Testimony 

Before the Subcommittee on Environment 

and Hazardous Materials, Committee on 

Energy and Commerce, House of 

Representatives

United States Government Accountability Office

GAO

For Release on Delivery 

Expected at 9:30 a.m. DST 

Thursday, July 22, 2004 DRINKING WATER 

Safeguarding the District of 

Columbia’s Supplies and 

Applying Lessons Learned 

to Other Systems 

Statement of John B. Stephenson, Director 

Natural Resources and Environment 

GAO-04-974T 
www.gao.gov/cgi-bin/getrpt?GAO-04-974T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact John 

Stephenson at (202) 512-3841 or 

stephensonj@gao.gov. 

Highlights of GAO-04-974T, a statement

to the Subcommittee on Environment and 

Hazardous Materials, Committee on 

Energy and Commerce, House of 

Representatives 

July 2004

DRINKING WATER

Safeguarding the District of Columbia’s 

Supplies and Applying Lessons Learned 

to Other Systems 

This statement discusses GAO’s preliminary observations and highlights 

areas of further examination. 

One of the key relationships in the effort to ensure the safety of the District’s 

drinking water is the one between WASA, the deliverer of water, and EPA’s 

Philadelphia Office, which oversees WASA’s compliance with drinking water 

regulations. Recent public statements and corrective actions by these 

parties clearly indicate that coordination and communication between them 

could have been better in the years preceding the current lead controversy. 

GAO’s future work will examine (to the extent appropriate) the 

interrelationships among other key agencies (such as the Aqueduct and the 

D.C. Department of Health); how other water systems in similar situations 

interacted with federal, state, and local agencies; and what the experiences 

of these other jurisdictions may suggest concerning how improved 

coordination can better protect drinking water in the District of Columbia. 

Other water systems facing elevated lead levels used public notification and 

education practices that may offer lessons for conducting outreach to water 

customers. For example, some of the practices of the two water systems we 

have begun to examine – the Massachusetts Water Resources Authority and 

the Portland (Oregon) Water Bureau – include tailoring their 

communications to varied audiences in their service areas, testing the 

effectiveness of their communication materials, and linking demographic 

and infrastructure data to identify populations at greatest risk from lead in 

drinking water. 

WASA faces challenges in collecting the information needed to identify 

District citizens at greatest risk from lead in drinking water. Specifically, 

WASA has partial information on which of its customers have lead service 

lines, and is in the process of obtaining more complete information. GAO’s 

future work will examine the efforts of other water systems to go one step 

further by linking data on at-risk populations (such as pregnant mothers, 

infants, and small children) with data on homes suspected of being served by

lead service pipes and other plumbing fixtures that may leach lead into 

drinking water. 

Nationally, much is known about the hazards of lead once in the body and 

how lead from paint, soil, and dust enter the body, but little research has 

been done to determine actual lead exposure from drinking water, and the 

information that does exist is dated. In our future work, we will examine the 

plans of EPA and other organizations to fill this key information gap. 

Concerns have been raised about lead 

in District of Columbia drinking water 

and how those charged with ensuring 

the safety of this water have carried 

out their responsibilities. The 1991 

Lead and Copper Rule (LCR) requires 

water systems to protect drinking 

water from lead by, among other 

things, chemically treating it to reduce 

its corrosiveness and by monitoring tap 

water samples for evidence of lead 

corrosion. If enough samples show 

corrosion, water systems officials are 

required to notify and educate the 

public on lead health risks and 

undertake additional efforts. The 

Washington Aqueduct, owned and 

operated by the U.S. Army Corps of 

Engineers, treats and sells water to the 

District of Columbia Water and Sewer 

Authority (WASA), which delivers 

water to D.C. residents. EPA’s 

Philadelphia Office is charged with 

overseeing these agencies. 

GAO is examining (1) the current 

structure and level of coordination 

among key government entities that 

implement the Safe Drinking Water 

Act’s regulations for lead in the District 

of Columbia, (2) how other drinking 

water systems conducted public 

notification and outreach, (3) the 

availability of data necessary to 

determine which adult and child 

populations are at greatest risk of 

exposure to elevated lead levels, and 

what information WASA is gathering to 

help track their health, and (4) the state 

of research on the health effects of lead 

exposure. 

The testimony discusses preliminary 

results of GAO’s work. GAO will report 

in full at a later date. 
Page 1 GAO-04-974T Lead in Drinking Water 

Mr. Chairman and Members of the Subcommittee: 

Thank you for the opportunity to discuss our work to date on the issues 

surrounding elevated levels of lead in Washington, D.C. drinking water. At 

the request of this Subcommittee, we are examining issues concerning 

lead in drinking water generally and the situation in Washington, D.C., in 

particular. Our testimony today lays out our preliminary observations on 

these issues and highlights areas of further examination. 

Although rarely the sole cause of lead poisoning, lead in drinking water 

can significantly increase a person’s total lead exposure. EPA estimates 

that drinking water is the source of about 20 percent of Americans’ lead 

exposure, but that it may be as high as 60 percent for infants who drink 

baby formulas and concentrated juices that are mixed with water. Adults 

who drink water with high lead concentrations could develop kidney 

problems or high blood pressure. Developing fetuses, infants and young 

children are more vulnerable to lead from all sources, including drinking 

water. Their exposure to lead may delay their physical or mental 

development. 

The delivery of safe water to residents requires that water systems and 

regulators work cooperatively in fulfilling the requirements of the Safe 

Drinking Water Act.1

 In most cases, states have primary oversight and 

enforcement authority under the Act. Lead in drinking water is regulated 

under the Act’s 1991 Lead and Copper Rule.2

 The rule requires water 

systems to treat their water to limit its corrosiveness, monitor tap water 

samples for evidence of elevated levels of lead, and report this information 

to their state. In addition, drinking water systems may consult with state 

health agencies when communicating with their customers about health 

risks from drinking water. 

The relationship between regulators and water systems is more 

complicated in the District of Columbia, where the Washington Aqueduct, 

 1

42 U.S.C. 300f-300j. 

2

40 C.F.R. pt. 141, subpart I. The Lead and Copper Rule established an action level of 15 

parts per billion (ppb) for lead in drinking water. Under the rule, the action level is 

exceeded if lead levels are higher than 15 ppb in over 10 percent of tap water samples 

taken. For each monitoring period, a system must report the lead level at the 90th 

percentile of homes monitored. For example, if a system monitors 100 homes, it sorts its 

results from the lowest to the highest concentrations and reports the concentration it 

observed in the 90th sample. 
Page 2 GAO-04-974T Lead in Drinking Water 

owned by the U.S. Army Corps of Engineers, draws and treats water from 

the Potomac River. The Aqueduct sells the treated water to the District of 

Columbia Water and Sewer Authority (WASA), which distributes it to 

District residents. The Environmental Protection Agency’s (EPA) 

Region III Office in Philadelphia, Pennsylvania, has primary oversight and 

enforcement authority for the District’s public water systems. The District 

of Columbia’s Department of Health, while having no formal role under 

the Safe Drinking Water Act, is responsible for educating District residents 

on potential health risks. 

In the District, the Washington Aqueduct treats drinking water and 

monitors for most contaminants, while WASA monitors tap water samples 

for lead and reports these results to EPA’s Philadelphia Office. Tap water 

monitoring is important because, unlike most drinking water 

contaminants, lead is not generally introduced to drinking water supplies 

from source water. Rather, lead leaches into drinking water as it travels 

through lead service pipes, over pipe joints connected with lead-based 

solder, and through brass plumbing fixtures that contain lead. According 

to EPA, its Philadelphia Office is responsible for providing technical 

assistance to the Aqueduct and WASA on how to comply with federal 

regulations; ensuring that they report the monitoring results to EPA by 

required deadlines; taking enforcement actions if violations occur; and 

using those enforcement actions to return the water systems to 

compliance in a timely fashion. 

Significant concerns were raised in early 2004 about how federal and local 

agencies were carrying out their responsibilities under the Safe Drinking 

Water Act. At that time, the local media reported that a number of tap 

water samples showed elevated levels of lead. 

You asked that we (1) examine the current structure and level of 

coordination among key government entities that implement the Safe 

Drinking Water Act’s regulations for lead in the District of Columbia, and 

identify any improvements to increase efficiency and accountability, (2) 

determine how other drinking water systems that exceeded the EPA 

action level for lead have conducted public notification and outreach, (3) 

assess the availability of data necessary to determine which adult and 

child populations are at greatest risk of exposure to elevated lead levels, 

and what information WASA is gathering to help track their health, (4) 

evaluate the state of research on lead exposure, and how this information 

could help inform other drinking water utilities of potential problems in 

their systems. 
Page 3 GAO-04-974T Lead in Drinking Water 

To respond to these questions, we are interviewing key officials and staff 

with the federal and local agencies responsible for managing drinking 

water and monitoring health for lead exposure in Washington, D.C., 

including officials at EPA’s headquarters and in its Philadelphia Office, 

WASA, the Washington Aqueduct, and the D.C. Department of Health. We 

are also (1) reviewing records documenting key activities and interactions 

among these agencies, and examining their current responses to the lead 

problem, (2) contacting academic and non-governmental experts in lead 

contamination, and (3) examining how other water systems facing similar 

circumstances notified and educated their customers on lead health risks, 

and how they interacted with federal, state, and local agencies to respond 

to the problem. Many of the facts and circumstances surrounding the 

District’s lead controversy are the subject of active litigation. Accordingly, 

we do not take a position on these issues and on how they bear on the 

question of interagency coordination and communication, and instead 

report them only as stated by the affected parties. 

We are here to present our preliminary observations on these issues. We 

will report our final findings and any recommendations we may develop at 

a later date. In summary: 

• Providing safe drinking water requires that water systems, regulators, and 

public health agencies fulfill individual roles, yet work together in a 

coordinated fashion. It is particularly important that these entities report 

and communicate information to each other in a timely and accurate 

manner. Recent public statements and corrective actions by the 

responsible entities, particularly EPA and WASA, clearly indicate that 

coordination could have been better in the years preceding the current 

controversy. As our work continues, we will seek to examine (to the 

extent appropriate) specific ways in which improved coordination 

between EPA and WASA could help both agencies better fulfill their 

responsibilities. We will also examine interrelationships among other key 

agencies (such as the Aqueduct and the D.C. Department of Health); how 

other water systems in similar situations interacted with federal, state, and 

local agencies; and what the experiences of these other jurisdictions may 

suggest concerning how improved coordination can better protect 

drinking water in the District of Columbia. 

• Other water systems facing elevated lead levels used public notification 

and education practices that appear to offer lessons for conducting 

outreach to water customers, including those in the District of Columbia. 

For example, some of the practices of the two systems we have begun to 

examine—the Massachusetts Water Resources Authority and the Portland 
Page 4 GAO-04-974T Lead in Drinking Water 

Water Bureau—include tailoring their communications to varied 

audiences in their service areas, testing the effectiveness of their 

communication materials, and linking demographic and infrastructure 

data to identify populations at greatest risk from lead in drinking water. 

• WASA faces challenges in collecting the information needed to identify 

District citizens at greatest risk from lead in drinking water. Specifically, it 

has partial information on which of its customers have lead service pipes, 

although it is currently in the process of obtaining more complete 

information. In our future work, we will examine the efforts of other water 

systems to go one step further by linking data on at-risk populations (such 

as pregnant mothers, infants, and small children) with data on homes 

suspected of being served by lead service pipes and other plumbing 

fixtures that may leach lead into drinking water. 

• Much is known about the hazards of lead in the human body and about 

how lead from paint, soil, and dust enter the body. However, little research 

has been done to determine actual lead exposure from drinking water, and 

the information that does exist is dated. In our future work, we will 

examine the plans of EPA and other organizations to fill this key 

information gap. 

Lead is unusual among drinking water contaminants in that it seldom 

occurs naturally in source water supplies like rivers and lakes. Rather, 

lead enters drinking water primarily as a result of the corrosion of 

materials containing lead in the water distribution system and in 

household plumbing. These materials include lead service pipes that 

connect a house to the water main, household lead-based solder used to 

join copper pipe, and brass plumbing fixtures such as faucets. 

The Safe Drinking Water Act is the key federal law protecting public water 

supplies from harmful contaminants. The Act established a federal-state 

arrangement in which states may be delegated primary implementation 

and enforcement authority (“primacy”) for the drinking water program. 

Except for Wyoming and the District of Columbia, all states and territories 

have received primacy. For contaminants that are known or anticipated to 

occur in public water systems and that the EPA Administrator determines 

may have an adverse impact on health, the Act requires EPA to set a nonenforceable maximum contaminant level goal (MCLG) at which no known 

or anticipated adverse health effects occur and that allows an adequate 

margin of safety. Once the MCLG is established, EPA sets an enforceable 

standard for water as it leaves the treatment plant, the maximum 

Background 
Page 5 GAO-04-974T Lead in Drinking Water 

contaminant level (MCL). The MCL generally must be set as close to the 

MCLG as is “feasible” using the best technology or other means available, 

taking costs into consideration. 

The fact that lead contamination occurs after water leaves the treatment 

plant has complicated efforts to regulate it in the same way as most 

contaminants. In 1975, EPA set an interim MCL for lead at 50 parts per 

billion (ppb), but did not require sampling of tap water to show 

compliance with the standard. Rather, the standard had to be met at the 

water system before the water was distributed. The 1986 amendments to 

the Act directed EPA to issue a new lead regulation, and in 1991, EPA 

adopted the Lead and Copper Rule. 

Instead of an MCL, the rule established an “action level” of 15 ppb for lead 

in drinking water, and required that water systems take steps to limit the 

corrosiveness of their water. Under the rule, the action level is exceeded if 

lead levels are higher than 15 ppb in over 10 percent of tap water samples 

taken. Large systems, including WASA, generally must take at least 100 tap 

water samples in a 6-month monitoring period. Large systems that do not 

exceed the action level or that maintain optimal corrosion control for two 

consecutive 6-month periods may reduce the number of sampling sites to 

50 sites and reduce collection frequency to once per year. If a water 

system exceeds the action level, other regulatory requirements are 

triggered. The water system must intensify tap water sampling, take 

additional actions to control corrosion, and educate the public about steps 

they should take to protect themselves from lead exposure. If the problem 

is not abated, the water system must annually replace 7 percent of the lead 

service lines under its ownership. 

The public notification requirements of the Safe Drinking Water Act are 

intended to protect public health, build trust with consumers through open 

and honest sharing of information, and establish an ongoing, positive 

relationship with the community.3

 While public notification provisions 

were included in the original Act, concerns have been raised for many 

years about the way public water systems notify the public regarding 

health threats posed by contaminated drinking water. In 1992, for 

example, we reported, among other things, that (1) there were high rates 

of noncompliance among water systems with the public notification 

regulations in effect at that time and (2) notices often did not clearly 

 3

Public Notification Handbook, EPA Office of Water (EPA 816-R-00-010, June 2000). 
Page 6 GAO-04-974T Lead in Drinking Water 

convey the appropriate information to the public concerning the health 

risks associated with a violation and the preventive action to be taken.4

The 1996 Amendments to the Safe Drinking Water Act attempted to 

address many of these concerns by requiring that consumers of public 

water supplies be given more accurate and timely information about 

violations and that this information be in a form that is more 

understandable and useful. 

Drinking water is provided to District of Columbia residents under a 

unique organizational structure: 

• The U.S. Army Corps of Engineers’ Washington Aqueduct draws water 

from the Potomac River and filters and chemically treats it to meet EPA 

specifications. The Aqueduct produces drinking water for approximately 1 

million citizens living, working, or visiting in the District of Columbia, 

Arlington County, Virginia, and the City of Falls Church, Virginia. Managed 

by the Corps of Engineers’ Baltimore District, the Aqueduct is a federally 

owned and operated public water supply agency that produces an average 

of 180 million gallons of water per day at two treatment plants located in 

the District. All funding for operations, maintenance, and capital 

improvements comes from revenue generated by selling drinking water to 

the District of Columbia, Arlington County, Virginia, and the City of Falls 

Church, Virginia. 

• The District of Columbia Water and Sewer Authority buys its drinking 

water from the Aqueduct. WASA distributes drinking water through 1,300 

miles of water mains under the streets of the District to individual homes 

and buildings, as well as to several federal facilities directly across the 

Potomac River in Virginia. From its inception in 1938 until 1996, WASA’s 

predecessor, the District of Columbia Water and Sewer Utility 

Administration, was a part of the District’s government. In 1996, WASA 

was established by District of Columbia law as a semiautonomous regional 

entity. WASA develops its own budget, which is incorporated into the 

District’s budget and then forwarded to Congress. All funding for 

operations, improvements, and debt financing come from usage fees, EPA 

grants, and the sale of revenue bonds. 

• EPA’s Philadelphia Regional Office has primary oversight and 

enforcement responsibility for public water systems in the District. 

 4

U.S. General Accounting Office, Drinking Water: Consumers Often Not Well-Informed of 

Potentially Serious Violations, GAO/RCED-92-135 (Washington, D.C. June 1992). 
Page 7 GAO-04-974T Lead in Drinking Water 

According to EPA, the Regional Office’s oversight and enforcement 

responsibilities include providing technical assistance to the water 

suppliers on how to comply with federal regulations; ensuring that the 

suppliers report the monitoring results to EPA by the required deadlines; 

taking enforcement actions if violations occur; and using those 

enforcement actions to return the system to compliance in a timely 

fashion. 

• The District’s Department of Health, while having no formal role under 

the Act, is responsible for identifying health risks and educating the public 

on those risks. 

Providing safe drinking water requires that water systems, regulators, and 

public health agencies fulfill individual responsibilities yet work together 

in a coordinated fashion. It is particularly important that these entities 

report and communicate information to each other in a timely and 

accurate manner. In the case of drinking water in the District of Columbia, 

one of the key relationships is the one between WASA, the deliverer of 

water to District customers, and EPA’s Philadelphia Office, the regulator 

charged with overseeing WASA’s compliance with drinking water 

regulations. Of particular note, one of WASA’s key obligations is to 

monitor the water it supplies to District customers through a tap water 

sampling program, and to report these results accurately and in a timely 

manner to EPA’s Philadelphia Office. As EPA itself has noted, one of the 

Philadelphia Office’s key obligations is to ensure that WASA understands 

the reporting requirements and reports monitoring results by required 

deadlines. 

It is noteworthy that WASA and EPA have taken or agreed to take steps 

that are clearly intended to improve communication and coordination 

between the agencies. For example: 

• Under the Consent Order signed by EPA and WASA on June 17, 2004, 

WASA agreed to improve its format for reporting tap water samples by 

ensuring that the reports include tap water sample identification numbers, 

sample date and location, lead and copper concentration, service line 

materials, and reasons for any deviation from previously sampled 

locations. The monitoring reports are also to include the laboratory data 

sheets, which contain the raw test data recorded directly by the 

laboratory. Under the Order, WASA also agreed to submit to EPA for 

comment a plan and schedule for enhanced information, database 

management, and reporting. The plan is to describe how monitoring 

Coordination Among 

Agencies Is Critical To 

Ensure Safe Drinking 

Water 
Page 8 GAO-04-974T Lead in Drinking Water 

reports will be generated, maintained, and submitted to EPA in a timely 

fashion. 

• EPA’s Philadelphia Office has altered the way in which it will handle 

compliance data from WASA and the Washington Aqueduct. According to 

the office, compliance data from both water systems will now be sent to 

those in the Office responsible for enforcing the Safe Drinking Water Act, 

so as to separate the enforcement/compliance assurance function from the 

municipal assistance function. 

Aside from the tap water monitoring issue, EPA’s Philadelphia Office 

acknowledges that its oversight of WASA public notification and education 

efforts could have been better, noting that “In hindsight, EPA should have 

asked more questions about the extent, coverage and impact of DC 

WASA’s public education program, and reacted to fill the public education 

gaps where they were evident.”5

 To address the problem, the Philadelphia 

Office reported on its website that it will have to make some 

improvements in the way it exercises its own oversight responsibilities.6

Suggested improvements include obtaining written agreement from WASA 

to receive drafts of education materials and a timeline for their 

submission, reviewing drafts of public education materials for compliance 

with requirements, as well as effectiveness of materials and delivery, and 

acquiring outside expertise to assist in evaluating outreach efforts. 

As our work continues, we will seek to examine (to the extent it does not 

conflict with active litigation) other ways in which improved coordination 

between WASA and EPA could help both agencies better fulfill their 

responsibilities. We will also examine interrelationships that include other 

key agencies, such as the Aqueduct and the D.C. Department of Health. We 

will also examine how other water systems in similar situations interacted 

with federal, state, and local agencies. These experiences may offer 

suggestions on how coordination can be improved among the agencies 

responsible for protecting drinking water in the District of Columbia. 

 5

Letter from William C. Early, Regional Counsel, EPA Region III, to Eric H. Holder, Jr., 

Covington & Burling (June 25, 2004) attaching EPA’s Response to May 13, 2004, letter from 

Covington & Burling, Response #26. 

6

http://www.epa.gov/dclead/pep_recommendations.htm. 
Page 9 GAO-04-974T Lead in Drinking Water 

WASA is not the first system to exceed the action level for lead. According 

to EPA, when the first round of monitoring results was completed for large 

water systems in 1991 pursuant to the Lead and Copper Rule, 130 of the 

660 systems serving populations over 50,000 exceeded the action level for 

lead. EPA data show that since the monitoring period ending in 2000, 27 

such systems have exceeded the action level.7 As part of our work, we will 

be examining the innovative approaches some of these systems have used 

to notify and educate their customers. I would like to touch on the 

activities of two such systems, the Massachusetts Water Resources 

Authority and the Portland, Oregon, Water Bureau. Each of these systems 

has employed effective notification practices in recent years that may 

provide insights into how WASA, and other water systems, could improve 

their own practices. 

The Massachusetts Water Resources Authority (MWRA) is the wholesale 

water provider for approximately 2.3 million customers, mostly in the 

metropolitan Boston area. Under an agreement with the Massachusetts 

Department of Environmental Protection, monitoring for lead under the 

Lead and Copper Rule occurs in each of the communities that MWRA 

serves and the results are submitted together. Initial system-wide tap 

water monitoring results in 1992 showed a 90th percentile lead 

concentration of 71 ppb (meaning 10 percent of its samples scored at this 

level and above). According to MWRA, adjustments in corrosion control 

have led to a reduction in lead levels, but the 90th percentile lead 

concentration in MWRA’s service area has still been above the action level 

in four of the seven sampling events since early 2000. 

According to an MWRA official, the public education program for lead in 

drinking water is designed to ensure that all potentially affected parties 

within MWRA’s service area receive information about lead in drinking 

water. He noted, for example, that while the Lead and Copper Rule 

requires that information be sent to consumers in their water bills, the 

large population of renters living in MWRA’s service area often do not 

receive water bills. Therefore, MWRA included information about lead in 

its consumer confidence report, which is sent to all mailing addresses 

within the service area. Additionally, MWRA uses public service 

 7

EPA Office of Ground Water and Drinking Water, Summary: Lead action level 

exceedences for medium (3,300-50,000) and large (>50,000) public water systems 

(Updated as of June 1, 2004). 

Experiences of Other 

Water Systems 

Highlight Effective 

Ways to Inform and 

Educate the Public 

Massachusetts Water 

Resources Authority 
Page 10 GAO-04-974T Lead in Drinking Water 

announcements, interviews on radio and television talk shows, 

appearances at city councils and other local government agency meetings, 

and articles in local newspapers to convey information. MWRA also 

conducted focus groups to judge the effectiveness of the public education 

program and continually makes changes to refine the information about 

lead in drinking water. 

An MWRA official also noted that MWRA focuses portions of its lead 

public education program on the populations most vulnerable to the 

health effects of lead exposure. For example, MWRA worked with officials 

from the Massachusetts Women, Infants and Children Supplemental 

Nutrition Program (WIC) to design a brochure to help parents understand 

how to protect their children from lead in drinking water. Among other 

things, the brochure includes the pertinent information in several foreign 

languages, including Spanish, Portuguese, and Vietnamese. The WIC 

program also includes information on how to avoid lead hazards when 

preparing formula. 

The Portland Water Bureau provides drinking water to approximately 

787,000 people in the Portland metropolitan area, nearly one-fourth of the 

population of Oregon. Since 1997, the city has exceeded the lead action 

level 6 times in 14 rounds of monitoring. According to Bureau officials, the 

problem stems mainly from lead solder used to join copper plumbing and 

from lead in home faucets. Portland’s system has never had lead service 

lines, and the Water Bureau finished removing all lead fittings within the 

water system’s control in 1998. 

The Portland Water Bureau sought flexibility in complying with the Lead 

and Copper Rule. The state of Oregon allowed the Water Bureau to 

implement a lead hazard reduction program as a substitute for the optimal 

corrosion control treatment requirement of the Lead and Copper Rule. 

Portland’s lead hazard reduction program is a partnership between the 

Portland Water Bureau, the Multnomah County and Oregon State health 

departments, and community groups. According to Portland Water Bureau 

officials, the program consists of four components: (1) water treatment for 

corrosion control; (2) free water testing to identify customers who may be 

at significant risk from elevated lead levels in drinking water; (3) a home 

lead hazard reduction program to prevent children from being exposed to 

lead from lead-based paint, dust, and other sources; and (4) education on 

how to prevent lead exposure targeted to those at greatest risk from 

exposure. 

Portland Water Bureau 
Page 11 GAO-04-974T Lead in Drinking Water 

As the components suggest, the program is focused on reducing exposure 

to lead through all exposure pathways, not just through drinking water. 

For example, the Water Bureau provides funding to the Multnomah 

County Health Department’s LeadLine—a phone hotline that residents can 

call to get information about all types of lead hazards. Callers can get 

information about how to flush their plumbing to reduce their lead 

exposure and can request a lead sampling kit to determine the lead 

concentration in the drinking water in their home. The Water Bureau also 

provides funding for lead education materials provided to new parents in 

hospitals, for billboards and movie advertisements targeted to 

neighborhoods with older housing stock, and to the Community Alliance 

of Tenants to educate renters on potential lead hazards. Each of these 

materials directs people to call the LeadLine if they need additional 

information about any lead hazard. The Water Bureau evaluates the results 

of the program by tracking the number of calls to the LeadLine, and by 

surveying program participants to determine their satisfaction with the 

program and the extent to which the program changed their behavior. 

In January 2004, the Portland Water Bureau sent a targeted mailing to 

those residents most likely to be affected by lead in drinking water. The 

mailing targeted homes of an age most likely to contain lead-leaching 

solder where a child 6 years old or younger lived. Approximately 2,600 

postcards were sent that encouraged residents to get their water tested for 

lead, learn about childhood blood lead screening, and reduce lead hazards 

in their homes. Water Bureau officials said that they obtained the 

information needed to target the mailing from a commercial marketing 

company, and that the commercial information was inexpensive and easy 

to obtain. 

In an ideal world, a water utility such as WASA would have several 

different types of information that would allow it to monitor the health of 

individuals most susceptible to the health effects of lead in drinking water. 

The utility would know the location of all lead service lines and homes 

with leaded plumbing (pipes, solder and/or fixtures) within its service 

area. The utility would also know the demographics of the residents of 

each of these homes. With this information, the utility could identify each 

pregnant woman or child six years old or younger who would be most 

likely to be exposed to lead through drinking water. These individuals 

could then be educated about how to avoid lead exposure, and lead 

exposure for each of these individuals could then be monitored through 

water testing and blood lead testing. 

WASA Faces 

Challenges in 

Identifying At-Risk 

Populations 
Page 12 GAO-04-974T Lead in Drinking Water 

Unfortunately, WASA and other drinking water utilities do not operate in 

an ideal world. WASA does have some information on the location of lead 

service lines within its distribution area. Its predecessor developed an 

inventory of lead service lines in its distribution system in 1990 as part of 

an effort to identify sampling locations to comply with the Lead and 

Copper Rule. According to WASA officials, identifying the locations of lead 

service lines was difficult because many of the records were nearly 100 

years old and some of the information was incomplete. According to this 

1990 inventory, there were approximately 22,000 lead service lines. WASA 

updated the inventory in September 2003, and estimated that it had 23,071 

“known or suspected” lead service lines. WASA subsequently identified an 

additional 27,495 service lines in the distribution system made of 

“unknown” materials. Consequently, there is some uncertainty over the 

actual number and location of the lead service lines in WASA’s distribution 

system. The administrative order that EPA issued in June 2004 requires 

WASA to further update its inventory of lead service lines. 

Regardless of the information WASA has about the location of lead service 

lines, according to WASA officials, WASA has little information about the 

location of customers who are particularly vulnerable to the effects of 

lead. The District’s Department of Health is responsible for monitoring 

blood lead levels for children in the District. Officials from the Department 

of Health told us that they maintain a database of the results of all 

childhood blood lead testing in the District, and have studied the 

distribution of blood lead levels in children on a neighborhood basis. 

However, according to a joint study by the D.C. Department of Health and 

the Centers for Disease Control and Prevention (CDC) published in March 

2004, it is difficult to discern any effect of lead in drinking water on 

children’s blood lead levels because the older homes most likely to have 

lead service lines are also those most likely to have other lead hazards, 

such as lead in paint and dust. This joint study also described efforts by 

the Department of Health and the United States Public Health Service to 

conduct blood lead monitoring for residents of homes whose drinking 

water test indicated a lead concentration greater than 300 ppb. None of the 

201 residents tested were found to have blood lead levels exceeding the 

levels of concern for adults or children, as appropriate. 
Page 13 GAO-04-974T Lead in Drinking Water 

A good deal of research has been conducted on the health effects of lead, 

in particular on the effects associated with certain pathways of 

contamination, such as ingestion of leaded paint and inhalation of leaded 

dust. In contrast, the most relevant studies on the isolated health effects of 

lead in drinking water date back nearly 20 years—including the Glasgow 

Duplicate Diet Study on lead levels in children upon which the Lead and 

Copper Rule is partially based.8

 According to recent medical literature and 

the public health experts we contacted, the key uncertainties requiring 

clarification include the incremental effects of lead-contaminated drinking 

water on people whose blood lead levels are already elevated from other 

sources of lead contamination and the potential health effects of exposure 

to low levels of lead. As we continue our work, we will examine the plans 

of EPA and other organizations to fill these and other key information 

gaps. 

Lead is a naturally occurring element that, according to numerous studies, 

can be harmful to humans when ingested or inhaled, particularly to 

pregnant and nursing women and children aged six or younger. In 

children, for example, lead poisoning has been documented as causing 

brain damage, mental retardation, behavioral problems, anemia, liver and 

kidney damage, hearing loss, hyperactivity, and other physical and mental 

problems. Exposure to lead may also be associated with diminished 

school performance, reduced scores on standardized IQ tests, 

schizophrenia, and delayed puberty. 

Long-term exposure may also have serious effects on adults. Lead 

ingestion accumulates in bones, where it may remain for decades. 

However, stored lead can be mobilized during pregnancy and passed to 

the fetus. Other health effects in adults that may be associated with lead 

exposure include irritability, poor muscle coordination and nerve damage, 

increased blood pressure, impaired hearing and vision, and reproductive 

problems. 

There are many sources of lead exposure besides drinking water, 

including the ingestion of soil, paint chips and dust; inhalation of lead 

particles in soil or dust in air; and ingestion of foods that contain lead from 

soil or water. Extensive literature is available on the health impacts of lead 

exposure, particularly from contaminated air and dust. CDC identified in a 

 8

Lacey R.F., et al. Lead in Water, Infant Diet and Blood: The Glasgow Duplicate Diet Study. 

The Science of the Total Environment, 41 (1985) 235-257. 

Researchers Face 

Gaps in Knowledge 

Regarding the Risks 

Posed by Lead in 

Drinking Water 
Page 14 GAO-04-974T Lead in Drinking Water 

December 2002 Morbidity and Mortality Weekly Report the sources of 

lead exposure for adults and their potential health effects.9

 In a September 

2003 Morbidity and Mortality Weekly Report, CDC identified the most 

prevalent sources of lead in the environment for children, and correlated 

high blood lead levels in children with race, sex, and income bracket.10 The 

surveys suggest that Hispanic and African-American children are at 

highest risk for lead poisoning, as well as those individuals who are 

recipients of Medicaid. Dust and soil contaminated by leaded paint were 

documented as the major sources of lead exposure. Children and adults 

living in housing built before 1950 are more likely to be exposed to lead 

paint and dust and may therefore have higher blood lead levels. 

Articles in numerous journals have reported on the physical and 

neurological health effects on children of lead in paint, soil, and dust. The 

New England Journal of Medicine published an article in April 2003 that 

associated environmental lead exposure with decreased growth and 

delayed puberty in girls.11 In 2000, the Journal of Public Health Medicine

examined the implications of lead-contaminated soil, its effect on produce, 

and its potential health effects on consumers.12 Lead can also enter 

children’s homes if other residents are employed in lead contaminated 

workplaces. In 2000, Occupational Medicine found that children of 

individuals exposed to lead in the workplace were at higher risk for 

elevated blood lead levels.13 The EPA has aided in some similar research 

through the use of its Integrated Exposure Uptake Biokinetic Model for 

 9

Centers for Disease Control and Prevention. Morbidity and Mortality Weekly Report: 

Adult Blood Lead Epidemiology and Surveillance – United States 1998-2001. 13 

December 2002. 

10Centers for Disease Control and Prevention. Morbidity and Mortality Weekly Report: 

Surveillance for Elevated Blood Lead Levels Among Children – United States 1997-2001. 

12 September 2003. 

11Sherry G. Selevan, Deborah C. Rice, Karen A. Hogan, Susan Y. Euling, et al. “Blood lead 

concentration and delayed puberty in girls.” The New England Journal of Medicine. 

Boston: Apr 17, 2003. Vol. 348, Iss. 16; pp. 1527-1536. 

12Prasad LR, Nazareth B. “Contamination of Allotment Soil with Lead: Managing Potential 

Risks to Health.” Journal of Public Health Medicine. 22(4) December 2000: 525-30. 

13Chan, J, et al. “Predictors of Lead Absorption in Children of Lead Workers.” Occupational 

Medicine. Vol 50, Issue 6, 398-405, 2000. 
Page 15 GAO-04-974T Lead in Drinking Water 

Lead in Children (IEUBK). This model predicts blood lead concentrations 

for children exposed to different types of lead sources.14

According to a number of public health experts, drinking water 

contributes a relatively minor amount to overall lead exposure in 

comparison to other sources. However, while lead in drinking water is 

rarely thought to be the sole cause of lead poisoning, it can significantly 

increase a person’s total lead exposure—particularly for infants who drink 

baby formulas or concentrated juices that are mixed with water from 

homes with lead service lines or plumbing systems. For children with high 

levels of lead exposure from paint, soil, and dust, drinking water is thought 

to contribute a much lower proportion of total exposure. For residents of 

dwellings with lead solder or lead service lines, however, drinking water 

could be the primary source of exposure. As exposure declines from 

sources of lead other than drinking water, such as gasoline and soldered 

food cans, drinking water will account for a larger proportion of total 

intake. Thus, according to EPA, the total drinking water contribution to 

overall lead levels may range from as little as 5 percent to more than 50 

percent of a child’s total lead exposure.15

Mr. Chairman, this completes my prepared statement. I would be happy to 

respond to any questions you or other Members of this Subcommittee may 

have at this time. 

For further information, please contact John B. Stephenson at (202) 512-

3841. Individuals making key contributions to this testimony included 

Steve Elstein, Samantha Gross, Karen Keegan, Jessica Marfurt, and Tim 

Minelli. 

 14U.S. Environmental Protection Agency. The IEUBK Model 

http:www.opa.gov/superfund/programs/lead/ieubk.htm 16 April 2004. 

15U.S. Environmental Protection Agency. Lead and Copper Rule. The Federal Register. Vol. 

56 NO. 110, 7 June 1991. 

Contact and 

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