There is no safe level of lead in drinking water, yet lead is present in common plumbing materials. When water is in contact with these materials, lead can dissolve into the water.
The risk of lead in water at your home, work, or school depends on the plumbing materials used, water quality in your community, and a variety of other factors, such as how much water runs through your pipes every day. The Lead and Copper Rule (LCR) is a regulation created under the federal Safe Drinking Water Act. It establishes requirements for water utilities to reduce the amount of lead or copper that dissolves into water from plumbing materials, focusing on water treatment. The requirements control the amount of lead and copper in the water, but they do not ensure the water is safe to drink in every home.
All states must adopt requirements at least as stringent as the federal LCR. In June 2018, Michigan added requirements to its LCR to address lead in drinking water more proactively. It is now the most stringent rule in the nation.
While water quality in your community likely hasn’t changed, the new information collected under the revised rule allows water utilities to identify risk and address lead in drinking water more directly and proactively. If the new data reveal higher lead levels, it means a more aggressive response to prevent lead exposure is appropriate, and may have been appropriate for some time. Better information allows water supplies to better inform and protect their customers.
If your community has experienced a lead action level exceedance, it is important for your water utility to be clear that members of the community may be at risk of exposure to lead in their drinking water. It is important for residents to know if they live in a home with a lead service line. Residents should continue with precautions to manage the household risk of lead exposure until lead service lines are removed or corrosion control is improved. When properly informed, community members have the ability to reduce their risk of lead exposure in their own homes.
If you are an elected official in a community with a lead action level exceedance, the information here can help you start to take appropriate action.
If your home has a lead service line, activity that moves or shakes the lead service line can increase your risk of exposure to lead through drinking water. Removing and replacing a water meter connected to the lead service line is one of these activities. The risk of exposure increases because the disturbance can cause lead particles to shake free from inside the lead pipes.¹ 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. Particulate lead is a concern because the lead content can be very high. EPA,² AWWA,³ and EGLE4 have recommended the use of lead reducing filters to reduce the risk of lead exposure during and following construction activities for 3-6 months.
- ¹ 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
- ² LEAD AND COPPER RULE REVISIONS WHITE PAPER. Environmental Protection Agency Office of Water. USEPA, October 2016.
- ³ American Water Works Association. ANSI/AWWA Standard C810-17 Replacement and Flushing of Lead Service Lines. First ed., 2017.
- 4CONSTRUCTION ACTIVITY COULD AFFECT YOUR DRINKING WATER Fact Sheet
Lead in drinking water is not safe at any level. Whenever we drink water that has lead in it, some of that lead will be absorbed into our bodies. This is especially true for very young children who will absorb more lead, and absorb it more efficiently than an adult. Health professionals in the United States and across the world have agreed there is no safe level of lead exposure. Once lead gets into our bodies, even small amounts can damage vulnerable organs. This is particularly a concern for the developing brains of young children, particularly babies in the womb. Adults also face health risks from low level lead exposure although they don’t absorb lead as quickly and efficiently as a young child. In adults, lead can cause problems to the heart and the blood circulation system. The most serious concern is elevated blood pressure.
The 15 ppb lead action level is not a health safety standard. It is a regulatory action level. Our health goal is to get lead exposure as close to zero as possible.
There are three major reasons why lead compliance samples from different homes with with lead service lines may have very different results:
- Lead particles. Random release of lead particles can cause unpredictable lead results in drinking water.1
- Water use inside the home. Lead levels tend to be lower in homes with higher water use.
- Lead-containing plumbing materials inside the home. Galvanized steel plumbing can absorb and re-release lead from the lead service line. Lead solder, and faucets and fixtures purchased before 2014 have higher lead content.
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. Even if a low lead result was detected in a home with a lead service line, residents should still consider taking steps to reduce their risk of exposure to lead in water.
- 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
Every water supply subject to compliance with the Michigan LCR must provide the following communications to their customers:
- Written notification to the owner and occupants of any residence with a service line that contains lead, galvanized steel previously connected to lead, or is of unknown material but is likely to contain lead, within 30 days of making this determination. Written notification is also needed if the water supply is unable to determine the content of sections of a service line.
- Written notification to the owner and occupant any time a new water account is opened at a residence with a service line that contains lead, galvanized steel previously connected to lead, or is of unknown material but likely to contain lead.
- An annual Consumer Confidence Report that includes the following information:
- Number of lead service lines, service lines of unknown material, and total service lines in the water supply.
- The 90th percentile of lead and copper results, the range of lead detected in compliance samples, and the number of samples above the lead action level.
- Text explaining the source of lead and copper in drinking water and their health effects.
- Notice of household lead and copper tap water sampling results to the residents of the homes where samples were collected. These must be provided as soon as possible but no later than 30 days after the supply learns of the tap monitoring results.
In addition to these notices, a water supply that exceeds the lead action level must provide these additional communications to their customers:
- A public advisory issued to the community within 3 business days of being informed of the lead action level exceedance by EGLE.
- Public education materials, with specific content requirements, to be distributed within 60 days of notification of the lead action level exceedance. This must be distributed in print to all bill paying customers, with additional outreach to organizations that serve at-risk community members. Distribution of public education materials continues once a year as long as the water supply continues to exceed the lead action level.
- A statement about lead in water with each water bill, issued no less than quarterly, as long as the supply exceeds the lead action level: [NAME OF WATER SUPPLY] exceeded the action level for lead in drinking water. Lead can cause serious health problems. For more information please call [NAME OF WATER SUPPLY] [or visit (WEB SITE HERE)].
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.
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
- Order all sample results from lowest concentration to highest concentration
- Number the samples from 1 (lowest concentration) to n (highest concentration)
- Multiply the total number of samples (n) by 0.9
- 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
- ¹ U.S. Environmental Protection Agency, “Lead and Copper Rule Revisions White Paper” (Washington: U.S. Environmental Protection Agency, 2016), epa.gov/sites/production/files/2016-10/documents/508_lcr_revisions_white_paper_final_10.26.16.pdf.
- ² “How Do I Calculate the 90th Percentile for Lead and/or Copper?” Ground Water & Drinking Water, safewater.zendesk.com/hc/en-us/articles/211400218-How-do-I-calculate-the-90th-Percentile-for-Lead-and-or-Copper-
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.
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
- 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
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 was due on January 1, 2020. A summary of the preliminary inventories submitted to the Michigan Department of Environment, Great Lakes and Energy is available here.
Water supplies are required to publish the number of lead service lines, unknown service lines, and total service lines in their annual consumer confidence report/water quality report along with other information described here. They must update these numbers annually.
If the inventory information for your water supply is not published in either of these two places, you should call your water supply to ask for a copy and contact the Michigan Department of Environment, Great Lakes, and Energy (EGLE) to ensure they enforce this requirement. Contact Michigan EGLE's Office of the Clean Water Public Advocate by email (EGLE-CleanWater@Michigan.gov) or call EGLE's Environmental Assistance Center at 800-662-9278.
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.
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.
- 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.
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.
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.
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.
- ¹ All of the material in the short and long responses are drawn from these two references: Michigan Lead and Copper Rule. Michigan Department of Environmental Quality. 2018. dmbinternet.state.mi.us/DMB/ORRDocs/AdminCode/1346_2014-023EQ_AdminCode.pdf and Lead and Copper Rule Revision Summary. Michigan Department of Environmental Quality. MDEQ, 2018. michigan.gov/documents/deq/deq-dwmad-cws-2018_Rule_Revision_Summary_631411_7.pdf
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.
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.
- ¹ Michigan Lead and Copper Rule (2018), Michigan Department of Environmental Quality
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 smaller sources of lead present in household plumbing after the lead service line is replaced.
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.
- 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
- To learn more about lead in water and Michigan's LCR, visit our searchable, sortable FAQ database
- For information on policy considerations, read our Policy Memos and the accompanying Policy Brief
- To learn more about the risk of lead in water in your community, search and view its Lead and Copper Rule compliance sampling results
- Visit this website to learn how many lead services lines are in your community
- Learn how to find your community's water quality report here
- Do you have more questions?
- If you have questions about your water, call your water utility
- If you have questions about the LCR, contact EGLE: (800)-662-9278 and Michigan.gov/lcr
- If you have a concern about your drinking water, visit EGLE's online drinking water concern system
- If you have questions about your private well, call your county health department