EPA’s Proposed Lead and Copper Rule Improvements (LCRI)
Public Comment of the National Center for Health Research
(EPA-HQ-OW-2022-0801-0036)
The National Center for Health Research is a nonprofit public health think tank in Washington, DC that is dedicated to improving the health and safety of adults and children by using scientific evidence to improve public policies and programs.
We strongly support the numerous improvements in the LCRI, such as the following plans:
- To eliminate the 10 ppb trigger level, since that level is not supported by the science. The current system built around this trigger is not adequate to protect children or public health.
- To expand the regulations to include 9 million pipes.
- To reduce the time frame to 10 years.
- To base compliance on either the first or fifth liter sample, whichever is higher
- To require that water systems report all home testing results to the residents within 3 days. Whenever possible, we encourage EPA to urge that testing results be made available even sooner.
- To calculate the average annual replacement rate across a rolling three-year period
- To require disclosure and offer pipe replacement whenever there is a change in building ownership.
We recommend the following improvements to the proposed rule:
Although EPA’s plan to lower the action level to 10 ppb is an important step in the right direction, we strongly recommend a lower action level of 5 ppb and agree with the AAP that the action level should be 0 ppb.
We urge EPA to require public water systems to be responsible for replacing the entire lead pipe, not only the part that is on public property. Partial pipe replacement should be prohibited except in the rare emergency situation when it is impossible to replace the entire pipe. In addition, we urge EPA to ensure that renters have equitable access to lead service line replacement.
Children’s lead exposures in schools, daycare facilities, and after school care facilities need to be reduced, and that requires greater EPA attention and enforcement to ensure safety. For example, mandatory installation of point-of-use filters on all faucets that are potentially used for drinking makes more sense than merely implementing a testing and monitoring program.
Overall, the regulatory language for reporting lead in water needs to be strengthened and enforced.
In conclusion, it is important to note that lead pipes should not be replaced with pipes that contain lead or other dangerous chemicals. For example, PVC pipes are also very hazardous to human health, because the base material is vinyl chloride, a chemical that has been linked to increased risk of liver, brain, and lung cancers, as well as lymphoma and leukemia.