¹,² These factors include:

  • How much lead is in the water;
  • How much lead-contaminated water was swallowed;
  • If there was exposure to lead from sources other than water, such as paint, soil, dust, etc.;
  • Whether exposure to lead (from any source) was ongoing at the time of blood sampling, and if discontinued, how long ago the last exposure was;
  • How long the exposure to lead (from any source) lasted;
  • The age and health of the person; and
  • The diet of the person -- especially if the diet is rich or deficient in calcium and iron.

It is particularly important to note that a blood lead test is only a reliable indicator of recent and/or ongoing exposure. The half-life of lead in adult human blood has been estimated at approximately 28-36 days.¹,² This means that after an exposure incident, it takes about one month for lead levels in the blood to decrease by one-half.¹ Furthermore, blood lead levels do not reflect the total amount of lead accumulated in the body from past exposures. Some of the lead that is in the blood moves from the blood into other parts of the body, such as bones and teeth, where it can be stored for several years. Release of lead from the bones is accelerated under conditions of increased bone turnover, such as during pregnancy and lactation, and with bone loss in post-menopausal women and the elderly.¹ You can learn more about blood lead testing here.

Because any exposure to lead may increase your blood lead levels, it is important to consult with a physician and your local health department if a blood sample shows elevated levels of lead. This is especially important for children, who have increased susceptibility to lead, as discussed here. You can locate your Michigan local public health office using the online Local Health Department Map.² These health professionals will help you understand blood lead test results (discussed here) and will guide you to the next steps. Most Michigan local public health departments have a public health nurse who can help identify possible sources of lead exposure in the home, which can include lead-containing water pipes, plumbing fixtures, paint dust, some jewelry, certain hobbies, and more.³

The bottom line is that a blood lead test alone cannot definitively determine if a person is exposed to lead in drinking water.

References:


Tags: Lead Exposure, Lead in Drinking Water, Blood Testing, Children

What are the health impacts of being exposed to lead?

Lead exposure can have many health impacts. The greatest concern for health is the impact of lead on the developing brain. Other significant health impacts include damage to blood cells, the kidneys, and the cardiovascular system. The health effects that occur from lead exposure depend on many factors, including:

  • How much lead exposure occurred;
  • Age at the time of lead exposure; and
  • Other medical conditions.

The U.S. Centers for Disease Control (CDC) has determined that there is no safe level of lead exposure for health.

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There are significant concerns for lead’s ability to damage the brain and other nervous tissue, blood cells, the kidneys, and the cardiovascular system. However, lead has the potential to diminish the function of any organ in the body. Moreover, the health impacts from lead exposure can vary from subtle changes to obvious disease. The health effects that occur from lead exposure depend on many factors. Some of the most important factors that determine health outcomes are:¹

  • How much lead exposure occurred. Lead exposure includes the amount of lead in each exposure source and the length of time of exposure. This is commonly referred to as the dose. As the dose increases, more different types of health effects and more severe health effects occur.
  • The age at the time of lead exposure. Children, including fetuses in the womb, are at the greatest risk for harm to health. The risk to a child from lead exposure decreases gradually over time up to adulthood.
  • Other medical conditions. Certain health conditions, such as pregnancy, liver disease, and kidney disease, can increase risk for harm from lead exposure.

It is lead’s effects on the developing brain that are of greatest concern. Lead damage to the brain of a child can last into adulthood and be permanent. Scientists have detected decreases in children’s IQ scores even at the lowest levels of lead exposure. Decreases of 1-13 IQ points have been observed with each increase of 10 μg/dL of blood lead level.² At high blood lead levels (100 – 120 μg/dL in adults or 70 – 100 μg/dL in children), more severe impacts on brain function can occur. At these higher blood lead levels, injury to the brain can cause a variety of symptoms such as: increased irritability, poor attention span, forgetfulness, tiredness, headache, and dizziness.

The greatest concern for lead exposure in the cardiovascular system is increased blood pressure. Lead has been linked to increased blood pressure even at the lowest levels of lead detection in the body.³ Elevated blood pressure could lead to kidney disease, among other problems. Lead exposure has impacts on blood cells, also. Elevated blood lead levels can decrease the number of red blood cells in the blood, a condition known as anemia. Because red blood cells carry oxygen from the lungs to the rest of the body, anemia can lead to too little oxygen in the body. In addition, lead can also decrease the ability of red blood cells to carry oxygen by reducing the amount of the oxygen-carrying protein hemoglobin. These effects on red blood cells can make a person feel tired or weak. They can also cause shortness of breath, dizziness, headaches, or an irregular heartbeat.4 Although elevated blood lead levels have been known to cause anemia for many years, more recent studies report increased anemia in children with blood lead levels as low as 10-20 μg/dL.5,6 Likewise, a recent study found decreased hemoglobin levels in children with blood lead levels below 10 μg/dL.7 Lead affects other blood cells, as well. Platelets are blood cells that help form blood clots to stop bleeding. Decreased platelet counts were observed with blood lead levels below 10 µg/dL.8

Lead has adverse effects on kidney function. Decreased kidney function has been observed with relatively low blood lead levels (below 10 μg/dL). Glomerular filtration rate (GFR) is used to understand how well kidneys are working. GFR was found to decrease with increasing blood lead levels, with a 6% decrease in GFR at blood lead levels below 10 µg/dL. Decreased kidney function can lead to a buildup of waste products in the body because kidneys cannot properly remove/filter waste products. Kidney disease can also disrupt blood pressure regulation.

References:

  • ¹ Agency for Toxic Substances and Disease Registry (ATSDR). “Relevance to Public health” Lead. atsdr.cdc.gov/toxprofiles/tp13-c2.pdf.
  • ² Hong SB et al. Environmental Lead Exposure and Attention Deficit/Hyperactivity Disorder Symptom Domains in a Community Sample of South Korean School-Age Children. Environmental Health Perspectives. 2015 Mar;123(3):271–276. PubMed PMID: 25280233; PubMed Central PMCID: PMC4348739.
  • ³ Faramawi MF et al. Environmental lead exposure is associated with visit-to-visit systolic blood pressure variability in the US adults. Int Arch Occup Environ Health. 2015 Apr;88(3):381-8. doi: 10.1007/s00420-014-0970-5. Epub 2014 Aug 3.PMID: 25086568.
  • 4 National Heart, Lung, and Blood Institute. Anemia. nhlbi.nih.gov/health-topics/anemia. Accessed May 31, 2018.
  • 5 Hegazy AA, Zaher MM, Abd El-Hafez MA, Morsy AA, Saleh RA. Relation between anemia and blood levels of lead, copper, zinc and iron among children. BMC Res Notes. 2010 May 12;3:133. doi: 10.1186/1756-0500-3-133. PubMed PMID: 20459857; PubMed Central PMCID: PMC2887903.
  • 6 Jain NB, Laden F, Guller U, Shankar A, Kazani S, Garshick E. Relation between blood lead levels and childhood anemia in India. Am J Epidemiol. 2005 May 15;161(10):968-73. PubMed PMID: 15870161.
  • 7 Liu J, McCauley L, Yan C, Shen X, Pinto-Martin JA. Low blood lead levels and hemoglobin concentrations in preschool children in China. Toxicol Environ Chem. 2012;94(2):423-426. doi: 10.1080/02772248.2011.628001. Epub 2011 Oct 28. PubMed PMID: 29430074; PubMed Central PMCID: PMC5802420.
  • 8 Concerato GM et al. Blood thioredoxin reductase activity, oxidative stress and hematological parameters in paintersand battery workers: relationship with lead and cadmium levels in blood. J Appl Toxicol. 2013 Feb;33(2):142-50. doi: 10.1002/jat.1731. Epub 2011 Sep 9. PubMed PMID: 21910133.

Tags: Lead Exposure, Lead in Drinking Water, Blood Testing, Children, Lead Health Effects

What are the health impacts of being exposed to lead in drinking water?

The U.S. Centers for Disease Control (CDC) has determined that there is no safe level of lead exposure for human health.¹,² Children are particularly vulnerable to adverse health effects from lead, as discussed here. Lead’s effects on the developing brain are of greatest concern. Scientists have detected decreases in children’s IQ scores even at the lowest levels of lead exposure (further discussion can be found here). Lead in drinking water can be taken up into the blood, as described here. How much lead is detected in the blood of a person exposed to lead in drinking water depends on several important factors, as described here. Once in the blood, lead can move to various parts of the body and damage sensitive tissues, as described here. Some of the health effects from drinking water highly contaminated with lead are anemia, hypertension, renal impairment, and toxicity to the reproductive organs, described here.

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References:


Tags: Lead Exposure, Lead in Drinking Water, Children, Lead Health Effects

What populations (age groups) are at highest risk for lead exposure from lead in drinking water?

Pregnant women, fetuses, and young children are at highest risk for lead exposure from drinking water. Once lead is in the mother’s blood, the fetus can be exposed because lead moves from the mother’s blood to the fetus. Lead exposure can have a negative impact on fetal body growth and brain development. Moreover, lead has been associated with premature birth and increased possibility of miscarriage. Young children take up more lead from drinking water than adults, putting them at higher risk. The contribution of lead from drinking water compared with other sources of lead exposure is highest for infants less than 6 months of age.12

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The highest risk for lead exposure from lead in drinking water is for pregnant women, babies in the womb, and young children. Pregnant women drink more water than non-pregnant women, and lactating women drink much more water than non-pregnant or non-lactating women.1,2,3 This increases opportunity for lead in contaminated drinking water to be absorbed into the blood of pregnant women or women who are breastfeeding their infant.

Lead in the mother’s blood easily crosses the placenta to expose the fetus. Lead in the mother’s blood also crosses into breast milk and contributes to an infant’s blood lead level.4,5 The amount of lead in breast milk is low compared to mother’s blood. However, lead levels were comparable or higher in breast milk compared to mothers’ blood plasma, the liquid portion of blood without red and white blood cells.5 In addition, hormone changes may cause lead levels in a mother’s blood to rise because of increased release of lead from the mother’s bones late in pregnancy and if she is breastfeeding.4

Children drink more water relative to their body weight than adults.³ Although children drink less than adults in terms of volume of water, their smaller body size means that the same amount of lead in the same amount of water can have a greater impact. Also, children who drink lead-contaminated water take up lead into their bodies much more effectively than adults. Compared to adults, infants take up about 4-5 times more lead from drinking water into their bodies.6 This means that blood lead levels can increase to higher levels in children compared to adults drinking the same contaminated water.


Figure source: American Academy of Pediatrics. Council on Environmental Health. Prevention of Childhood Lead Toxicity.7Click to enlarge.

The major sources of lead in blood are food, soil, dust, inhalation, and water. The leading contributors to children’s blood lead levels are shown in the graph above.7 However, the contribution of drinking water as a source of lead exposure changes with age and blood lead level. In children under the age of 6 months, drinking water contributes as much or more lead as soil and dust -- about 40% of the child’s blood lead -- except at high lead exposures.8,9 Drinking water continues to be a significant but less prominent source of lead exposure for children up to 6 years of age, contributing about 10-15 % of blood lead depending on blood lead level.

Fetuses exposed to lead are at risk for adverse health effects. Lead exposure during pregnancy can decrease growth of the baby in the womb. Also, lead can move into the brain of a developing child and disrupt brain development. These effects are often permanent and carry into adulthood. Furthermore, elevated lead levels in mother’s blood during pregnancy can lead to shorter pregnancies (preterm birth) and increase the possibility of miscarriage.10,11,12,13

References:

  • ¹ Ershow AG, Brown LM, Cantor KP. Intake of tapwater and total water by pregnant and lactating women. Am J Public Health. 1991 Mar;81(3):328-34. PubMed PMID: 1994741; PubMed Central PMCID: PMC1405003.
  • ² Zender R, Bachand AM, Reif JS. Exposure to tap water during pregnancy. J Expo Anal Environ Epidemiol. 2001 May-Jun;11(3):224-30. PubMed PMID: 11477520.
  • ³ Kahn, H; Stralka, K. (2008). Estimates of Water Ingestion for Women in Pregnant, Lactating, and Non-Pregnant and Non-Lactating Child-Bearing Age Groups Based on USDA's 1994-96, 1998 Continuing Survey of Food Intake by Individuals. Hum Ecol Risk Assess 14: 1273-1290. dx.doi.org/10.1080/10807030802494618.
  • 4 Gulson BL, et al. Pregnancy increases mobilization of lead from maternal skeleton. J Lab Clin Med 1997;130(1):51-62.
  • 5 Ettinger AS, Roy A, Amarasiriwardena CJ, Smith D, Lupoli N, Mercado-García A, Lamadrid-Figueroa H, Tellez-Rojo MM, Hu H, Hernández-Avila M. Maternal blood, plasma, and breast milk lead: lactational transfer and contribution to infant exposure. Environ Health Perspect. 2014 Jan;122(1):87-92.
  • 6 Theodore I. Lidsky, Jay S. Schneider. Lead neurotoxicity in children: basic mechanisms and clinical correlates. Brain. 2003;126(1):5-19.
  • 7 American Academy of Pediatrics. Council on Environmental Health. Prevention of Childhood Lead Toxicity. Pediatrics. 2016 Jul;138(1). pii: e20161493. doi: 10.1542/peds.2016-1493. Epub 2016 Jun 20. Erratum in: Pediatrics. 2017 Aug;140(2):. PubMed PMID: 27325637.
  • 8 Environmental Protection Agency (EPA). EPA Leads the Way on Lead Exposure Science and Risk Management. January 2, 2018. epa.gov/sciencematters/epa-leads-way-lead-exposure-science-and-risk-management.
  • 9 Zartarian, V., Xue, J., Tornero-Velez, R., and Brown, J. (2017). Children’s Lead Exposure: A Multimedia Modeling Analysis to Guide Public Health Decision-Making. Environmental Health Perspectives, 097009: 1-10.
  • 10 Torres-Sanchez LE, Berkowitz G, Lopez-Carrillo L, Torres-Arreola L, Rios C, Lopez-Cervantes M. Intrauterine lead exposure and preterm birth. Environ Res 1999;81:297–301.
  • 11 Hernandez-Avila M, Peterson KE, Gonzalez-Cossio T, Sanin LH, Aro A, Schnaas L, et al. Effect of maternal bone lead on length and head circumference of newborns and 1-month-old infants. Arch Environ Health 2002;57:482–8.
  • 12 American College of Obstetricians and Gynecologist (ACOG) (2012). Committee on Obstetric Practice. Lead Screening during Pregnancy and Lactation. Committee Opinion 533. Obstetrics & Gynecology,120:416–20.
  • 13 Hertz-Picciotto I. The evidence that lead increases the risk for spontaneous abortion. Am J Ind Med. 2000 Sep;38(3):300-9. Review. PubMed PMID: 10940968.

Tags: Lead Exposure, Lead in Drinking Water, Blood Testing, Children, Lead Health Effects

When should I get my child's blood lead level tested?

The American Academy of Pediatrics (AAP) recommends when and how children should be considered for blood lead testing. ¹ This schedule currently recommends that parents first consult with a pediatrician to discuss potential sources of lead exposure in the child’s environment beginning at six months of age. However, if there is reason for concern for lead exposure, the parents should consult with a pediatrician or their local health department earlier. If a risk for lead exposure is found, such as living in a home constructed before 1978, then the pediatrician may recommend that the child’s blood be tested for lead. ¹ In addition, immigrant and refugee children, as well as children adopted from another country, should have an initial test of their blood lead level soon after arriving in the U.S. Also, only bottledvwater or filtered water should be used to prepare formula reconstituted from powder (further discussed here).

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The American Academy of Pediatrics (AAP) and the U.S. Centers for Disease Control and Prevention (CDC) no longer recommend screening of all children for lead in their blood. However, many local and state agencies have guidelines for blood lead testing in certain communities that have higher risk for lead exposure. ¹ In particular, blood lead testing may be important for children living in older housing (built before 1978) that may have lead paint and lead water service lines. The State of Michigan has a Childhood Lead Poisoning Prevention Program and Lead Safe Home Program to assist target communities of concern for lead exposure. ²

Current recommendations from the AAP and CDC are that parents first consult with a pediatrician to discuss potential sources of lead exposure in the child’s environment. This risk assessment should be done at the following well-child visits to the pediatrician: 6 months, 9 months, 12 months, 18 months, 24 months, and at 3, 4, 5 and 6 years of age. If a risk for lead exposure is found, then the pediatrician may request that the child’s blood be tested for lead. ¹

A variety of potential sources of lead exposure in the child’s environment should be considered. The majority of exposures come from inside our homes from things such as dust, dishware and toys (especially if made outside of the USA), water that passes through lead pipes, and chipping paint that contains lead. Children living in older houses, built before 1978, are at higher risk for lead exposure from paint, lead contamination of soil outside of the home where children may play, and lead water service lines. Even lead paint that has been painted over several times can chip, providing an opportunity for children to pick up and swallow a paint chip. Certain home hobbies that use lead solder, such as making stained glass and jewelry, may be a source of lead exposure in home. Also, refinishing old furniture and woodwork that have lead paint may increase risk of exposure by air, dust, or paint chips. &sup4; You should discuss with your child’s pediatrician if you think your child has one or more of these opportunities to come in contact with lead. In addition, children who have come to live in the U.S. from another country should have an initial test of their blood lead level soon after arriving in the U.S.

References:


Tags: Lead Exposure, Lead in Drinking Water, Water Sampling, Blood Testing, Children, Lead Health Effects

Who should I contact to have my child’s blood tested for lead?

Children can have their blood tested for lead by consulting with the child’s pediatrician or the local health department. You can obtain contact information for local health departments in Michigan using an online map found here.¹ Many Michigan local health departments and other public health clinics offer free blood lead testing of children. For information about when to have your child’s blood tested for lead, see here.

References:


Tags: Blood Testing, Children

What do I do if my child tests high for lead?

Discuss the blood test result with the child’s pediatrician to identify potential sources of lead exposure. You can also contact your local public health office to learn about resources available to families concerned about lead exposure.¹ You can locate your Michigan local public health office using the online Local Health Department Map.² The most important step is to remove the sources of lead so that there is no further exposure. Most local public health offices have a public health nurse on staff who will assist families with understanding risks and options for children with elevated blood lead levels and who will also help identify lead hazards in the home. Information on how to reduce lead exposure in drinking water can be found here. If the child’s blood lead level is dangerously high, a medical treatment may be considered that uses a chelating agent, a medicine that binds with lead to help the body get rid of lead. However, chelation therapy has not been shown to reverse or diminish adverse neurodevelopmental effects of lead.³ Eating a balanced healthy diet with foods with calcium, iron, and vitamin C may help keep lead from being taken up into the body after swallowing.

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Children with elevated blood lead levels should be referred by pediatricians to local public health offices. Also, there are many resources available to families through the local public health offices as part of Michigan’s Childhood Lead Poisoning Prevention Program and Lead Safe Home Program.¹ You can locate your Michigan local public health office using the online Local Health Department Map². Most local public health offices have public health nurses on staff who will assist families with understanding risks and options for children with elevated blood lead levels and children at risk for elevated blood lead levels. Additional services include home assessments to help identify and remove lead hazards from the home environment and family lifestyle to ensure that all sources of lead are identified. Any treatment regimen that does not control environmental exposure to all sources of lead is considered inadequate.

The most important thing to do is to reduce the child’s exposure to lead.4 Treatment varies depending on how much lead is in the blood. Small amounts of lead in the blood are addressed by removing the source of exposure working with your local health department, and using approaches described in a factsheet from the Michigan Department of Health and Human Services.5 Actions you can take to reduce risk of exposure to lead in drinking water are discussed here and here. With elimination of exposure, the blood lead level will decrease gradually over time as the body naturally eliminates the lead. All siblings of a child with a high blood lead test result should be tested, also.

Children with extremely high lead levels in their blood may be recommended for hospitalization to receive a medication called a chelating agent, which binds with lead to help the body get rid of lead. However, a recent report from the U.S. Agency for Healthcare Research found limited evidence that chelation therapy improves long-term blood lead levels and neurodevelopmental health outcomes in lead-exposure children.³ A pediatrician experienced in managing children with lead poisoning should be consulted.

Because nutritional deficiencies, especially deficiencies of calcium and iron, can increase lead absorption from drinking water, a balanced healthy diet may help reduce lead uptake into the body. Consider adding milk, yogurt, cheese, and green leafy vegetables to increase calcium intake. Examples of foods with iron are red meats, beans, peanut butter, and cereals. Vitamin C is found in oranges, green and red peppers, and fruit juice.5

Pediatric Environmental Health Specialty Units (PEHSUs) are a source of medical information and advice on environmental conditions that influence reproductive and children’s health. They are academically based, typically at university medical centers and are located across the United States and Canada. These PEHSUs form a network that is capable of responding to requests for information throughout North America and offering advice on prevention, diagnosis, management, and treatment of environmentally-related health effects in children.6 The Great Lakes Center for Children’s Environmental Health is one of the 10 Pediatric Environmental Health Specialty Units across the country dedicated to children’s environmental health issues. The Great Lakes Center PEHSU’s primary area of focus is Region 5, which includes the states of Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin.7

This website contains information regarding state-wide programs available in Michigan to assist families dealing with lead exposure: michigan.gov/lead/0,5417,7-310-84216---,00.html

This website from the U.S. Centers for Disease Control (CDC) contains a wealth of information regarding childhood lead exposure and poisoning: cdc.gov/nceh/lead/default.htm

This State of Michigan website contains concise information regarding lead exposure, lead poisoning, and actions families can take to reduce lead hazards: michigan.gov/lead/0,5417,7-310-84213---,00.html.

This website contains contact information regarding PEHSU Region 5: pehsu.net/region5.html

This website provides information specifically on lead exposure from drinking water: dc.gov/nceh/lead/prevention/sources/water.htm

This website provides ways of protecting family from exposure to lead: epa.gov/lead/protect-your-family-exposures-lead

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Blood Testing, Children, Lead Health Effects

Does bottle-feeding versus breast-feeding make a difference for exposing infants to lead?

Infant formula prepared with tap water may expose an infant to lead.¹ Parents who prepare infant formula from powder should use bottled water or filtered tap water. Water from the hot water faucet should never be used. Additional information on reducing lead in tap water can be found here.

Breast milk is an excellent source of infant nutrition and offers other benefits for infant health. Still, nursing infants can be exposed to lead through breast milk. This is because lead can move from the mother’s blood into breast milk. Under most circumstances, mothers with blood lead levels less than 40 micrograms per deciliter (µg/dL) should feel at ease choosing to breastfeed.² However, if a mother’s blood lead level is 20-39 µg/dL and if the infant’s blood lead level is 5 µg/dL or higher, the mother’s and infant’s blood lead levels should be monitored, and additional steps should be taken to reduce the infant’s blood lead level.

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Risk for lead exposure with bottle feeding mainly occurs if tap water is used to prepare infant formula from powder.¹ Parents who prepare infant formula from powder should use bottled water or filtered tap water. Hot water directly from the faucet should not be used to prepare infant formula. Infant formula purchased as premade liquid is considered a safe alternative. Historically, some formula sold as premade liquid contained lead because of lead-lined and lead-soldered cans, but this is no longer the case.

Under most circumstances, the contribution of lead exposure from breast milk is expected to be less than from formula. Breastfeeding has many benefits for the health of the infant and is recommended under most circumstances. However, because lead can move from the mother’s blood into breast milk, nursing infants can be exposed to lead through breast milk. The amount of lead that moves from mother’s blood to breast milk is low, 3% or less.¹ This means that a mother with a blood lead level of 10 micrograms per deciliter (µg/dL) could have 0.3 µg/dL of lead in her breast milk.

Under most circumstances, mothers should feel at ease breastfeeding their infant as long as the mother’s blood lead levels are less than 40 µg/dL.² However, if the mother’s blood lead level is between 20 and 39 µg/dL, and if the infant’s blood lead level is 5 µg/dL or higher, then both mother and infant should have their blood lead levels monitored by a physician while taking steps to minimize exposure to lead. If the infant’s blood lead level fails to fall below 5 µg/dL over time, then breast milk as well as environmental sources should be evaluated as possible exposure sources for the infant. It is important to note that it is rare that a mother’s blood lead level is tested. Thus, it is important for parents to consider and discuss with the obstetrician and pediatrician any concerns they have about possible lead exposure to the mother and infant.

References:

  • ¹ Centers for Disease Control and Prevention (CDC). Guidelines for the Identification and Management of Lead Exposure in Pregnant and Lactating Women. 2010.
  • ² American College of Obstetricians and Gynecologist (ACOG) (2012). Committee on Obstetric Practice. Lead Screening during Pregnancy and Lactation. Committee Opinion 533. Obstetrics & Gynecology,120:416–20.

Tags: Lead Exposure, Lead in Drinking Water, Blood Testing, Children, Lead Health Effects

Are there people who are more susceptible to adverse health effects from copper?

Copper is an essential nutrient for all living organisms. However, some people may experience a different or heightened response to copper exposure because of a decreased ability to metabolize or remove copper from the body.¹ This allows copper to build up to toxic levels, particularly in the liver, and cause disease. The best understood reason for increased susceptibility to copper is Wilson disease, caused by a rare gene defect.² Although less understood, individuals with a single copy of the same gene that causes Wilson disease may also be at increased risk.² Moreover, some infants are more susceptible to adverse health effects from copper, possibly due to a genetic defect.1,4

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Copper is an essential nutrient for all living organisms. This means that some copper is needed in order for plants and animals -- including humans -- to grow and function properly. However, too much copper can make a person ill. Drinking water that has too much copper may cause health problems that range from stomach and intestinal disorders such as nausea, stomach cramps, vomiting, and diarrhea to more serious long-term health problems that include anemia, liver disease, and kidney failure.¹

Some people are more susceptible to copper toxicity, such as persons with decreased ability to metabolize or eliminate copper from the body.1,2 In particular, persons with Wilson disease are at high risk for serious health impacts from exposure to copper because they are unable to remove copper effectively from their bodies.² Wilson disease is a rare disease caused by a genetic defect in copper transport. Persons with Wilson disease carry two defective genes for a specific copper transport protein, one from the mother and one from the father. The defect in copper transport means the body is not able to eliminate copper effectively, allowing it to build up to dangerous levels in the liver, brain and other parts of the body. Symptoms of Wilson disease include liver dysfunction with yellowish skin coloring, swelling of legs and abdomen, and a tendency for bruising and prolonged bleeding.³ Other important symptoms include dysfunctions of the nervous system, including psychiatric disorders.³ Although less understood, individuals with a single copy of the same defective gene that causes Wilson disease may also be at increased risk.² People with the genetic defect that causes Wilson disease may have no symptoms or may develop symptoms at different ages and to various degrees, depending on whether the person has inherited the defective gene from one or both parents, how much copper the person has been exposed to, and other less well-defined factors.2,3 The incidence of Wilson disease is estimated to be about 1 in 30,000 worldwide.² It is estimated that about 1% of the U.S. population may carry one defective gene of Wilson disease.2,4

Some infants are more susceptible to adverse health effects from exposure to copper in drinking water.1,4 Primarily, these infants are thought to have increased risk because of a genetic defect in copper metabolism or transport.⊃ Also, infants drink considerably more water than adults relative to their body weight, especially if fed infant formula prepared from powder.4 To reduce the possibility of exposure to copper as well as lead, powdered infant formula should only be prepared using bottled water or filtered water, as described here. In addition, infants take up more copper into their bodies from drinking water compared to adults.4 Finally, infants less than one year of age have a reduced ability to remove copper from their bodies compared with older persons.4

Excess amounts of copper can leach from plumbing materials into drinking water, especially if water corrosiveness is not adequately controlled.5 Corrosiveness and corrosion control are discussed here and here. The U.S. Environmental Protection Agency (EPA) Lead and Copper Rule (LCR) sets the Maximum Contaminant Level Goal (MCLG) and action level for copper at 1.3 milligrams/liter for public water supplies.6 The MCLG is defined as the level at which there is no adverse health effects from copper in drinking water. The action level is the level of copper in water samples that requires water supplies to undertake additional action to protect customers from exposure. If a water supply exceeds the copper action level, they have to take additional steps to improve corrosion control.

To reduce copper exposure, susceptible persons should allow tap water to run 3 to 5 minutes before using for drinking and food preparation if water has not been used in the home for 6 hours. Susceptible persons should avoid using copper cookware and should not store food and beverages in copper containers.

Further information on common symptoms, diagnosis and treatment of Wilson disease can be found at this University of Michigan website: uofmhealth.org/conditions-treatments/digestive-and-liver-health/wilson-wilsons-disease.

A Public Health Statement for Copper from the U.S. Agency for Toxic Substances and Disease Registry (ATSDR) provides a concise summary of copper health risks and can be found at this website: atsdr.cdc.gov/phs/phs.asp?id=204&tid=37.

References:

  • ¹ Agency for Toxic Substances and Disease Registry (ATSDR). 2004. Toxicological Profile for Copper. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service.
  • ² Schilsky, M.L. (2019). Wilson disease: Epidemiology and pathogenesis. In K. M. Robson (Ed.), UpToDate. Retrieved July 23, 2019, from uptodate.com/contents/wilson-disease-epidemiology-and-pathogenesis.
  • ³ Schilsky, M.L. (2018). Wilson disease: Clinical manifestations, diagnosis, and natural history. In K. M. Robson (Ed.), UpToDate. Retrieved July 23, 2019, from uptodate.com/contents/wilson-disease-clinical-manifestations-diagnosis-and-natural-history.
  • 4 Copper in Drinking Water. Risk Characterization. National Research Council (US) Committee on Copper in Drinking Water. Washington (DC): National Academies Press (US); 2000.
  • 5ncbi.nlm.nih.gov/books/NBK225399/. Accessed Nov 13, 2018. Dietrich AM, Glindemann D, Pizarro F, Gidi V, Olivares M, Araya M, Camper A, Duncan S, Dwyer S, Whelton AJ, Younos T, Subramanian S, Burlingame GA, Khiari D, Edwards M. Health and aesthetic impacts of copper corrosion on drinking water. Water Sci Technol. 2004;49(2):55-62.
  • 6 U.S. Environmental Protection Agency (EPA). National Primary Drinking Water Regulations. (2018). epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations. Accessed July 22, 2019. Last updated March 22, 2018.

Tags: Water Sampling, Children, Copper Health Effects, Premise Plumbing, Michigan Lead and Copper Rule, Federal Lead and Copper Rule

What do different levels of lead in drinking water mean?

The U.S. Environmental Protection Agency (EPA) states that the lead action level of 15 parts per billion (ppb), as specified by the U.S. EPA Lead and Copper Rule, is not a measure of public health protection.¹ Look here for more information about the lead action level.

Federal and state regulatory agencies and national organizations have identified goals, recommendations, and action levels for different concentrations of lead in drinking water that are summarized below.

Lead level Source Goal, Recommendation, or Action Level
0 ppb Maximum Contaminant Level Goal in the Federal Lead and Copper Rule¹ The level at which there are no adverse health effects from lead in drinking water
1 ppb American Academy of Pediatrics² Lead in water in schools and child care facilities should not exceed 1 ppb.
5 ppb Food and Drug Administration Bottled Water standard³ Lead in bottled water should be no greater than 5 ppb.
12 ppb Action level in the Michigan LCR starting June 1, 2025&sup4; Corrosion control is not providing sufficient reduction in lead levels
15 ppb Action Level in the Federal Lead and Copper Rule¹ Corrosion control is not providing sufficient reduction in lead levels.

References:


Tags: Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Water Sampling, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

What is a lead service line?

Water service lines are small pipes that connect the water main, typically running under the street, to a water customer’s property as shown in the figure below. Prior to 1950, it was common for service lines to be made from lead pipe. The installation of new lead service lines (LSL) was prohibited in Michigan in 1988. The revised Michigan Lead and Copper Rule (LCR) defines the water service line as the pipe from the discharge of the corporation stop to the first shut-off valve inside the building, or 18 inches inside the building, whichever is shorter.

Under the revised Michigan Lead and Copper Rule (LCR), a “lead service line” (LSL) means a service line which is made of lead, any lead connection or fitting (sometimes called a pigtail or a gooseneck) that is connected to the service line, or both.¹ This means that a “lead service line” (LSL) is a service line that is made entirely of lead, or a service line that is made of more than one material, including lead. Plumbing materials such as the curb stop, connectors, valves, and water meter may also contain some lead as described here.

The Michigan Lead and Copper Rule (LCR) requires water supplies to replace all lead service lines (LSL) and galvanized steel service lines if the galvanized service line is or was connected to lead pipe.


Click to enlarge.

References:


Tags: Lead in Drinking Water, Lead Service Line Replacement, Premise Plumbing, Legal Responsibility, Michigan Lead and Copper Rule, Federal Lead and Copper Rule

What are the sources of lead in drinking water?

Lead is present in common plumbing materials. Any time lead is in contact with drinking water, there is a risk that lead can dissolve into the drinking water.¹

In Michigan, lead in plumbing can be found in:

  • Lead service lines;
  • Lead solder installed prior to 1988 and improperly installed after 1988;
  • Plumbing materials not intended for drinking water use -- lead is not regulated in these materials (e.g., lab faucets, hoses, spigots, some hand washing sinks, certain fittings and fixtures);
  • Pre-1988 drinking water coolers with lead-lined tanks;
  • Plumbing materials marked “lead-free” at a weighted average of up to 8% lead in products sold through January 2014;
  • Plumbing materials marked “lead-free,” which can contain up to 0.25% lead, that were sold starting in January 2014; and
  • Galvanized iron pipe (click here for more information).

Lead is a common metal found throughout the environment. Lead seldom occurs naturally in water supplies like rivers and lakes, and lead is rarely present in water coming from a treatment plant. The Michigan Department of Health and Human Services maintains a list of other sources of lead exposure.²

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Premise Plumbing, Galvanized Pipes

“I don’t know if I have a lead service line.” Are there any characteristics to my home that could indicate that I have a lead service line?

If your house was built before 1988 you may have a lead service line. Check with your water supply to learn when lead service lines were commonly installed. You can also check the material of your service line where it enters your home. There are a variety of resources available to help you identify a lead service line inside your house2,3 including a mobile app you can walk through on your phone.4

Homes may have a partial lead service line or other lead components between the water main and the house that cannot be identified inside the house.

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In 1986, the United States Environmental Protection Agency (USEPA) banned lead-containing pipes and solder from use in household plumbing. This was done through an amendment to the Safe Drinking Water Act (SDWA), which became effective in 1988.¹ Therefore, one characteristic of homes with lead service lines is that the plumbing was installed or last updated prior to 1988.

A service line for a home usually enters a home in the basement, and is commonly located just prior to the shut off valve. The water meter may be in the same location. The picture below depicts a typical configuration for service lines and meters, although the orientation of the pipes may be different depending on the home. The following steps can help a homeowner identify the construction material of the service line:


Photo: Detroit Water and Sewerage Department. Click to enlarge.

  1. Locate where the service line comes into your house near the main shutoff valve. Look for the test area between the wall or the floor and the shutoff valve, shown circled in the picture above. In some locations the service line may not be visible at all.
  2. Does a magnet stick? If yes, the service line is galvanized steel.
  3. Gently scratch the surface of the pipe with a coin. If the pipe is soft and easily scraped, silver, and a magnet doesn’t stick, it is lead. It may have a bulb in the pipe near the shutoff valve.
  4. If it is copper colored and a magnet doesn’t stick, it is copper.
  5. If the pipe is white or grey and the piping is joined with a clamp, screw or glue, it is plastic.

If you find a lead line entering your home, you have a lead service line. If you don’t find lead but you do live in a pre-1988 home, there is still a possibility that you have a lead service line buried between your home and the water main.

Finally, homeowners can call their water utility and inquire about the material of their service line. Many water providers keep records of construction date, material, and other aspects. The initial phase of the new Michigan Lead and Copper Rule also mandates an inventory of service lines, so the utility will be required to notify you if they find or suspect a lead service line at your home.

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Galvanized Pipes, Michigan Lead and Copper Rule, Compliance

How do I know if I have a lead service line? Will my water supplier notify me if I have one?

Water suppliers must notify owners and residents within 30 days if the supply finds that a house is served by a lead service line. Any time a new water account is opened at a building served by a lead service line, the water supply must notify the owner and the occupant that there is a lead service line. Lead service lines are defined here.

The revised Michigan Lead and Copper Rule requires water supplies to create a Distribution System Materials Inventory that identifies the material of all service lines in the distribution system, including the portions on both public and private property. A preliminary inventory is due by January 1, 2020 and a complete inventory is due by January 1, 2025.¹ Water supplies will identify lead service lines and notify residents as they complete their Distribution System Materials Inventories.

You can call your water supply at any time to ask about the material of your service line. You can also check where your service line enters your house as described here.

Show expanded answer

Service lines can consist of many different parts and materials, and your water supply may not know the material of every portion of the service line. A service line may have up to four distinct portions,³ as shown in the figure below.

  1. The section from the water main in the street to the curb stop near the property line is typically considered the “public side” and is typically owned by the city. The corporation stop and the curb stop are both valves that can be used to stop the flow of water.
  2. In some cases there is a small, city-owned “gooseneck” or “pigtail” that bends to connect the service line to the water main.²
  3. The section from the curb stop to the house is typically owned by the homeowner and is called the “private side”. The ownership of service lines may differ from city to city. To determine who owns the service line sections, you may ask your water utility.
  4. The only portion of a service line that can be identified without digging up the pipe is the short piece inside the house that runs to the meter or the main shutoff valve inside the house. The portion inside the house can be a different material than the buried portions of the service line.

Water service line diagram.
Water service line diagram. Click to enlarge.

Your water supply may have limited information on the materials in your service line, but they are required to have a complete Distribution System Materials Inventory by January 1, 2025. The complete inventory will identify the materials on the public and private sides of the service line for all service connections.

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Premise Plumbing

What does the Lead and Copper Rule require my water supplier to do to reduce my exposure to lead in my drinking water?

Under the revised Michigan Lead and Copper Rule, water supplies have several requirements to help reduce exposure to lead in drinking water.¹ Lead compliance sampling identifies whether overall lead levels are changing for a water supply and may trigger the water supplies to take additional action to reduce lead. Other Rule requirements, including corrosion control treatment, notifying consumers of lead service lines, lead service line replacement, and public education and information campaigns all help reduce consumer exposure to lead.

Show expanded answer

Water supplies are required to take the following steps to reduce exposure to lead in drinking water:

Source water and corrosion control treatment at the water plant
Your water supplies is required to use optimized corrosion control treatment (OCCT) if the supplies serves more than 50,000 and/or if the 90th percentile of water samples test above the action level for lead.¹ Supplies may also be required to submit new or updated corrosion control studies when switching to a new source of water.

Identify lead service lines and notify residents
All water supplies are required to submit a complete Distribution System Materials Inventory (DSMI) by January 1st, 2025. This inventory identifies where lead service lines are and can help supplies plan for replacement. Your water supplies is required to notify owners and residents of buildings with lead service lines in writing within 30 days of determining the service line material.

Lead service line replacement
All water supplies must replace all their lead service lines, both the public side and the private side, at an average rate of 5% per year so that all lead service lines are replaced within 20 years. The MDEQ may approve an alternative schedule based on an asset management plan. If the water supply exceeds the lead action level, the water supply is then required to replace lead service lines at 7% per year.

Public Education
Supplies are required to provide a section of the annual consumer confidence report that explains the health risks of lead and copper in drinking water. Supplies that serve more than 50,000 people must establish a community advisory council to improve outreach about lead in drinking water for the community. If the water supplies exceeds the lead action level, the supplies must notify residents and distribute public education materials that inform consumers about the risks of lead in water.

Lead sampling at household taps
Water supplies are required to monitor lead and copper at high risk buildings as described in these FAQS. These samples are used to calculate the 90th percentile of lead results for the water supply as described here. Many water supplies will also collect data for water quality parameters to monitor the effectiveness of corrosion control throughout the distribution system. Lead sampling indicates the effectiveness of corrosion control treatment and whether system-wide lead levels are changing over time.

If the 90th percentile lead level is greater than the lead action level, the water supply is required to 1) collect source water samples and install source water treatment if necessary 2) send public education notices to all customers, 3) optimize corrosion control, and 4) increase the pace of lead service line replacement to 7% per year if appropriate control had already been in place.

References:


Tags: Actions to Reduce Lead Exposure, Lead in Drinking Water, Water Sampling, Lead Service Line Replacement, Legal Responsibility, Corrosion Control, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

Who is responsible for implementing and enforcing the provisions of the revised Michigan Lead and Copper Rule?

The revised Michigan Lead and Copper Rule (LCR) creates more stringent requirements to reduce the risk of exposure to lead and copper in drinking water beyond the requirements of the federal LCR written by the U.S. Environmental Protection Agency (EPA).¹,²,³

Municipalities and water supplies are responsible for implementing the new LCR requirements. The EPA has granted the Michigan Department of Environmental Quality/Department of Environment, Great Lakes, and Energy (MDEQ/EGLE) the authority to enforce the revised LCR.4 The EPA oversees MDEQ/EGLE’s administration and enforcement of the rule.4

Show expanded answer

Under the Michigan Lead and Copper Rule (LCR), each water supply is required to take certain actions based on the type of supply, population served, and water quality. Each water supply must report specific information to the Michigan Department of Environmental Quality/Department of Environment, Great Lakes, and Energy (MDEQ/EGLE) as defined in the LCR. For example, water supplies are required to submit a preliminary Distribution System Materials Inventory by January 1, 2020.¹,²

Some LCR provisions require ongoing interaction between customers, water supplies, and MDEQ/EGLE. Water supplies collect lead and copper samples at customer homes, also referred to as compliance testing, as described here. Water supplies report the sample results to the customers at the sampled homes and to the MDEQ/EGLE to calculate the 90th percentiles of lead and copper results (described here). If a water supply exceeds the lead or copper action level, MDEQ/EGLE informs the water supply and tells them the additional actions they must take to comply with the rules. If the water supply exceeds the lead action level, the water supply prepares public education materials for MDEQ/EGLE to review, and then the water supply delivers the materials to all customers.¹,²

The MDEQ/EGLE must keep compliance testing records for water supplies per the requirements of the Michigan Safe Drinking Water Act. If a water supply fails to comply with the LCR, the MDEQ/EGLE has authority to issue a violation to the water supply.¹,² MDEQ/EGLE must provide quarterly reports to the EPA about new violations and enforcement actions taken. EPA conducts annual reviews of state drinking water programs, including MDEQ/EGLE, and a more thorough review every 6 years.4

EPA has authority to issue emergency orders to protect the public if there is imminent and substantial endangerment to human health due to a water supply and/or MDEQ/EGLE not complying with their requirements.5

References:


Tags: Legal Responsibility, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

What is an asset management program, and how do communities use it to replace lead service lines?

Asset Management for water infrastructure is an organized strategy for

  1. Identifying all infrastructure, or assets, necessary for the water supply to operate including source, treatment, pumping, and distribution system assets (asset inventory),
  2. Evaluating the current condition of the assets (condition assessment)
  3. Identifying expectations for infrastructure reliability and safety (level of service)
  4. Identifying what could go wrong if the asset fails and the likelihood of it failing (level of risk and asset criticality),
  5. Developing a decision making strategy for prioritizing repair and replacement projects to prevent assets from failing or responding quickly when they do fail (optimizing life cycle cost), and
  6. Preparing a prioritized plan for upgrading, replacing, or repairing water supply assets including how to pay for implementing the plan.¹

An asset management plan is the written description that an individual water supply prepares after completing each of the steps listed above.

The Michigan Lead and Copper Rule (LCR) requires community water supplies to use the presence of lead service lines as a factor for prioritizing asset criticality in asset management programs.² This may accelerate water main replacements in areas with many lead service lines because those infrastructure assets present a greater risk and must be addressed before lower risk assets.

The Michigan LCR also provides the opportunity for a water supply to replace their lead service lines on a schedule established by an asset management plan approved by the Michigan Department of Environmental Quality/Department of Environment, Great Lakes, and Energy (MDEQ/EGLE) . This may speed up or slow down lead service line replacement for a given water supply depending on their asset inventory.

Show expanded answer

In Michigan, community water supplies serving more than 1,000 people were required to develop asset management plans by January 1, 2018.³ An asset management plan (AMP) is the written plan that a water supply uses to plan capital improvement projects and maintenance decisions after working through the asset management process. A Capital Improvements Plan is the portion of the asset management plan that details the infrastructure upgrades and repairs that are necessary within the next 5 and 20 years. A key purpose of AMPs is to drive longer term thinking and planning and ensure the organization has the money to pay for the work that must be done.¹

Even though the original water asset management plans were due in January 2018, the June 2018 Michigan Lead and Copper Rule required water supplies to revise their asset management plans. The Michigan Water Asset Management Council is developing guidance to help water supplies continue work on the Asset Management process.4

Service lines are essential assets and should be itemized in AMPs because they are the critical infrastructure that connect water distribution systems to the customers they serve. It is good management practice to keep and maintain records for all service line materials for all service connections in a water supply.

When a water supply uses the presence of lead service lines as a factor for prioritizing asset criticality, water main replacements and other infrastructure work are likely to be scheduled sooner in areas with more lead service lines. Asset management plans will still consider other risk factors for prioritizing infrastructure upgrades, but areas where lead service lines and other critical infrastructure needs overlap will likely be addressed sooner. As described here, the cost of lead service line replacement and other infrastructure upgrades will be lower when infrastructure needs within an area are all addressed at the same time.

Asset management plans are not required to be made publicly available, but you can ask your water supply for a copy. You may be able to find the Capital Improvements Plan on your water supply’s website.

References:


Tags: Lead in Drinking Water, Lead Service Line Replacement, Water Rates, Costs, Michigan Lead and Copper Rule, Compliance

What is corrosion control, and why do we use it for drinking water?

Corrosion in pipes can lead to release of metals, including lead and copper, into water. Corrosion control treatment typically means adding a chemical at the water treatment plant to reduce pipe deterioration. Effective corrosion control limits corrosion in pipes and can reduce lead release into drinking water. However, corrosion control does not eliminate all of the risk of exposure to lead in drinking water.

Show expanded answer

If a pipe contains lead or copper, either in the surface or the buildup on the surface, corrosion can release lead and copper into the water. Water supplies apply corrosion control strategies to reduce corrosion as water travels through the distribution system. As the name implies, corrosion control is the process of changing the nature of the water at the treatment plant to reduce corrosion in the distribution system. This can be done by either adding chemicals to the water (commonly orthophosphate, but several other corrosion inhibitors can be used) or by changing the pH (acidity) or hardness (calcium and magnesium levels) at the drinking water treatment plant.¹ These changes help reduce corrosion of the inside of the pipes due to characteristics of the water.

Some water supplies are required to use corrosion control. For example, a corrosion control study is mandated under the Lead and Copper Rule for systems serving greater than 50,000 people or water supplies that exceed the lead action level. These water supplies are required to determine the level of corrosion control needed to minimize the release of lead into drinking water while maintaining compliance with other drinking water regulations. Additionally, a corrosion control study may be required when a water supply switches source water, changes chemical additives to the water, or experiences fluctuations in drinking water quality.¹ Corrosion can affect different pipe materials differently. Treatment to reduce iron corrosion may not be effective for lead corrosion. The most effective form of corrosion control for a water supply is specific to the source water quality, historic and current water treatment, and distribution system materials.²

While corrosion control can reduce lead in water, corrosion control does not eliminate the risk of exposure to lead in drinking water. Corrosion control is very sensitive to pipe and water quality conditions and may not be as reliable during pipe disturbances, long periods with low water use, and galvanic corrosion conditions.¹ Corrosion control works best when used as part of a larger lead response strategy that includes public education, filter use, and lead removal.

References:

  • ¹ United States Environmental Protection Agency. Optimal Corrosion Control Treatment Evaluation Technical Recommendations for Primacy Agencies and Public Water Systems. EPA 816-B-16-003, 2016, www.epa.gov/sites/production/files/2016-03/documents/occtmarch2016.pdf.
  • ² American Water Works Association Research Foundation. Internal Corrosion of Water Distribution Systems. second ed., 1996.

Tags: Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Water Sampling, Corrosion Control, Federal Lead and Copper Rule

My water supplier asked to collect lead and copper water samples from my home. Should I be concerned about my water because they are asking to test it? What should I do?

If a water supplier asks to collect lead and copper water samples from your home, it means your home has been selected from a “sampling pool” of homes in your service area. This sampling pool gives priority to the highest risk buildings as described here. However, being selected for the sampling pool does not necessarily indicate that there is a known concern about the drinking water in your home.

If your home is selected, you may receive a sample bottle and sampling instructions or a utility employee may ask to make an appointment to collect the samples. Follow the instructions provided by your water supply regarding water use before the samples are collected.

Show expanded answer

The instructions will detail the sampling process to be completed by the utility employee or the resident. These instructions will ask you to stop using water in your house at least 6 hours before sampling. While these instructions may be inconvenient, they are important to ensure the accuracy of the tests. Samples will be collected from a household tap typically used for drinking water, usually the kitchen or the bathroom sink.

If you have a lead service line, it is more likely that a utility employee will collect the samples. They will collect the first liter and the fifth liter out of the tap. The first liter represents water from your household fixtures, and the fifth liter represents water from the lead service line. Only the first liter out of the tap will be collected at homes without lead service lines.

The water samples will be analyzed by a certified laboratory and the results will be delivered to customers whose homes were sampled. The range of sample results will be distributed to the water utility customers in the yearly water quality report.¹

References:


Tags: Lead in Drinking Water, Water Sampling, Michigan Lead and Copper Rule, Compliance

The Lead and Copper Rule (LCR) requires regular lead and copper tap water sampling. How many samples are required and how are sampling sites selected in the Michigan LCR?

The LCR requires water supplies to collect tap water samples to measure effectiveness of corrosion control for reducing lead in water.

Water supplies collect samples based on the size of the population they serve, according to the chart below.¹ Sampling sites must be selected from a sampling pool created by the water supply that meets the criteria defined in the Michigan LCR. These criteria prioritize the highest risk homes in the service area, specifically buildings with lead service lines or lead pipes.

Supply Size (Number of People Served) Number of Sites (Standard Monitoring) Number of Sites (Reduced Monitoring)
More than 100,000 100 50
10,001 to 100,000 60 30
3,301 to 10,000 40 20
501 to 3,300 20 10
101 to 500 10 5
Fewer than 101 5 5

Water supplies must continue sampling the highest risk homes. Homes where lead service lines have been replaced will be removed from the sampling pool until the utility removes all lead service lines and lead pipes.

Show expanded answer

Water supplies that meet the lead and copper action levels for two consecutive 6-month periods, plus additional criteria that depend on the size of the water supply, can use the number of sites in the reduced monitoring column. It is very common for water supplies to take samples at the reduced number of sites. They can also reduce their sampling frequency.

Sampling sites must be selected from a sampling pool created by the water supply. For a home to be initially considered for the sampling pool, it must be selected based on the following criteria (in order of decreasing priority):²

  • Tier 1 sites: Single family homes with lead service lines or lead pipes
  • Tier 2 sites: Multi-family homes or other buildings with lead service lines or lead pipes
  • Tier 3 sites: Homes with copper pipes with lead solder installed before July 1988
  • Sites representative of the water supply system

Thus, the sampling pool is created using the highest risk sites in the water supply system. This ensures that the water supply is monitoring sites with the highest risk of lead exposure. The sampling results allow a water supply to design corrosion control strategies or capital improvement projects that consider the highest risk buildings in the system.

References:


Tags: Lead in Drinking Water, Water Sampling, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

How are lead and copper compliance samples collected under the new Michigan Lead and Copper Rule?

The Lead and Copper Rule (LCR) has specific requirements for how lead and copper water samples are collected.¹ Samples are collected after at least 6 hours of no water use in the building being sampled. Samples are collected from a tap regularly used for drinking water, typically the kitchen or bathroom faucet.

In homes with lead service lines, the first liter and the fifth liter out of the tap will be collected, each in a 1 liter sample bottle. The first liter represents water from household fixtures, and the fifth liter is more likely to represent water from the lead service line. Only the first liter out of the tap will be collected at homes without lead service lines.

Michigan Lead and Copper Rule water compliance sampling protocols.
Michigan Lead and Copper Rule water compliance sampling protocols. Click to enlarge.

Show expanded answer

Water supplies are required to select LCR sample sites as described here. Water supply staff will contact residents at selected sites for permission to sample, and either the resident or water supply staff will collect samples. An overview of this process is described here.

Compliance sample results are used to calculate a water supply’s 90th percentile lead level as described here. For information on how to read individual sample results click here. For information about what the sample results mean about lead exposure risk at an individual home, click here.

References:


Tags: Lead in Drinking Water, Water Sampling, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

When will I receive my Lead and Copper Rule (LCR) compliance sample results for my house? How do I read the results letter?

Results must be delivered to homes that were tested within 30 days of being analyzed by the laboratory. Once samples are collected and preserved, they may not be analyzed immediately so the timing can vary widely. Otherwise, your water supplier will receive results from the lab and distribute them to you. If your home’s result is a number, that number corresponds to the concentration of the listed metal (lead or copper) in your water. If it reads “ND”, “Not Detected”, or “<2 ppb”, it means the concentration was so small that the laboratory equipment could not detect any of the metal.

Show expanded answer

When you get LCR compliance sample results back, they will likely look something like the following form:¹


LCR compliance sample results example. Click to enlarge.

While each water supply is different, the information on this example is required under the LCR so it will appear on results reports from most water supplies. As shown in the table key, “AL” refers to the “Action Level”, the concentration above which a water supply must pursue treatment or other measures to reduce the concentration of the contaminant. “MCLG” (or Maximum Contaminant Level Goal) is the level at which there is no health risk.

Entries in the “Your Result” column could be either numbers, or the letters “ND”, as described earlier. While “ND” does not mean the metal is not present at all, it does mean the metal concentration is small enough that testing equipment is unable to sense it. A water supply will also likely provide the minimum level of detection, below which a result would be “ND”. Sometimes a non-detection is reported in a format such as “<2 ppb.” This means that the instrument cannot accurately detect concentrations below 2 ppb, and the instrument did not detect the metal above that threshold.

These sample results will also include a list of methods to reduce lead in tap water, options for alternative water sources, and contact information for the tester, the water supply, or both. To get individualized answers to questions regarding your specific results sheet, contact your water supply.

Your water supply will report the range of lead and copper results detected in other compliance samples, as well as the 90th percentile of sample results, in your annual water quality report (or Consumer Confidence Report). This report is typically delivered to all customers in May through July of each year.

References:


Tags: Lead in Drinking Water, Water Sampling, Michigan Lead and Copper Rule, Compliance

If Lead and Copper Rule compliance samples were collected in my home, what do my sampling results tell me about lead exposure in my home?

Lead and Copper Rule compliance sample results indicate lead and copper levels in the water at a household tap after 6 or more hours of the water being in contact with lead and copper service lines and/or household plumbing. The purpose of Lead and Copper Rule compliance sampling is to determine if a corrosion control program is effective at reducing lead and copper levels in drinking water throughout a water supply from lead service lines and household plumbing.¹ All sample results are taken together to calculate the 90th percentile lead and copper levels for the entire water supply as explained here. Lead and Copper Rule samples are not designed to measure individual household risks of exposure to lead and copper in drinking water.²

Compliance sampling can reveal high lead levels and confirm lead contamination.³ But when testing shows little or no lead, there could still be a concern about lead in the water when lead is present in the service line or plumbing. Different sampling methods can reveal lead contamination that is not captured by compliance sampling.³ Particles of lead can cause unpredictable lead results in drinking water.4 As a result, compliance sampling can miss high lead levels and offer false assurance, even when sources of lead may be present in your service line or plumbing.

Show expanded answer

Lead sampling can show a wide range of results, especially when particulate lead loosens from plumbing.4 Particulate lead is a form of lead like tiny grains of sand that loosen from the pipes or plumbing and are released into the water. Disturbances, like replacing a water meter, or construction and excavation activities, increase the risk of particulate lead release because the work can shake particulates free from pipes and plumbing.5 Particulate lead is a concern because the lead content can be very high. A lead particulate could end up in a single glass of water, but not in water sampled just before or after.

If a compliance sample result shows detectable lead, it means that there is a source of lead in the plumbing. Try to identify sources of lead in your plumbing (sources of lead in drinking water are listed here) and take action to reduce your risk of exposure as described here. Call your water supply to discuss your sample results.

Even if lead was not detected in your sample, consider taking steps to reduce your risk of exposure to lead in water especially if you know you have a lead service line or there are other sources of lead in your plumbing.

The US EPA states that the lead action level of 15 parts per billion (ppb) is not a measure of public health protection.² Several regulatory agencies and organizations have identified goals, recommendations, and action levels for different concentrations of lead in drinking water in Michigan that are summarized below.

Lead level Source What it means
0 ppb Maximum Contaminant Level Goal in the Federal Lead and Copper Rule6 The level at which there are no adverse health effects from lead in drinking water
1 ppb American Academy of Pediatrics7 Lead in water in schools and child care facilities should not exceed 1 ppb.
5 ppb Food and Drug Administration Bottled Water standard8 Lead in bottled water should be no greater than 5 ppb.
12 ppb Action level in the Michigan LCR starting June 1 20259 Corrosion control is not providing sufficient reduction in lead levels
15 ppb Action Level in the Federal Lead and Copper Rule6 Corrosion control is not providing sufficient reduction in lead levels.

The US EPA states that the lead action level of 15 parts per billion (ppb) is not a measure of public health protection.²

References:

  • ¹ Lead and Copper Monitoring and Reporting Guidance for Public Water Systems. Environmental Protection Agency Office of Water. USEPA, February 2002
  • ² LEAD AND COPPER RULE REVISIONS WHITE PAPER. Environmental Protection Agency Office of Water. USEPA, October 2016
  • ³ Riblet, Cé., Deshommes, E., Laroche, L., Prévost, Michè., “True exposure to lead at the tap: Insights from proportional sampling, regulated sampling and water use monitoring”. Water Research (2019), doi: doi.org/10.1016/j.watres.2019.03.005.
  • 4 Clark, B., Masters, S., and Marc Edwards. “Profile Sampling To Characterize Particulate Lead Risks in Potable Water”. Environmental Science & Technology. 48.12 (2014): 6836-6843, DOI: 10.1021/es501342j
  • 5 Del Toral, M. A., Porter, A., and Michael R. Schock. “Detection and Evaluation of Elevated Lead Release from Service Lines: A Field Study”. Environmental Science & Technology. 47.16 (2013): 9300-9307. DOI: 10.1021/es4003636
  • 6 Federal Lead and Copper Rules, 40 C.F.R. Sec 141
  • 7 “COUNCIL ON ENVIRONMENTAL HEALTH. Prevention of Childhood Lead Toxicity. Pediatrics. 2016;38(1):e20161493.” Pediatrics, American Academy of Pediatrics, 1 Aug. 2017, pediatrics.aappublications.org/content/140/2/e20171490
  • 8 Requirements for Specific Standardized Beverages 21 C.F.R. Sec 165.110
  • 9Michigan Lead and Copper Rule. Michigan Department of Environmental Quality. 2018. dmbinternet.state.mi.us/DMB/ORRDocs/AdminCode/1346_2014-023EQ_AdminCode.pdf

Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Water Sampling, Corrosion Control, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

Once a year, water supplies provide a consumer confidence/water quality report to all customers. What information is in the report and what will I learn about my water supply’s compliance with the Lead and Copper Rule?

The United States Environmental Protection Agency (EPA) requires every community water system to develop and distribute to customers a Consumer Confidence Report (CCR), sometimes known as an annual water quality report.5 It contains information about your water source, detected contaminants, compliance with drinking water regulations, and information about specific contaminants.²

The revised Michigan Lead and Copper Rule (LCR) requires each CCR to include the 90th percentile value of the most recent round of lead and copper rule sampling, the number of sampling sites exceeding the action level, and the range of individual sample results for all monitoring locations.³ The 90th percentile is explained here. Even if a water supply has a 90th percentile under the lead action level, individual homes may still be at risk of elevated lead exposure.

Water suppliers with lead service lines or service lines with unknown material must report the number of lead service lines, the number of service lines of unknown material, and the total number of service lines in their system. Michigan CCRs must now identify lead service lines as a major source of lead in drinking water.

Show expanded answer

Consumer Confidence Reports (CCRs) must be sent by your water supplier each year by July 1.4 People who do not pay their own water bills, such as those who live in apartments or condos or rent houses, may need to contact a building manager for more information regarding their CCR. Also, people who get their water from a private groundwater well do not receive CCRs because private wells are not regulated by EPA. If you don't receive the report, you can either call your local water supplier or you may find your report using EPA's CCR search tool.¹

Information covered in this report includes a brief summary of the risk of contamination of the local drinking water source, the regulated contaminants found in local drinking water, the potential health effects of any contaminant detected in violation of an EPA health standard, and educational information on nitrate, arsenic, or lead in areas where these contaminants may be of concern.4

Michigan CCRs will include additional information related to the new Lead and Copper Rule. There may be additional reporting requirements in other states, but they must also include the basic information in the federal requirements.4

You can learn several things about Lead and Copper Rule compliance from your CCR:

  • The most recent year your water supply collected lead and copper compliance samples
  • The range of lead detected in compliance samples, and the number of samples above the lead action level. It is important to understand that even if a water supply has a 90th percentile under the lead action level, individual homes may still be at risk of elevated lead exposure.
  • The number of lead service lines, service lines with unknown material, and total service lines in the water supply. If you compare these numbers from year to year you will be able to track your water supply’s progress on their lead service line replacement program.

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Water Sampling, Lead Health Effects, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

How are lead compliance sampling results used? What is the 90th percentile and what does it mean?

The purpose of Lead and Copper Rule compliance sampling is to determine if a corrosion control program is effective at reducing lead in drinking water. Sampling site requirements are described here and sampling procedures are described here. The 90th percentile of sampling results is used to determine if corrosion control is performing as expected. The 90th percentile is the concentration for which 90% of collected samples are less than the 90th percentile and 10% are greater than the 90th percentile. For example, if the 90th percentile lead concentration for a community is 6 ppb, that means that 90% of samples from that community have lead concentrations lower than 6 ppb. The other 10% of samples have lead levels over 6 ppb and may be greater than 15 ppb.

The 90th percentile of the sample results must be below the lead action level of 15 ppb, or 12 ppb starting in 2025, for corrosion control to be considered effective. The lead action level is used to represent corrosion control effectiveness, it is not a measure of public health protection.¹ A water supply can have a 90th percentile below the lead action level even when lead measured in individual homes is above the action level.

Show expanded answer

When a water supply has a 90th percentile that is under the lead action level, it does not mean that there is no risk of lead exposure at any home. It means that corrosion control is effective enough in most homes to reduce lead release.

Even when a water supply’s 90th percentile is below the lead action level, consumers should check whether they have lead in their own service line and household plumbing (see here for information on sources of lead in drinking water) so they can reduce their risk of exposure as described here.

The 90th percentile is calculated as follows after lead and copper compliance testing:²

  1. Order all sample results from lowest concentration to highest concentration
  2. Number the samples from 1 (lowest concentration) to n (highest concentration)
  3. Multiply the total number of samples (n) by 0.9
  4. If the result of step 3 is a whole number, the 90th percentile concentration value is the concentration of this sample number. If the result of step 3 is not a whole number, the Michigan Department of Environmental Quality/Environment, Great Lakes, and Energy (MDEQ/EGLE) interpolates to calculate the 90th percentile value.

For a helpful video about how 90th percentiles are calculated more generally, see the video at the following link: youtube.com/watch?v=hREi9sXeBMo

References:


Tags: Lead in Drinking Water, Above Lead Action Level, Water Sampling, Corrosion Control, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

What steps should I take to reduce my risk of exposure to lead in drinking water

There are several steps consumers can take to reduce their risk of exposure to lead in drinking water:

  • Always use cold water for drinking and cooking.
  • Remove and clean the aerators on your faucets monthly.
  • If water has gone unused in the home for six hours or more, run the water for 30 seconds to 2 minutes before drinking. If you have a lead service line, let the water run 3-5 minutes to flush water from both the interior building plumbing and the lead service line.
  • If you have a lead service lines or if there is a pregnant woman or children age 6 and under in your home, consider buying a filter that meets NSF standard 53 for lead removal for drinking and cooking.
  • Always use a filter or bottled water if you are preparing formula for an infant.

The expanded answer provides additional details and strategies.

Show expanded answer

  1. Check whether your home has lead service lines or has any lead solder installed before 1988. Homes with lead service lines have a higher risk of having high lead levels in drinking water. Additionally, lead solder installed before 1988 can have significant lead content. Contact your water utility for more information or click here to learn how to check for a lead service line in your home.
  2. Run your water to flush out lead. The more time water has been sitting in your home’s pipes, the more lead it may contain. If your water has not been used for several hours, run the water before using it for drinking or cooking. This flushes lead-containing water from the pipes.

    • If you do not have a lead service line, run the water for 30 seconds to two minutes, or until it becomes cold or reaches a steady temperature.
    • If you do have a lead service line, run the water for 3 to 5 minutes to flush water from both the interior building plumbing and the lead service line.¹

    Additional flushing may be required for homes that have been vacant or have a longer service line. Your water utility can help you determine if longer flushing times are needed.

  3. Use cold water for drinking and cooking. Do not cook with or drink water from the hot water tap; lead dissolves more easily into hot water.²

  4. Use bottled or filtered water for preparing baby formula. Do not use water from the hot water tap to make baby formula. If you have a lead service line, use bottled water or an NSF-Certified filter that removes lead to prepare baby formula.³

  5. Do not boil water to remove lead. Boiling water will not reduce lead levels.4

  6. Use a filter that removes lead from drinking water. Read packaging to find a filter that meets NSF/ANSI Standard 53 for the reduction of lead (see example below). Be sure to maintain and replace the filter device in accordance with the manufacturer’s instructions to protect water quality. ³

    NSF

  7. Consider purchasing bottled water. The Food and Drug Administration (FDA) regulates bottled water. The bottled water standard for lead is 5 ppb (parts per billion).5

  8. Get your child tested. Contact your local health department or healthcare provider to find out how you can get your child tested for lead if you are concerned about exposure.4

  9. Clean your aerator. The aerator on the end of your faucet is a screen that will catch debris. This debris could include particulate lead. The aerator should be removed at least monthly to rinse out any debris.³

  10. Test your water for lead. Call your water supply to find out how to get your water tested for lead.²

  11. Identify and replace older plumbing fixtures that likely contain lead. Consider replacing any older faucets, fittings, fixtures, and valves that may contribute lead to drinking water. Any new pipes, fittings, and fixtures intended for drinking water use sold starting in 2014 should contain no more than 0.25% lead. Look for materials that are certified to meet NSF/ANSI standard 61. EPA prepared a brochure that explains the various markings that can indicate that materials meet the new “lead free” definition.6

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Premise Plumbing, Michigan Lead and Copper Rule

What alternative sources of water are available if I am concerned about lead in my drinking water?

You may be concerned about lead in your drinking water because of sources of lead in your plumbing, sample results for your home, information from your water supply, or from hearing about lead in the water in other communities. Exposure to lead in drinking water depends on how you use the water. The most important routes of exposure to lead in water are drinking and cooking. Bottled water and filtered water can be used for drinking and cooking to reduce lead exposure from these activities. Point-of-use (POU) filters have been demonstrated to be very effective for reducing lead in drinking water.¹ They can be used for months at a time and produce less waste than bottled water. Look for point-of-use filters that meet NSF/ANSI Standard 53 for the reduction of lead and NSF/ANSI Standard 42 for particulate removal as described here.

Show expanded answer

Bottled water is regulated by the US Food and Drug Administration and must not contain lead concentrations above 5 ppb.² Bottled water can be more reliable than unfiltered tap water for low or not detectable lead levels because bottled water does not sit in contact with leaded plumbing materials for long periods of time.

However, some bottled waters have not been tested and may not be appropriate for consumption.³ Contact independent testing organizations that certify bottled water4,5 or contact the bottled water distributor for more information about lead testing results for a specific bottled water. Treatment and sampling requirements for bottled water are different than for public water supplies regulated under the Safe Drinking Water Act. Because of this, water bottled from a municipal supply may be safer because it is subject to both Food and Drug Administration and Safe Drinking Water Act regulations.

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Lead Health Effects, Premise Plumbing

What is point-of-use (POU) treatment?

A point-of-use (POU) treatment device treats water at the “point” where water is being used. A point-of-use device/system is typically installed at a single water outlet, either under the sink or on the faucet.¹ A pitcher with a filter is also a point-of-use treatment device. This type of treatment is a good option for treating only the water you use for drinking and cooking.² It is important to note that point-of-use treatment will only filter at the actual point-of-use, where the filter is physically located.

Point-of-use treatment is an effective way to treat lead in drinking water when lead is present in service lines and/or plumbing because lead from household plumbing gets trapped in the filter at the point the water is being used.

It is important to select point-of-use devices that are certified to reduce the contaminants you are concerned about as described here.

Show expanded answer

Point-of-use (POU) treatment devices are certified to reduce specific contaminants. For example, there are many filters that meet NSF/ANSI 53 certification for lead reduction but are not certified to reduce copper. To achieve the certified level of lead reduction, it is important to follow the manufacturer’s operating instructions for the point-of-use device.

When a device has an indicator that tells you when to change a filter cartridge, the indicator device typically measures the time the cartridge has been in use or measures the water flow through the device. In most cases, the indicator does not measure when the filter is no longer reducing contaminants from the water.

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Premise Plumbing

What is point-of-entry (POE) treatment?

Point-of-entry (POE) systems, treatment that is installed near the location where the water service line enters a home, can be effective for reducing contaminants from the water entering the home. It will not reduce contaminants that are released from plumbing inside the home. It is not as reliable as point-of-use (POU) devices for lead reduction because there are multiple potential sources of lead in household plumbing, as described here. Lead can dissolve into water passing through household plumbing after it has been treated by a point-of-entry system.¹,²

It is important to select point-of-entry devices that are certified to reduce the contaminants you are concerned about. Certification standards and product markings are described here.

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Premise Plumbing

When should I consider point-of-use (POU) treatment or filtration?

You may want to consider point-of-use (POU) treatment or filtration because of sources of lead in your plumbing, sample results for your home, information from your water supply, or from hearing about lead in the water in other communities. You should use filtered or treated water for drinking, cooking, or preparing formula if you have a lead service line, or if you have a pregnant woman or children under 6 years old in your home.


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Premise Plumbing

How do I use a point-of-use (POU) or point-of-entry (POE) treatment system?

Always follow the manufacturer’s instructions when installing or using any water treatment system. You will need to replace the filter cartridge on a schedule as instructed by the manufacturer.

All tests for drinking water treatment devices are completed using cold water, so you should only use cold water in your treatment device at your home. Most faucet mount filters have a bypass that you can use for washing dishes with hot water. 

When a device has an indicator that tells you when to change a filter cartridge, the indicator device typically measures the time the treatment unit has been in use or measures the water flow through the device. In most cases, the indicator does not measure when the filter is no longer reducing contaminants from the water.

The Michigan Department of Health and Human Services (MDHHS) has made YouTube videos to explain how to install¹ and replace² Brita faucet mount filters.

References:

  • ¹ “Brita Faucet Filter Installation”. YouTube, uploaded by the Michigan Department for Health and Human Services, February 12, 2019, youtube.com/watch?v=fdGjZWAF6RU.
  • ² “How to Replace your Brita Water Filter.” YouTube, uploaded by the Michigan Department of Health and Human Services, November 4, 2015, youtube.com/watch?v=plsOvmH___0

Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Premise Plumbing

How do I know if my point-of-use (POU) or point-of-entry (POE) water treatment device is certified? What does the certification mean?

It is important to select water treatment devices that are certified to reduce the contaminants you are concerned about.¹ The device package should clearly indicate that the treatment device meets at least one drinking water certification standard, and the package should list the contaminants that it is certified to reduce as in the example below. The USEPA has developed a tool to help consumers recognize the markings on certified filter packages.³

Certified filter mark
Certified filter mark. Click to enlarge.

NSF/ANSI 53, NSF/ANSI 58, and NSF/ANSI 42 are the drinking water treatment certification standards you are likely to see. If you are selecting a device to remove lead, the package needs to state that it meets NSF/ANSI 53 or 58 for the reduction of lead.

NSF International (formerly known as the National Sanitation Foundation) is an independent, not-for-profit organization that writes standards, and tests and certifies point of use treatment devices. NSF International uses a consensus-based process to develop national standards which means that regulators (including the U.S. Environmental Protection Agency (USEPA)), consumers, academia, and industry are involved in developing standards. NSF International drinking water certification programs are accredited by American National Standards Institute (ANSI).

Show expanded answer

NSF/ANSI Standard 53 for Drinking Water Treatment Units is the nationally recognized standard for evaluating and certifying drinking water treatment systems for the reduction of contaminants from drinking water. NSF/ANSI Standard 58 is the national recognized standard for Water Treatment Systems that use reverse osmosis technology. Water filters are tested and certified to NSF/ANSI 53 and 58 to ensure they reduce contaminants, including lead, per the requirements of the standards.

The NSF/ANSI standards define specific tests that treatment devices must pass to be certified as effective for reducing an individual contaminant. Filters can be certified to reduce multiple contaminants.

NSF/ANSI 42 is used to evaluate and certify filters that reduce aesthetic impurities such as chlorine and taste/odor. These can be point-of-use or point-of-entry treatment systems. Both NSF/ANSI 42 and 53 cover adsorption and filtration which is a process that occurs when liquid, gas, or dissolved/suspended matter adheres to the surface of, or in the pores of, an adsorbent media. In contrast, NSF/ANSI 58 uses reverse osmosis system that uses reverse pressure to force water through a semi-permeable membrane. Most reverse osmosis systems incorporate one or more additional filters on either side of the membrane.5

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Premise Plumbing

Are point-of-use (POU) and point-of-entry (POE) treatment effective for reducing lead in drinking water?

It is important to select point-of-use (POU) and point-of-entry (POE) water treatment devices that are certified to reduce the contaminants you are concerned about. These devices are certified using the NSF/ANSI certification program as described here.

The NSF/ANSI standards define specific tests that treatment devices must pass to be certified as effective for reducing an individual contaminant. All drinking water treatment devices are tested using cold water. They are not tested for contaminant reduction at higher temperatures that you might use for showers or dishwashing.³ The lead reduction certification test uses water containing 150 parts per billion (ppb) of lead. The treatment device must reduce lead to 10 ppb or less¹ to be certified. A recent peer reviewed study found that certified filters reliably bring lead down to non-detect levels even when lead levels in the tap water are higher than the 150 ppb required in the certification test.4

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Premise Plumbing

Who can help with reducing water lead levels in my house?

You may be concerned about lead in your drinking water because of sources of lead in your plumbing, sample results for your home, information from your water supply, or from hearing about lead in water in other communities. Both the U.S. EPA Lead and Copper Rule and Michigan Lead and Copper Rule (LCR) requires water suppliers to provide at least some assistance with reducing lead levels in individual homes, as described here. Water suppliers are not responsible for plumbing materials inside homes, but they are responsible for providing water that meets corrosion control requirements.

A licensed plumber can help you identify the materials in your home plumbing system, inform you about alternate approved materials, and replace household plumbing with these approved materials. All household drinking water pipes, fittings, and fixtures should use materials intended for drinking water use be certified to meet National Sanitation Foundation / American National Standards Institute, >NSF/ANSI standard 61. NSF/ANSI 61 certification demonstrates that plumbing materials meet the current definition of “lead-free,” which means the materials may contain up to 0.25% lead by weight.

Although there are programs that complete home assessments for lead poisoning hazards, they typically focus on lead paint hazards. An evaluation of plumbing or drinking water risks is not always included. Before using any of these services, you should investigate to make sure that the assessment will include a comprehensive assessment of household plumbing and risk of lead exposure in drinking water, and that their testing methods meet current sampling requirements.

Show expanded answer

Plumbers should always use lead-free solder. It is important to ensure the right solder is used because leaded solder is still available for non-drinking water applications. When selecting a plumber, ask questions about the materials they use, as well as the methods they use to identify plumbing materials with higher lead content in customers’ homes.

Some state and local health departments may conduct assessments of homes where children with elevated blood lead levels have been identified. In Michigan, assessments in homes of Medicaid-enrolled residents may include an inventory of plumbing materials within the home, and collection of water samples using a sequential sampling technique. These assessments can be very useful for identifying risks of lead in drinking water throughout a home. To find out whether such assessments are available in your community, contact your local health department.

You can call your water supplier to ask questions you may have about water treatment, lead service lines (LSLs), sources of lead in household plumbing or advice on how you can reduce exposure to lead in water in your home. As described here, water supplies must take several steps to educate customers about lead in drinking water and reduce exposure to lead in drinking water system-wide.

In addition to these resources, the Michigan Department of Environmental Quality/Department of Environment, Great Lakes, and Energy¹ (MDEQ/EGLE) and the U.S. Environmental Protection Agency² (EPA) maintain websites with information about lead in drinking water.

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Water Sampling, Premise Plumbing, Legal Responsibility, Corrosion Control, Galvanized Pipes, Michigan Lead and Copper Rule, Federal Lead and Copper Rule

I’m a renter and I want to know more about the potential for lead in my water – what should I ask my landlord?

Here is a list of questions you may want to ask your landlord about the potential for lead in your drinking water:

  • Has the water been tested for lead and copper either by the management or by the water supplier? If so can I receive a copy of the results?
  • What year was the building constructed?
    • This will indicate whether your building is likely to have a lead service line as described here.
  • Does the service line connecting the building to the water main contain lead or did it ever contain lead? If part or all of the lead service line was removed, when was this done?
  • Have you identified plumbing materials for drinking water lines within the building? (lead in plumbing materials is described here) If so, is lead solder present? Are there fittings and fixtures purchased before 2014?
  • When were the faucets installed?
  • Does the building have a Point-of-Entry treatment system? If so, does it remove lead? Who maintains it and how frequently is it maintained?
  • Will the management provide point-of-use filters for residents?
  • Where does the service line enter the building? (You can check the service line yourself as described here)

Tags: Actions to Reduce Lead Exposure, Lead in Drinking Water, Water Sampling, Lead Service Line Replacement, Premise Plumbing, Legal Responsibility

What is my water supplier required to do if my home has elevated lead in the water?

If you collected water samples for compliance with the Lead and Copper Rule (LCR) through your water supplier, your water supplier is required to notify you within 30 days of receiving the sample results.¹ This notification they send you will identify strategies for reducing your risk of exposure to lead in drinking water, as described here. Learn about what compliance sample results mean for an individual home here. Because there is no safe level of lead exposure, you may consider any detectable lead in your water to be elevated. You may have lead in your water if you have lead in your service line or plumbing, as described here.

Your water supply is only required to take additional actions to address lead in drinking water if 10%, or more, of samples collected throughout the entire water system during a compliance sampling period are greater than the lead action level, as described here. The lead action level is 15 parts per billion (ppb) and will go down to 12 ppb in 2025. More information about actions required after a lead action level exceedance can be found here.

Show expanded answer

If you collected water samples without going through your water supplier and discovered elevated lead in the water, notify your water supplier. They are not required to take further action, but they may be interested in taking additional samples to confirm your results.

If you have elevated lead results at your home, including levels above the lead action level, there are no requirements for your water supply to identify the source of lead or to prioritize your home for a lead service line replacement. However, your water supply should contact you to collect water samples again during the next compliance sampling period. Depending on your water supply’s sampling schedule they may contact you again in 6 months, 1 year, or 3 years.

References:

  • ¹ Michigan Lead and Copper Rule (2018), Michigan Department of Environmental Quality

Tags: Actions to Reduce Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Water Sampling, Legal Responsibility, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

Why do galvanized service lines need to be removed if they were connected to a lead service line? Is the galvanized plumbing in my house a source of lead in drinking water?

Galvanized Iron Pipes (or GIP) are iron pipes with a thin coating of zinc, and were commonly used in homes built before 1970. When GIP service lines are connected to lead service lines, they can capture lead released from the lead service lines on the inner surface of the GIP. This stored lead can itself be released into the home. Newer GIP can also release trace amounts of lead that is present in the zinc coating. GIP in household plumbing is a larger source of potential lead exposure if the house has or had a lead service line. The risk of lead exposure is smaller but still present if the home never had a lead service line.

Show expanded answer

GIP manufactured before 2014 can have anywhere between 0.5% and 1.4% lead content by weight.¹ The Michigan Plumbing Code states that new GIP for drinking water must be lead-free (less than 0.25% lead by weight). With use over time, the zinc layer can be corroded or worn down, exposing the iron layer underneath to the water. As exposed iron layers corrode in the GIP, lead in the water can attach to the iron walls of the pipe.

GIP can serve as a source for lead contamination in two main ways. First, in newer GIP where the zinc coating is still present, release of lead occurs as the zinc layer dissolves and zinc and lead are released into the water (Figure 1). Second, in GIP that are located downstream from other sources of lead, lead that has attached to the iron walls of the pipe can be released (Figure 2).4 Since the lead content of GIP being used for water delivery is difficult to determine, it is safest to assume that GIP can continue to release lead into the water until the plumbing is replaced.2,3


Figure 1: Release of lead from newer GIP as zinc coating layer dissolves. Click to enlarge.


Figure 2: Release of lead due to captured lead in the iron scale. Click to enlarge.

GIP is a source of lead exposure in homes that have these pipes. Residents can determine if they have GIP and take appropriate action. The original construction date can indicate whether a home may have GIP, as the majority of homes constructed post-1970 will not contain GIP.5 GIP is also easy to identify if exposed, because a magnet will stick to it, unless it is coated by paint or rust. Point-of-use (at the tap) filters can provide temporary protection from lead until GIP are replaced in the home. If GIP are present within a home’s plumbing, the only sure way to eliminate possible lead release from GIP is to replace them with lead-free certified pipes.

References:

  • ¹ Clark, B N., et al. "Lead Release to Drinking Water from Galvanized Steel Pipe Coatings." Environmental Engineering Science, vol. 32, no. 8, 2015, pp. 713-21, doi:10.1089/ees.2015.0073.
  • ² HDR. "An Analysis of the Correlation between Lead Released from Galvanized Iron Piping and the Contents of Lead in Drinking Water." 2009, archive.epa.gov/region03/dclead/web/pdf/galvanized%20project%20report.pdf.
  • ³ McFadden, M, et al. "Contributions to drinking water lead from galvanized iron corrosion scales." Journal - American Water Works Association, vol. 103, no. 4, 2011, pp. 76-89, doi:10.1002/j.1551-8833.2011.tb11437.x.
  • 4 Pieper, K.J., et al. "Flint Water Crisis Caused by Interrupted Corrosion Control: Investigating “Ground Zero” Home." Environmental Science & Technology, vol. 51, no. 4, 2017, pp. 2007-14, doi:10.1021/acs.est.6b04034.
  • 5 Tang, M, et al. "The Relationship Between Discolored Water from Corrosion of Old Iron Pipe and Source Water Conditions." Environmental Engineering Science, vol. 35, no. 9, 2018, pp. 943-52, doi:10.1089/ees.2017.0435.

Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Premise Plumbing, Corrosion Control, Galvanized Pipes, Michigan Lead and Copper Rule, Compliance

What is a partial lead service line replacement? Why are partial lead service line replacements banned in the new Michigan Lead and Copper Rule?

Service lines are small pipes that connect the water main in the street to a water customer’s home. When water supplies disconnect a lead service line while doing maintenance and repair work, they are not allowed to reconnect it to the water main. The lead service line must be removed. Before the new Michigan Lead and Copper Rule (LCR), water supplies have typically replaced only the service line on public property, leaving the lead or galvanized service line in place on private property. This practice is called “Partial lead service line replacement.” Studies show that partial lead service line replacement (PLSLR) releases particulate lead, increases corrosion, and can allow more lead to reach a consumer’s tap. The Michigan LCR has banned PLSLR to prevent the risk of increased lead exposure after PLSLR.

Show expanded answer

Service lines are located in the public right of way starting at the water main in the street until they reach the property boundary. This is where the curb stop and shutoff valve are typically located (see figure). The rest of the service line runs on private property until it enters the customer’s home. In most cities in Michigan, the water supply is responsible for the service line on public property. The property owner is responsible for the section on private property.


Figure. Click to enlarge.

The 1986 Amendments to the Safe Drinking Water Act (P.L. 99-339) banned the installation of lead service lines. When water supplies disconnect a lead service line while doing maintenance and repair work, they are not allowed to reconnect it to the water main. The lead service line must be removed. As a result, most water supplies have been completing partial lead service line replacements.

Partial lead service line replacement increases lead in drinking water over the short term and does not reduce lead over the long term. The 1991 Lead and Copper Rule raised concerns about the practice.¹ Several studies, including a report by the Environmental Protection Agency’s Science Advisory Board, documented an increase in water lead levels after partial replacement². Studies have shown that partial lead service line replacement releases particulate lead3,4,5,6 increases regular corrosion on fresh surfaces3,4 and can create galvanic corrosion7,8,9 the corrosion that occurs when two dissimilar metals come in contact with each other.

The American Water Works Association published a new standard for Replacement and Flushing of Lead Service Lines in 2017 that states “every effort shall be made to avoid partial replacements.”10 The new Michigan Lead and Copper Rule requires water supplies to replace the entire lead service line at one time, except in cases of emergency. This prevents the risks of PLSLR, stops the ongoing lead contamination of household plumbing from lead service lines, and minimizes the cost of lead service line replacement by doing all the work at one time.

References:

  • ¹ United States Environmental Protection Agency. Maximum Contaminant Level Goals and National Primary Drinking Water Regulations for Lead and Copper. Federal Register 56, 26460 ed., 1991.
  • ² United States Environmental Protection Agency. Science Advisory Board Evaluation of the Effectiveness of Partial Lead Service Line Replacements. EPASAB-11-015 ed., 2011, www.epa.gov/sites/production/files/2015-09/documents/sab_evaluation_partial_lead_service_lines_epa-sab-11-015.pdf.
  • ³ Deshommes, E, et al. "Short- and Long-Term Lead Release after Partial Lead Service Line Replacements in a Metropolitan Water Distribution System." Environmental Science & Technology, vol. 51, no. 17, 9 Aug. 2017, pp. 9507-15.
  • 4 Dore, E, et al. "Study of the long-term impacts of treatment on lead release from full and partially replaced harvested lead service lines." Water Research, vol. 149, 25 Nov. 2018, pp. 566-77, doi:10.1016/j.watres.2018.11.037.
  • 5 St. Clair, J, et al. "Long-Term Behavior of Simulated Partial Lead Service Line Replacements." Environmental Engineering Science, vol. 33, no. 1, 2016, pp. 53-64, doi:10.1089/ees.2015.0337.
  • 6 Trueman, B F., et al. "Evaluating the Effects of Full and Partial Lead Service Line Replacement on Lead Levels in Drinking Water." Environmental Science & Technology, vol. 50, no. 14, 2016, pp. 7389-96, doi:10.1021/acs.est.6b01912.
  • 7 Clark, B, et al. "Effect of connection type on galvanic corrosion between lead and copper pipes." Journal AWWA, vol. 105, no. 10, 2013, pp. E576-86, doi:10.5942/jawwa.2013.105.0113.
  • 8 Triantafyllidou, S, and M Edwards. "Galvanic corrosion after simulated small-scale partial lead service line replacements." Journal AWWA, vol. 103, no. 9, 2011, pp. 85-99, doi:10.1002/j.1551-8833.2011.tb11535.x.
  • 9 Welter, Gregory, et al. Galvanic Corrosion Following Partial Lead Service Line Replacement. Water Research Foundation, 2013, www.waterrf.org/PublicReportLibrary/4349.pdf.
  • 10 American Water Works Association. ANSI/AWWA Standard C810-17 Replacement and Flushing of Lead Service Lines. First ed., 2017.

Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Lead Service Line Replacement, Premise Plumbing, Legal Responsibility, Corrosion Control, Michigan Lead and Copper Rule, Compliance

This is called the Lead and Copper Rule. Why are we only talking about lead?

In 1991, the U.S. Environmental Protection Agency (EPA) published a regulation called the Lead and Copper Rule (LCR) that requires water suppliers to control lead and copper in drinking water using corrosion control.¹ Neither lead nor copper are typically found in source waters, but they are both very common service line materials and are also found in household plumbing. Corrosion control, described here, is an effective way to reduce the release of these metals from plumbing materials into drinking water. This is why these two metals were originally grouped together in the regulation. Recent information has indicated that different strategies might be needed to address copper corrosion compared to lead.²

Much of the discussion about the Lead and Copper Rule (LCR) focuses on lead because of lead’s potent toxicity, especially to children. Lead’s health impacts are described further here and here. Due to the significant negative health impacts of lead at very low doses, there is a widespread national focus on addressing lead in drinking water. Whereas lead has no beneficial role in the human body, copper is an essential nutrient and is beneficial at appropriate doses.³ However, exposure to too much copper can adversely impact health, especially in infants or persons with Wilson’s disease. More information on increased susceptibility to copper toxicity and Wilson’s disease can be found here.

Some groups have recognized that in addition to fixing weaknesses in the Lead and Copper Rule (LCR) to reduce lead exposure, there is also a need to address copper corrosion directly.4

References:


Tags: Lead Exposure, Lead in Drinking Water, Lead Health Effects, Michigan Lead and Copper Rule, Federal Lead and Copper Rule

After all lead service lines are replaced, will my community still treat drinking water with corrosion control?

The Lead and Copper Rule (LCR) includes corrosion control treatment requirements for water suppliers that depend on the size of the water supply and lead sampling results. All community water suppliers serving more than 50,000 people are required to use corrosion control as defined in the LCR.¹ If these large water suppliers have very low lead and copper levels, they are considered to have “Optimized Corrosion Control” and do not require additional treatment. Small and medium water suppliers, those that serve 50,000 or fewer people, are considered to have optimized corrosion control treatment if they comply with the lead and copper action levels. If their 90th percentile lead or copper results (explained here) exceed an action level (see here), they have to evaluate and use corrosion control treatment.

These corrosion control requirements will still apply when all lead service lines (LSL) are removed, so many water suppliers will continue to treat drinking water with corrosion control. This is because smaller sources of lead will remain in household plumbing after lead service lines (LSLs) are replaced (described here), and most newer homes use copper plumbing. After a major change in distribution system materials, water suppliers may want to study corrosion control treatment options that are more appropriate for the new materials.

Show expanded answer

The presence of lead service lines (LSLs) is not the only reason for a water supplier to use corrosion control treatment. Other reasons that a water supplier may wish to use corrosion control treatment are described here. If you are interested in more specific information about corrosion control treatment utilized in your community, call your water supplier.

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Above Lead Action Level, Water Sampling, Premise Plumbing, Corrosion Control, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

How is my municipality prioritizing whose lead service lines are being replaced first?

The Michigan Lead and Copper Rule (LCR) requires water suppliers to replace lead service lines (LSLs) at a rate of 5-7% per year,1,2 but it does not mandate the order in which the LSLs are replaced. The Michigan LCR requires community water supplies to consider LSLs as they develop their asset management plans as described here. This can prioritize LSL replacement in areas with many LSLs or areas that face multiple health risks that need to be resolved through infrastructure improvements.

Water supplies have flexibility to prioritize LSL replacement to best meet their community’s needs. Water supplies can choose to prioritize replacement based on high lead sample results, or in areas with large at-risk populations such as children, schools and in-home child care centers. In some cases water supplies may be able to meet their LSL replacement requirements by coordinating with planned capital improvement projects and addressing maintenance and repair needs.

To find out how your water supply prioritizes LSL replacement, call your local water supply and ask them to provide their plan for replacing LSLs.

Show expanded answer

Water supplies may use several criteria to determine the priority of replacement of their LSLs. The American Water Works Association has suggested the following items to consider when prioritizing LSL replacement:

  • Any LSL that is physically disturbed by nearby construction activity.
  • Existing partial LSL replacements.
  • LSLs supplying schools, day care centers, or other at-risk populations.
  • LSLs where sample results are more than established health levels.
  • LSLs located in or near other scheduled underground infrastructure work.
  • Multiple LSLs within a neighborhood.
  • Length of lead pipe present in a given service line.
  • Presence of lead goosenecks and galvanized service lines.

Replacing all of the LSLs in a community may take considerable time to complete. Your water supply may be willing to allow individual homeowners to contract for the replacement of their service line in advance of when the water supply has planned for the replacement if the homeowner is willing to incur the expense. If your replacement is scheduled in the future you should consider using a NSF/ANSI certified filter for your drinking and cooking water until the LSL is removed.

References:


Tags: Actions to Reduce Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Funding Sources, Costs, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

Why is it important to get my entire lead service line replaced?

A lead service line (LSL) is a lead pipe that delivers water from the water main in the street to a water customer’s home. Lead service line (LSL) replacement has several health, maintenance, and financial benefits. The health benefits of lead service line (LSL) replacement are discussed further here.

Any time lead is in contact with drinking water, it can dissolve or flake off into the water, even when a water supply uses corrosion control treatment as described here. Lead released from a lead service line (LSL) can deposit and accumulate in household plumbing as described here. Lead release in drinking water is unpredictable, which means lead sampling can reveal a wide range of results, especially when particulate lead loosens from plumbing.¹ You cannot see, smell, or taste lead in drinking water. This means that consumers cannot distinguish a lead free glass of water from a glass of water containing lead.

Full (or complete) lead service line (LSL) replacement reduces the risk of lead exposure by removing the largest source of lead affecting drinking water in homes and buildings. Once a lead service line (LSL) is removed, no new lead will be added to household plumbing from the service line. There may still be sources of lead in household plumbing but the largest risk of lead release

Show expanded answer

People who live in homes with lead service lines (LSL) should take precautions to limit their exposure to lead in drinking water as described here and here. Learn about what will happen at your house during a lead service line (LSL) replacement here.

It is important to get all parts of the lead service line (LSL) replaced at the same time because replacing only one portion at a time can increase the risk of exposure to lead in drinking water as described here. Because of this, partial lead service line (LSL) replacements are not allowed under the revised Michigan Lead and Copper Rule (LCR), except for emergency repairs.

While there will still be sources of lead in household plumbing after the lead service line (LSL) is removed, the risk of lead exposure will be greatly reduced.

Lead service lines (LSL) can diminish the value of the home due to the risk of lead exposure, so replacing them can enhance a home’s value. Health effects and related health care and educational costs due to lead exposure can be limited if lead exposure is reduced as a result of lead service line (LSL) removal.

Old and deteriorated service lines are more likely to require emergency repairs due to wear, which can be costly and result in lead exposure. Deteriorating service lines may require more frequent maintenance. A new service line will likely require fewer repairs and related disruptions.

References:

  • ¹ Clark, B., Masters, S., and Marc Edwards. “Profile Sampling To Characterize Particulate Lead Risks in Potable Water”. Environmental Science & Technology. 48.12 (2014): 6836-6843, DOI: 10.1021/es501342j

Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Premise Plumbing, Legal Responsibility, Michigan Lead and Copper Rule, Federal Lead and Copper Rule

What will happen at my house when my lead service line is replaced?

Every water supply will have its own process for identifying and replacing lead service lines (LSLs, also see here), but most programs will include the same basic steps. These include confirming the location of the lead service line (LSL), getting a signed agreement to complete the work if necessary, inspecting where the water service enters the house, completing the service line replacement, and providing instructions about proper flushing of the home’s plumbing after the work is finished. These steps are described below in greater detail in the expanded answer.

Contact your water supplier for specific information on how they are running their lead service line (LSL) replacement program.

Show expanded answer

The lead service line (LSL) replacement process typically starts when your water supplier contacts you to let you know that you have a lead service line (LSL) that needs to be replaced, or that they want to inspect your service line and replace it if they find it is made of lead. The following list describes the most common steps of this process and details you should know as your lead service line (LSL) is being replaced. Your water supplier may take these steps in a different order or have different variations on these steps.

  1. Your water supplier should contact you about replacing your lead or galvanized steel service line at least 45 days before they intend to do the work, unless the work is needed due to an emergency.¹
  2. An employee or contractor may excavate around the curb stop in your yard to confirm which portions of the service line are made of lead and/or galvanized steel. Anytime excavation work is completed at your home, the workers should turn off the water to the house so that water cannot carry lead particles into household plumbing while the work is being done.
  3. You may be asked to sign an agreement giving the water supplier permission to access your property and replace the service line to your home. If the water supplier is asking your permission to replace the line, the Michigan Lead and Copper Rule (LCR) requires the water supplier to cover this expense.
    1. The agreement should not require you to pay any money for the replacement.
    2. The agreement should clearly state that the entire lead service line (LSL), and any galvanized steel portion of the service line that is or was connected to lead, will be replaced from the water main to the inside of your house.
    3. The agreement should state that the party performing the work has insurance in the event any damage is caused during the work.
    4. The agreement should state how your property is to be restored after the work is complete.
    5. The agreement may say that you are responsible for maintaining the private side of the service line after the replacement is complete.


    Click to enlarge.

  4. The homeowner or a responsible adult should be home during the replacement work, and most utilities will not turn the water back on after the replacement unless there is an adult at home to verify there are no running faucets that could cause flooding in the home.
  5. The water supplier, or a contractor, will inspect the location where your water service line enters your house. You should make this area inside your house accessible and safe for them to work in before they enter your home. The workers may take pictures before the work is started to document the work area. You may also want to take your own pictures before they start work so you can demonstrate whether the property has been restored to its previous condition after the work is complete.
  6. There are three common strategies for lead service line (LSL) replacement.
    1. The first, open trench replacement, is where the entire length of the existing water service is excavated, the lead pipe is disconnected, and a new water service pipe is laid in the open trench.²
    2. The second strategy uses the existing service line to pull a new service pipe through the yard.² This method minimizes digging on the property. The water supplier or contractor will disconnect the pipe inside the home, excavate a portion of the lead service line (LSL), and feed a cable through the pipe and into the house. They will bring a coil of new pipe into the home and connect it to the cable so that the lead pipe can be pulled out from the access hole in the yard and the new pipe will be pulled into place. A video of this process can be found here
    3. The third strategy typically leaves the old lead pipe in the ground and a new pipe is installed along a different route using a drill to bore the path of the new service line underground.² This method requires access holes to be excavated at the water main, the curb stop, and potentially at the building. This replacement strategy does not require an open trench, but it may require a new hole in the basement wall or floor for the new service line to pass through.
  7. Depending on the configuration of the current water service and the construction of the house, the new pipe will go through the basement or crawlspace wall or floor. Per the Michigan Lead and Copper Rule (LCR), the service line will be replaced to the shutoff valve or 18 inches inside the home, whichever is shorter. Your new service line will be made of a material that meets the current standard for drinking water pipes, typically copper or plastic. Your water supply determines what materials will be used.
  8. The new service line will be connected to the water main and the water meter or household plumbing. For typical service line replacements the water will be restored in the home within 4-8 hours. The water supplier may replace the water meter and meter setting while they are doing the work, and they may do a cross connection inspection while they are in your home.
  9. The water supplier may assist with flushing inside your home after the lead service line (LSL) replacement. If they do not assist with flushing, they should provide you instructions for flushing your household plumbing after the work is complete. You should complete the recommended flushing steps when they turn the water back on, before water is used in the house for any other purposes.
  10. Lead service line (LSL) replacement can disturb the plumbing in your home and may result in short term increases in lead release in your water. Consider using a point-of-use filter that meets NSF/ANSI standards for lead reduction for up to 6 months following the lead service line (LSL) replacement, as described here. Some water suppliers are providing filters at all homes where lead service line (LSL) replacements are happening.
  11. The water supplier or contractor will restore your property. The details of restoration are typically covered in the agreement you may have signed at the beginning of this process (step 3 above). At a minimum, the water supplier or contractor should properly grade your property and apply grass seed after the work is complete.

When the work is complete your water supplier should update their records to reflect the new service line material at your home. In Michigan, your water supplier will update the total number of lead service lines (LSL) in your water system in the annual water quality report. The numbers published in the next water quality report should reflect the lead service line (LSL) replacement at your home.

References:


Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Premise Plumbing, Michigan Lead and Copper Rule, Federal Lead and Copper Rule

How are water utilities (and water main replacements) typically funded?

A water utility is primarily funded by the rates paid by the water customers connected to that system. Ratepayer funds are used for ongoing operations of the utility as well as longer-term projects like water main replacements. Grants or low interest loans are also available to some communities. For example, communities may apply for the US EPA’s Drinking Water State Revolving Fund;¹ USDA’s Water and Environmental Programs for small rural systems;² and HUD’s Community Development Block Grant Program.³

References:


Tags: Water Rates, Funding Sources, Costs

 

How much will lead service line replacement cost?

The cost to replace a lead service line (LSL) depends on whether the line is being replaced in coordination with water main or road resurfacing projects. When coordinated, the costs can be as low as $1,000 - $3,600 per line. If replaced outside of the context of other projects, costs range from $6,500 - $8,000 per LSL or more.

Show expanded answer

Several factors affect the cost of a lead service line (LSL) replacement. For instance, it is much easier and cheaper to replace a LSL in coordination with other water, sewer, or road projects; that way, the street and sidewalk only need to be dug-up and repaved once.

The cost per replacement is also smaller when an entire block or neighborhood has their LSLs replaced at the same time. Equipment only needs to be moved to the work site once and multiple replacements can be completed each day. The work is less efficient and costs more when crews replace one line at a time in different locations throughout a water system.

The location of the service line on the property can also have an impact on replacement cost. For example, it costs more to replace a LSL for a house on a slab, or if the service line runs underneath the house or a porch. Costs may also be affected by fluctuations or regional variation in the cost of labor and material prices, and whether the work is completed by water supply personnel or by contractors.

In cases where LSLs are replaced outside of the context of other water main or road resurfacing projects, costs can be as high as $6,500 - $8,000 per LSL (Lansing),¹ or even more depending on the circumstances.

In cases where LSLs are replaced in coordination with water main or road resurfacing projects, it can cost as little as $1,000 - $4,000 to replace the entire LSL (i.e, both public and private portion). Examples include: City of Eau Claire (Avg. $2,000),² Lansing ($3,600),³ Grand Rapids ($1,000 - $4,000).4,5

References:


Tags: Actions to Reduce Lead Exposure, Lead Service Line Replacement, Costs, Galvanized Pipes, Michigan Lead and Copper Rule

How will the new Rule impact my water rates?

How the new rule will impact your water rates will depend on a number of factors. Most importantly: how many lead service lines there are in your community and how your utility decides to fund their replacement.

Water utilities get most of their revenue from ratepayers and this revenue is used for system maintenance, repairs, and upgrades. Many water utilities have been planning to replace some lead service lines each year, even under the old Lead and Copper Rule. So in communities with relatively few lead service lines remaining, the new Rule will likely have limited impact on water rates. (That does not mean, though, that water rates will not change in these communities. There may be other operations or maintenance needs that require rates to increase. Also, rates do typically go up over time to keep pace--at the very least--with inflation.)

In communities with many lead service lines, the costs to replace those service lines might exceed what was originally budgeted. In this case, water utilities may need to revisit their budgets and water rates. To minimize the impact on water rates, a water utility may need to seek out additional funding or financing sources as described here. These include federal, state, and local sources of funding.

It should be noted that water rates are established by the water utility, and how the costs are spread among ratepayers is a function of how the utility designs its rates. If you have questions about how the rate is set in your community, you should contact your water utility.


Tags: Water Rates, Costs

Is state or federal funding or financing going to be available?

As of May 2019, no new funding or finance sources have been made available at either the state or federal level for the purpose of compliance with the new Lead and Copper Rule. It is unclear whether such funding will be made available in the future.

However, on-going funding programs and strategies available through MDEQ have been revised to help municipalities with additional costs associated with the new rule.

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Recently, MDEQ provided $9.5 million in pilot grants to 18 communities to develop asset management plans, service line inventories, and implement full lead service line replacement.¹ These are all activities that are required or encouraged in the Michigan Lead and Copper Rule. The lessons learned from these pilots may be used to justify future grant or loan programs.

Utilities often use the Drinking Water Revolving Fund (DWRF) to help reduce the cost of infrastructure projects. MDEQ has determined that the replacement of service lines on public and private property is a DWRF eligible expense as long as the replacement reduces the public health risk.² As of September 2018, MDEQ issued a second call for projects because there were more funds available than the demand at that time.³

Call Karol Patton, pattonk@michigan.gov, 517-284-5433 for the most up to date information regarding the Michigan DWRF.

References:


Tags: Lead Service Line Replacement, Water Rates, Funding Sources, Costs, Michigan Lead and Copper Rule

Which other states are fully replacing lead service lines, and how are they funding it?

Michigan is currently the only state that requires full replacement of all lead service lines within a set time period. However, many other states, local governments, and water suppliers have taken actions to make lead service line replacement a priority. Some states, such as Wisconsin, have created grant programs to reimburse homeowners for the cost of replacement. Other states, including Wisconsin, Indiana, New Jersey, and Virgina, have used state programs to leverage federal dollars, allowing them to provide low-rate or 0% loans (and in some cases grants) to communities for lead service line replacement. Other states have authorized local water suppliers to build lead service line replacement costs into the water rates they charge utility customers.

The funding that is available to homeowners in Michigan is described here. Funding for municipalities is described here.

A series of three reports provides more detailed analysis of funding options that might be applicable to water utilities in Michigan.


Tags: Actions to Reduce Lead Exposure, Lead Service Line Replacement, Funding Sources, Costs

Would water supplies be replacing lead service lines without the new Michigan Lead and Copper Rule? How much of the estimated lead service line replacement cost is due to the new requirements?

As described here, many water supplies replace lead service lines (LSLs) on a daily basis as part of operations and maintenance and capital improvement projects. These LSL replacements would have continued regardless of whether the Michigan Lead and Copper Rule (LCR) had been revised.

There are two important differences in LSL replacement plans now that the new rule is in place:

  1. Prior to the revision, many water supplies were only doing partial LSL replacements, and these are now forbidden except in emergency situations. So these supplies must now pay to replace the entire line, as described here, rather than only the portion of the line on public property.
  2. Some water supplies (including Grand Rapids¹ and Kalamazoo²) committed to full LSL replacement even before the new LCR became effective. However, most were not planning on replacing all LSLs in the next 20 years as required in the new Rule. So the new Rule will speed up LSL replacement.

Under the new Michigan LCR it will be more expensive for water supplies to pay to replace the full service line compared to just the portion on public property as many were previously doing, since there are more material and labor costs. However, replacing the whole line at once is more cost effective and protective of public health than replacing the public and private portions at different times, as often occurred in the past.

LSL replacement costs vary based on a number of factors, as described here. The American Water Works Association currently estimates that there are 460,000 LSLs in Michigan.³ A group of water supplies estimates that it would cost approximately $2.5 billion in total to replace all the lead service lines in Michigan.4 Because water supplies would have continued replacing LSLs even if the Michigan LCR had not been adopted, not all of the estimated $2.5 billion cost of LSL replacement is attributable to the revised Rule.

References:


Tags: Lead Service Line Replacement, Costs, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

Who pays to replace lead service lines that run under private property?

The revised Michigan Lead and Copper Rule requires water supplies to replace the entire service line, including the portion that runs under private property, at the water supply’s expense. The rationale for this requirement is discussed here.

Some argue that this requirement conflicts with Michigan’s Constitution which states that public funds may only be used for “public purposes.”¹ Some consider replacing the private portion of lead service lines as a benefit primarily to that property, not the public. Others note that “public purpose” in some contexts has been broadly interpreted by regulators and the courts,² who may determine replacing the private portion of lead service lines is a public purpose. A lawsuit that included this issue³ was filed in late 2018. The outcome may help to clarify this issue.

In a few communities (including Lansing), water supplies own the entire service line, even the portion that runs under private property. In these cases, the question about responsibility for replacement does not apply.

References:


Tags: Lead Service Line Replacement, Water Rates, Funding Sources, Legal Responsibility, Michigan Lead and Copper Rule

Why does the new Michigan Lead and Copper Rule require water supplies to replace the entire lead service line at the water supply’s expense?

While replacing the entire lead service line (LSL) reduces a household’s risk of exposure to lead in drinking water, research has found that replacing only a portion of a LSL can actually increase the risk of exposure.¹ Not all households can afford to replace the portion of the LSL that runs under their private property. Therefore, the Michigan Lead and Copper Rule requires public water supplies to replace the entire lead service line at its expense to ensure that all residents in Michigan, regardless of income, receive equitable benefits from LSL replacement.

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This question arises because in most communities property owners are considered responsible for the portion of the service line that runs under private property.

Water service line diagram.
Water service line diagram. Click to enlarge.

In the past, water supplies commonly replaced only the public portion of a lead service line (LSL) (i.e., a partial replacement), or would offer to replace the entire line if the property owner paid for replacement of the private portion. As discussed here, research has found that partial LSL replacements can increase the risk of exposure to lead in drinking water.¹ Therefore, the revised Michigan Lead and Copper Rule (LCR) bans partial replacements and requires water supplies to replace the entire service line.

If the LCR allowed or required water supplies to charge property owners for the cost of private side LSL replacement, those who cannot afford to pay would either receive emergency partial LSL replacements, or risk having their water shut off due to non-compliance. These scenarios put these families at risk for either increased lead exposure or a variety of public health risks due to lack of running water. Requiring water supplies to bear the entire expense prevents this disparity by spreading the costs of LSL replacement over all ratepayers.

References:


Tags: Actions to Reduce Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Legal Responsibility, Costs, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

How was replacement of lead service lines handled prior to the revision of the Michigan Lead and Copper Rule?

Since 1986,¹ water suppliers have not been allowed to connect--or reconnect--lead service lines (LSLs) to the water main. As a result, water suppliers have been replacing lead service lines (LSLs) whenever they encounter them through their normal maintenance and capital improvement projects One of the changes in the new rule is that water suppliers now have to replace all LSLs by a set deadline, as described here, not just as they see them in the course of their normal work.

other change involves how much of the LSL water suppliers must replace. Prior to the revision of the Michigan Lead and Copper Rule (LCR), many water suppliers only replaced the portion of the LSL that runs under public property. As described here, this practice is called a partial lead service line (LSL) replacement, and can increase a household’s exposure to lead. The revised Michigan LCR now bans partial LSL replacements, except in emergency situations, and requires water suppliers to pay for replacing the whole line (noted here).

Show expanded answer

When partial LSL replacements were conducted in the past, the water supply would only replace the service line from the main to the curb stop valve which is typically located at the edge of the right-of-way or the property line. The customer may or may not have been notified that the remaining portion, often owned by the customer, also contained lead or was galvanized iron pipe that could harbor lead leached off the lead upstream in the service. This may have placed the property owners at risk of elevated lead exposure.

These partial LSL replacements were done because in most communities in Michigan, it was assumed that property owners owned the portion of the service line that runs through their property, and that the water utility owned the rest of the line (see figure). That assumption may not be entirely accurate as Michigan courts have used a multi-factor test to determine whether a utility owns the infrastructure that runs under private property, and ownership of private side service lines has not been tested in Michigan courts.² This question of split ownership isn’t unique to Michigan. It happens all over the United States, and often complicates what sources of money can be used to pay to replace the full service line.³ The case studies we developed about financing LSL replacement address this.

In a few communities, water supplies own the entire service line all the way from the main to inside the house. In these cases, the entire water service line would likely have been replaced, even under the old rules.

Property owners should consult with their local water supply as to what portion of the water service is owned by the supply and what portion is owned by them. In many cases this is detailed in either the water service agreement or the water system’s rules and regulations for water service.

References:

  • ¹ Memo: Updated Guidance on Emergency Authority under Section 1431 of the Safe Drinking Water Act. USEPA Office of Enforcement and Compliance Assurance. USEPA. May 30, 2018
  • ² See, Continental Cablevision of Michigan, Inc. v. City of Roseville, 430 Mich. 727 (1992); Michigan Consolidated Gas Company v. Michigan State Tax Commission, 4 Mich. App. 33 (2006); Toll Northville, Ltd. v. Northville Township, 272 Mich. App. 352 (2008), vacated in part by Toll Northville, Ltd. v. Township of Northville, 480 Mich. 6 (2016).
  • ³ “Legal Factors.” Legal Factors, LSLR Collaborative, lslr-collaborative.org/legal-factors.html.

Tags: Actions to Reduce Lead Exposure, Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Premise Plumbing, Legal Responsibility, Costs, Galvanized Pipes, Michigan Lead and Copper Rule, Federal Lead and Copper Rule

Can funds from the federal and state programs that allow for whole-house lead remediation be used to fund replacing the private portion of the lead service line?

The federal Department of Housing and Urban Development (HUD) runs two grant programs for remediating lead paint in homes.¹ At this time, neither of these programs includes replacement of lead service lines or plumbing.

In Michigan, some assistance has been made available. In October 2018, the Michigan Department of Health and Human Services (MDHHS) issued about $7 million in grants to local governments and organizations to help remediate lead in the homes of Medicaid-enrolled residents.² Grant funds may be used for lead service line replacement for homes where water lead levels are at least 15 parts per billion (ppb). More information on concentrations of lead in drinking water can be found here.

While current funding is not sufficient to replace lead service lines on a statewide scale, the State may choose to expand grant programs in the future. Check for current funding opportunities with the State of Michigan.

References:


Tags: Actions to Reduce Lead Exposure, Lead in Drinking Water, Lead Service Line Replacement, Funding Sources, Costs

If I live in a rented house or in a rental unit that is not considered a public water supply, what is my landlord’s responsibility if elevated lead levels are found in my water?

Michigan’s law is unclear about what responsibilities a landlord has when elevated lead is found in the water of a rental unit. The Michigan Lead and Copper Rule does not require landlords to take any action even if sampling results show lead concentrations above the action level, and landlords may even be able to refuse to allow their water supplies to replace the lead service line (if one is present). It is possible that basic landlord-tenant law applies to situations involving lead in water, but because the law is not clear, concerned tenants are encouraged to seek the advice of an attorney.

Show expanded answer

Generally, the law does not require much of landlords when it comes to lead and drinking water. For example, the Residential Lead-Based Paint Hazard Reduction Act of 1992 says that landlords must disclose lead paint hazards to interested renters.¹ However, there is no similar requirement to disclose the presence of lead service lines and plumbing to interested renters.² The Michigan Lead and Copper Rule (LCR) requires water supplies to disclose lead service lines to owners and occupants (e.g., existing tenants). The LCR also requires water supplies to deliver a copy of any tap water monitoring results to the occupants of the sites that are tested. There is no requirement, though, that landlords must pass this information on to future renters.

Furthermore, Michigan’s LCR requires water supplies to offer to replace lead service lines at their own cost. Yet landlords can still refuse replacement without tenants having a say.³

When a tenant finds elevated levels of lead in their water, Michigan’s drinking water laws do not require landlords to do anything in response. That doesn’t mean, however, that tenants have no rights. Basic landlord-tenant law may come into play.4

Landlords must ensure that their building is “fit for the use intended.”5 Landlords must also keep the property in “reasonable repair.”6 A tenant likely intends to use the apartment as a safe living space where he or she has access to clean drinking water. Therefore, a tenant may be able to argue that an apartment with high lead levels in the water is not fit for the intended use. Further, when the building’s lead service lines or lead plumbing contribute to the high lead levels, the “reasonable repair” requirement comes into play. Here, a tenant could argue that it is the landlord’s responsibility to replace the lines or plumbing.

Landlord-tenant law also says landlords cannot punish tenants who complain about living conditions by evicting them.7 Therefore a landlord cannot evict a tenant for expressing concern (to the landlord or to others such as the local water supplies) about elevated lead levels. If a tenant thinks they were evicted due to a lead complaint, legal resources may be available to fight the eviction and secure safe housing.8

Not all landlords will voluntarily address a tenant’s complaint about lead in the water. For landlord-tenant law to work, a tenant would have to sue the landlord. Michigan courts have not yet applied landlord-tenant law to situations that involve lead in water. This is why a landlord’s responsibilities under the laws are unclear. Where possible, tenants should seek the advice of an attorney.8

References:

  • ¹ 42 USC § 4852d (part of the Residential Lead-Based Paint Hazard Reduction Act of 1992); 24 CFR Part 35.
  • ² Cincinnati is the rare city that requires disclosure of lead service lines. Ordinance No. 185 of 2017, §6.
  • ³ Michigan Administrative Code, Rule 325.10604f(5)(c)
  • 4 There may be two types of claims: statutory law (see MCL 554.139) and common law (See, Secunda v. Gregory, 2019 Mich. App. LEXIS 312(2019). The claims are similar, but In a common law claim, the plaintiff would have to prove (among other things) that the landlord failed to provide reasonable care to protect the tenant from an unreasonable risk of harm caused by a dangerous condition. Common law claims also don't extend to open and obvious dangers while a statutory claim does.
  • 5 MCL 554.139.
  • 6 MCL 300.5720.
  • 7 Michigan Legislature. "A Practical Guide for Tenants and Landlords." , michigan.gov/documents/Landlord__Tenant_Guide_10-2005_142052_7.pdf
  • 8Legal & Law Related Programs by County, State Bar of Michigan, michbar.org/public_resources/legalaid.

Tags: Actions to Reduce Lead Exposure, Lead in Drinking Water, Water Sampling, Lead Service Line Replacement, Premise Plumbing, Legal Responsibility, Michigan Lead and Copper Rule, Federal Lead and Copper Rule, Compliance

Is there any requirement to disclose known lead service lines at transfer of property? Whose responsibility?

When a property is sold, Michigan requires sellers to disclose what type of material is used in the building’s plumbing system, but does not specifically call out lead service lines (LSLs) as one of the types of systems that must be disclosed. It also requires sellers to disclose if there are any “known problems” in the plumbing system.¹ Both of these items are covered in item 7 of the Seller’s Disclosure Statement.

Show expanded answer

The Environmental Defense Fund (EDF) analyzed and graded the housing disclosure policies of all U.S. states and Washington, D.C., according to their ability to help homebuyers make informed decisions about lead service lines (LSLs) before they sign a sales contract.² They assessed four aspects of the seller disclosure policies:

  1. Does the state law require any disclosures of deficiencies, defects, or environmental hazards at sale?
  2. Is there a required or voluntary form for disclosure?
  3. Does a seller need to disclose knowledge of lead pipes or pipe material?
  4. Does a seller need to disclose knowledge of environmental hazards generally?

The highest overall grade given was an A-, which reflects the fact that there is always room for improvement, even for the highest performing states. States with mandatory disclosure specifically asking about lead pipes received an A-, and all other states were compared to these top performers. Four states (Connecticut, Delaware, New York, and Pennsylvania) scored an A- because they each have a state-required disclosure form that specifically asks if the home has lead plumbing.

Six other states--including Michigan--plus Washington, D.C., received a B because they either require disclosure of pipe material (with lead not explicitly addressed), require disclosure of unsafe conditions or unsafe concentrations related to lead in water pipes, or have a voluntary disclosure form that specifically asks about lead pipes. Michigan requires sellers to disclose if there are any “known problems” in the plumbing system. The state also requires sellers to disclose what type of material is used in the plumbing system, but does not specifically call out lead service lines (LSLs).

Buyers and sellers can be proactive by hiring an inspector certified by the American Society of Home Inspectors (ASHI) to identify the water pipe material. The ASHI Standard of Practice for Home Inspectors requires inspection and description of the pipe material of the interior water supply and distribution system.

Buyers can also check for information from previous property inspections. In addition, they can try to identify if a lead service line (LSL) is visible in the home on their own, as described here.

References:


Tags: Legal Responsibility