Drinking Water: EPA Could Use Available Data to Better Identify Neighborhoods at Risk of Lead Exposure
Fast Facts
Lead in drinking water comes primarily from corrosion of service lines that connect the water main to a building. The total number of lead service lines in the United States is unknown.
Through our statistical analysis of 4 water systems' geospatial lead data and U.S. Census data, we found that areas with older housing and vulnerable populations were more likely to have lead service lines. Many water systems face challenges identifying high-risk areas for required testing. The EPA has not updated guidance for identifying these areas since 1991.
We made 4 recommendations, including that the EPA develop new guidance for water systems.
Typical location of a water main, service line, and other pipes that deliver drinking water to homes
Highlights
What GAO Found
GAO's statistical analysis indicates that areas with older housing and vulnerable populations (e.g., families in poverty) have higher concentrations of lead service lines in the selected cities GAO examined. By using geospatial lead service line data from the selected water systems and geospatial data from the U.S. Census Bureau's American Community Survey (ACS), GAO identified characteristics of neighborhoods with higher concentrations of lead service lines. The Environmental Protection Agency's (EPA) guidance for water systems on how to identify the location of sites at high-risk of having lead service lines has not been updated since 1991 and many water systems face challenges identifying areas at risk of having lead service lines. By developing guidance for water systems that outlines methods for identifying high-risk locations using publicly available data, EPA could better ensure that public water systems test water samples from locations at greater risk of having lead service lines and identify areas with vulnerable populations to focus lead service line replacement efforts. (See figure for common sources of lead in home drinking water.)
Common Sources of Lead in Drinking Water within Homes and Residences
EPA has taken some actions to address the Water Infrastructure Improvements for the Nation (WIIN) Act requirement, which include developing a strategic plan regarding lead in public water systems. However, EPA's published plan did not satisfy the statutory requirement that the agency's strategic plan address targeted outreach, education, technical assistance, and risk communication undertaken by EPA, states, and public water systems. For example, the plan does not discuss public education, technical assistance or risk communication. Instead, EPA's plan focused solely on how to notify households when EPA learns of certain exceedances of lead in their drinking water. Moreover, EPA's plan is not consistent with leading practices for strategic planning. For example, EPA's plan does not set a mission statement or define long-term goals. Developing a strategic plan that meets the statutory requirement and fully reflects leading practices for strategic planning would give EPA greater assurance that it has effectively planned for how it will communicate the risks of lead in drinking water to the public.
Why GAO Did This Study
Lead in drinking water comes primarily from corrosion of service lines connecting the water main to a house or building, pipes inside a building, or plumbing fixtures. As GAO reported in September 2018, the total number of lead service lines in drinking water systems is unknown, and less than 20 of the 100 largest water systems have such data publicly available.
GAO was asked to examine the actions EPA and water systems are taking to educate the public on the risks of lead in drinking water. This report examines, among other things: (1) the extent to which neighborhood data on cities served by lead service lines can be used to focus lead reduction efforts; and (2) actions EPA has taken to address WIIN Act requirements, and EPA's risk communication documents.
GAO conducted a statistical analysis combining geospatial lead service line and ACS data to identify characteristics of selected communities; reviewed legal requirements and EPA documents; and interviewed EPA officials.
Recommendations
GAO is making four recommendations, including that EPA develop (1) guidance for water systems on lead reduction efforts, and (2) a strategic plan that meets the WIIN Act requirement. EPA agreed with one recommendation and disagreed with the others. GAO continues to believe the recommendations are warranted, as discussed in the report.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Environmental Protection Agency | EPA's Assistant Administrator for Water should develop guidance for water systems that outlines methods to use ACS data and, where available, geospatial lead or other data to identify high-risk locations in which to focus lead reduction efforts, including tap sampling and lead service line replacement efforts. (Recommendation 1) |
As of December 2023, this recommendation is partially implemented. EPA indicated that the agency has been working with four states on a technical assistance initiative called Lead Service Line Replacement Accelerators, to address existing barriers and accelerate progress toward lead service line identification and replacement; the agency estimates completing this effort in early 2025. EPA's August 2022 Guidance for Developing and Maintaining a Service Line Inventory includes information for water systems that offers, among other items, service line investigation methods such as the use of geostatistical models and other approaches. In addition, the document includes factors for when a system may want to prioritize investigations at locations served by unknown service lines, such as the presence of children at schools or childcare centers. The recommendation included the use of ACS data to support the identification of high-risk locations, but the guidance did not identify such a method. We await additional information from EPA on its progress.
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| Environmental Protection Agency | EPA's Assistant Administrator for Water should incorporate use of (1) ACS data on neighborhood characteristics potentially associated with the presence of lead service lines and (2) geospatial lead data, when available, into EPA's efforts to address the Federal Action Plan to Reduce Childhood Lead Exposures and Associated Health Impacts. (Recommendation 2) |
As of December 2023, this recommendation is partially implemented. EPA indicated that as part of its technical assistance initiative called Lead Service Line Replacement Accelerators, the agency is working with 40 communities to address existing barriers and accelerate progress toward lead service line identification and replacement. Part of this effort includes developing tools and case studies to facilitate best practices on identifying lead service lines, which the agency estimates completing in early 2025. EPA's August 2022 Guidance for Developing and Maintaining a Service Line Inventory discusses various approaches that can be used to establish lead service line inventories. The document provides guidance in a section titled "How to Make the Data Publicly Available" that includes recommendations on web-based map applications and useful information for addressing lead exposures in children. However, the recommendation identified the use of ACS data on neighborhood characteristics with geospatial data, when available, which was excluded from the guidance. We await additional information from EPA on its progress.
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| Environmental Protection Agency |
Priority Rec.
EPA's Assistant Administrator for Water should develop a strategic plan that meets the WIIN Act requirement for providing targeted outreach, education, technical assistance, and risk communication to populations affected by the concentration of lead in public water systems, and that is fully consistent with leading practices for strategic plans. (Recommendation 3) |
EPA disagreed with our recommendation. As of April 2024, EPA maintains that the proposed Lead and Copper Rule Improvements rule, published in December 2023, is responsive to our recommendation. According to EPA officials, the rule has several key provisions, including strengthening protections to reduce exposure to lead in drinking water. However, the proposed rule is not a strategic plan and does not include all of the elements required by the WIIN Act for the strategic plan. The WIIN Act requires EPA to develop a strategic plan to provide targeted outreach, education, technical assistance, and risk communication undertaken by EPA, states, and public water systems to populations affected by the concentration of lead in public water systems-including dissemination of information to households when there are certain exceedances of the lead action level. We maintain that implementing our recommendation will give EPA greater assurance that it has effectively planned for how to communicate to the public the risks of lead in drinking water.
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| Environmental Protection Agency |
Priority Rec.
The Administrator of EPA should establish a time frame for publishing new risk communication guidance or updating existing risk communication manuals. (Recommendation 4) |
As noted in its comments in our December 2020 report, EPA agreed with the recommendation to establish a time frame for publishing new risk communication guidance or updating existing risk communication manuals and has taken action to do so. Specifically, in April 2021, EPA updated its risk communication website: http://www.epa.gov/risk-communication with several new Agency-wide guidance documents, including: (1) an updated research-based definition of risk communication: (2) a new risk communication framework for all EPA staff to use in carrying out risk communication, focusing on strategy, action, learning, and tools; and (3) some new risk communication videos and case studies.
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