Comments and collation of policy extracts by Elizabeth O'Brien, National Coordinator, The LEAD Group Inc

It is unacceptable for public authorities to turn their interest and funds away from the lead issue without having implemented their own policies. What happened to the recommendations of the National Strategy in Reducing Lead Exposure in Australia, to "Implement a pilot program for testing lead in first flush drinking water, rainwater tanks and drinking fountains; conduct education programs to inform home handy persons of the dangers in using lead solder in plumbing and review drinking water guidelines for lead in context of an overall lead reduction strategy" ??? The LEAD Group Inc. invites anyone to show that any single lead in drinking water strategy planned in the following 5 government policies has been carried out adequately and to completion.

Further, on the basis of one Victorian study that found one in every four rainwater tanks tested in Victoria had lead levels at or exceeding the Australian Drinking Water Guidelines, and knowing that 13% of all Australian households use rainwater tanks for drinking water [Reference: "Guidance on the Use of Rainwater Tanks" by David Cunliffe (1998)], it can be extrapolated that over 600,000 Australians have too much lead in their drinking water.

REFERENCE 1: "Lead Issues Paper Strategy Framework" in NSW Lead Issues Paper – March 1993, published by NSW EPA and NSW Health Department, Sydney, March 1993.

• Lead in water and wastewater – through review of existing data on drinking and wastewater and identification of problem areas

• Lead in water and wastewater – through assessment of data on lead contamination and the development of action plans to address problems identified.

REFERENCE 2: "Recommendations for a National Strategy" in Reducing Lead Exposure in Australia - July 1993, Final Report Vol 1 - Pages ES 7 To ES 20. Funded by National Health and Medical Research Council. Published by Commonwealth Department of Human Services and Health, Commonwealth of Australia, Canberra, 1994.

Rationale : Despite widespread confidence among water industry professionals about the low level of lead in Australian water, there is virtually no evidence about the lead content of first flush water in homes and drinking fountains. Testing of drinking water is almost exclusively, focused on water sources and distribution systems. If lead is present in drinking water, it will not be detected in these tests because its likely source is household plumbing; commonly lead solder used with brass fittings or copper pipes.

Even where tap water is tested for lead, standard procedures involve measurement of running water. Lead from plumbing shows up in first flush tap water, that is, water drawn after the system has been standing idle for several hours or overnight. A small test in several Australian cities found that although most samples had very low lead content, a very high level (up to 64 µg/litre) was found in some cases. Given the hazard posed to children by levels of lead in drinking water, there are good reasons for immediately undertaking a pilot sampling program to determine lead levels from first flush water in homes and drinking fountains used by children.

Although the contribution of lead in water to blood lead level is relatively small in comparison with that of lead in petrol, an overall lead strategy should examine the contribution from all sources and the potential for reduction. The potential for reducing lead exposure from each source must be examined. Only by considering all sources together will it be possible to determine the appropriate guideline for lead in water. (For impacts, see page ES-34.)

Principal agencies: NHMRC, Water Resources Council. Others involved: Water authorities, State health departments, consumer organisations.

Major activities:

• Develop and implement pilot program for testing lead in first flush water. The program should target houses most likely to have conditions generally associated with high lead levels in tap water.

• Develop and implement pilot program for testing rainwater tanks to determine if lead is a problem in drinking water from tanks.

• Develop and implement pilot program for testing water from drinking fountains, particularly first flush water.

• If the results of the pilot programs indicate that lead is present in water from taps, rainwater tanks or drinking fountains, develop appropriate programs of remediation. Prepare and conduct public education program aimed at home handypersons to warn of dangers in using lead solder in plumbing. This issue should also be one aspect of the program for renovators.

• Review drinking water guidelines in context of maximum overall lead intake that will permit achievement of the blood lead level goal.

Timetable: Immediately develop and implement pilot drinking water testing program. Immediately prepare and implement public education program on dangers of lead solder use. Immediately begin examination of maximum lead intake to achieve goal, including contribution of drinking water.

REFERENCE 3: NSW Lead Management Action Plan (LMAP). Published for the *Interdepartmental Lead Taskforce by NSW Environment Protection Authority, Sydney, November 1994.

Strategy 110. Conduct a water sampling program which includes the following areas:

• high rise (complex plumbing systems)

• schools (long run systems)

• old urban areas

(Strategy implementation: Water Board and other local water authorities through the provision of research grants funded by appropriate Commonwealth and State authorities. NSW Public Works to develop a program for rural water authorities)

Strategy 111. Information obtained through implementation of the above should be incorporated into the education strategy where appropriate.

(Strategy implementation: Lead Reference Centre)

Strategy 112. Data collected on lead within the water and wastewater section to be included in the EPA State of the Environment report, to enable the effectiveness of reduction initiatives to be monitored.

(Strategy implementation: Data collection undertaken by water authorities and NSW Public Works. EPA to incorporate data into the State of the Environment Report)

Strategy 113. Reduce the allowable level of lead in plumbing products to the minimum practical level.

(Strategy implementation: industry, water authorities and Standards Australia,
co-ordinated by the Department of Consumer Affairs)

Strategy 114. Investigate the application of environmentally benign alternatives to lead plumbing products.

(Strategy implementation: industry)

Strategy 115. Mark solders as either suitable or unsuitable for use in plumbing systems.

(Strategy implementation: industry;
co-ordinated by the Department of Consumer Affairs)

Strategy 116. Develop standard methods for testing the extraction of metals from products in contact with drinking water [Australian Standard AS 4020 (interim Standard)]

(Strategy implementation. Standards Australia)

Strategy 117. Amend the draft NHMRC goal of 10 m g/L of lead in drinking water to include prescribed sampling methodologies.

(Strategy implementation: NHMRC;
co-ordinated by ANZECC)

Strategy 119. Develop comprehensive general and targeted education campaigns which:

• focus on key target groups (eg carers of young children, lead industry workers and do it yourself plumbers)

• focus on ways to minimise individual exposure

• focus on problems associated with first draw water and the use of hot water systems used specifically for consumption purposes.

Investigate the feasibility of distributing this material with water bills and at plumbing hardware centres.

(Strategy implementation: water authorities in consultation with the Lead Reference Centre)

Strategy 120. Develop exposure reduction strategies, especially for domestic situations, where indicated necessary by the outcome of the recommended data collection program.

(Strategy implementation: Undertaken by the relevant water authorities or Public Works in rural regions. Prevention strategies which focus on education should be developed by the Lead Reference Centre with input from relevant authorities)

Strategy 121. Where practical, introduce water treatment to reduce lead leaching rates from supply systems in high risk areas.

(Strategy implementation: Water Board/local water authorities/local government)

Strategy 122. Strictly apply the guidelines for the application of biosolids and sewage effluent to land within water supply catchments.

(Strategy implementation: Water Board/local water authorities)

Strategy 123. Investigate the efficiency of water filters to remove lead especially for schools and multileveled buildings.

(Strategy implementation: Manufacturers. Information co-ordinated and reported by the Lead Reference Centre)

Strategy 124. Investigate ways of reducing the cost to the consumer of lead analysis of drinking water in areas of high lead exposure.

(Strategy implementation: Water Board/local water authorities)

Strategy 125. Develop effective and economic mitigation techniques.

(Strategy implementation: Water Board/local water authorities)

REFERENCE 4: "Recommendations for Strategies, Priorities and Guidelines" in Report of the Select Committee upon Lead Pollution" December 1994. Published by the *Select Committee upon Lead Pollution, NSW Parliament, Sydney, December 1994.

*The Select Committee upon Lead Pollution was comprised of the following Members of Parliament:

1. Paul Zammit (Chairman)

2. Jeff Hunter (Deputy Chairman)

3. Bill Beckroge

4. Jeremy Kinross

5. Sandra Nori

6. Bill Rixon

7. Clover Moore

Data Collection
Both the TR [Report of the NSW Interdepartmental Lead Taskforce 1994] and the LWaterWWGR [Lead in Water and Wastewater Working Group Report] recommend a water sampling program but, whereas the TR gives examples of areas to be sampled high rise buildings, schools and old urban areas, the LWaterWWGR gives high rise buildings, schools, bottled water and rainwater tanks.

Materials and Standards
The TR omitted the following recommendation of the LWaterWWGR: "that water supply authorities and individuals take action to reduce the lead present in systems under their control whenever the opportunity arises".

Education
The LWaterWWGR recommends that the education campaign should clearly describe the relative risks and importance of different lead sources and the interaction between the components.

The Lead Education Working Group Report recommends "that Local Government includes in all Building Applications, information on lead paint and plumbing issues. This issue should be developed by the institute of Environmental Health with input from the proposed Lead Reference Centre, Councils, Community, Industry and the EPA."

REFERENCE 5: Resolution of the Organisation For Economic Cooperation And Development (OECD) Council Concerning the Declaration on Risk Reduction for Lead OECD Document number: C(96)42/FINAL (adopted by the Council at its 869th Session on 20 February 1996 [C/M(96)4/PROV]).

THE COUNCIL

1. NOTES the Declaration on "Risk Reduction for Lead" adopted by the Governments of OECD Member countries at the meeting of the Environment Policy Committee at a Ministerial level on 19-20 February 1996 (the text of the Declaration is reproduced in the Annex to this Resolution).

2. RECOGNISES that the support and publicity to be given by Member Governments to the Declaration will be an important factor in its authority, efficiency and success…

3.  INSTRUCTS the Environment Policy Committee to review the progress made by Member countries and to assess the need for further action in conformity with paragraph 9 of the Declaration….

ANNEX

DECLARATION on Risk Reduction for Lead

THE GOVERNMENTS OF OECD MEMBER COUNTRIES,¹

1 The mention of "Governments’ is deemed to also apply to the European Communities.

DECLARE THAT THEY WILL:

(2) Give highest priority to actions which address the risk of exposure from food and beverages, water, air, occupational exposure and other potential pathways in accordance with Annex I;

(3) Continue to review lead levels in the environment and exposure to lead of sensitive populations (such as children and pregnant women) and of high risk populations (such as certain groups of workers) using the results to evaluate the effectiveness of national programs in reducing risks from exposure to lead and to identify priorities and opportunities for future actions; …

FURTHER DECLARE THAT THE OECD SHOULD:

… (9) Review progress by Member countries in pursuance of this Declaration three years after adoption and assess the need for further action; …

Annex I

… g. Reduce lead levels in drinking water through appropriate measures (e.g., treatment of the water, use of materials in the distribution system which do not release lead into the water);