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Drinking Water: EPA Could Use Available Data to Better Identify Neighborhoods at Risk of Lead Exposure

GAO-21-78 Published: Dec 18, 2020. Publicly Released: Dec 18, 2020.
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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

Diagram showing how water lines connect to a home.

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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

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)
Open – Partially Addressed
Based on input from EPA in December 2022, this recommendation is partially implemented. EPA's 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 child care 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 will confer with EPA further on this matter.
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)
Open – Partially Addressed
Based on input from EPA in December 2022, this recommendation is partially implemented. EPA's "Guidance for Developing and Maintaining a Service Line Inventory" includes a section on inventory planning that 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 will confer with EPA further on this matter.
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)
Open
In March 2023, EPA reiterated its disagreement with our recommendation and stated that it believes the agency has satisfied WIIN Act requirements. However, we maintain that the recommendation is still warranted because EPA's Strategic Plan for Targeted Outreach to Populations Affected by Lead does not address all of the WIIN Act's requirements and does not meet leading practices for strategic plans. For example, EPA's plan does not address education, technical assistance, or risk communication. Rather, the plan only discusses actions to disseminate information to households after EPA has learned of certain lead action level exceedances. EPA officials stated that the agency had also developed a proposed National Primary Drinking Water Regulation to implement ways to protect citizens from lead in drinking water. However, the proposed regulation is not a strategic plan and does not include all of the elements required by the WIIN Act for the strategic plan. Implementing our recommendation would give EPA greater assurance that it has effectively planned for how to communicate to the public the risks of lead in drinking water.
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)
Closed – Implemented
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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Topics

CensusCommunitiesHousingLead poisoningPotable waterSafe drinking waterStrategic planWater pipelinesWater quality standardsWater systems