Academy Comments to EPA re: Lead and Safe Water

March 6, 2017

Erik Helm
U.S. Environmental Protection Agency
Office of Ground Water and Drinking Water
Standards and Risk Management Division
(Mail Code 4607M)
1200 Pennsylvania Avenue NW
Washington, DC 20460

Re: Peer Review Materials To Inform the Derivation of a Water Concentration Value for Lead in Drinking Water (Docket ID No. EPA-HQ-OW-2016-0686)

Dear Sir or Madam,

The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the U.S. Environmental Protection Agency (EPA) related to its open docket regarding "Peer Review Materials To Inform the Derivation of a Water Concentration Value for Lead in Drinking Water (Docket ID No. EPA-HQ-OW-2016-0686)," published in the Federal Register on January 19, 2017.  Representing over 100,000 registered dietitian nutritionists (RDNs),1 nutrition dietetic technicians, registered (NDTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States and is committed to improving the nation's health through food and nutrition and to advancing the public health through sensible measures to ensure a potable, sustainable water supply for all Americans.

The Academy strongly supports the proposed regulatory revisions to improve public health protections, especially in light of the fact that no safe lead exposure level can be established. Moreover, clinical treatment options are limited or absent, especially to the populations most affected. Our members look forward to utilizing forthcoming research results to help realize the public's right to a safe drinking water supply.

A. Academy of Nutrition and Dietetics' Commitment to Water Safety

It is the position of the Academy that all people should have access to a safe water supply.2 Lead contamination of water supplies is entirely preventable, yet the United States experiences significant economic costs, loss of productivity (2.4% per lost IQ point) and reduced quality of life as a result.3  In 2015, over 1,100 water systems supplied drinking water containing lead in excess of the current EPA Action Level (15 ppb) to 3.9 million people.4 This indicates potentially over 300,000 children under age seven are exposed to such water on a daily basis5. Moreover, no safe level of exposure has been found.6 Thus, based on clear evidence of harm (and readily-available technology), the Academy fully supports the EPA's efforts to further substantiate the critical need to revise the drinking water Action Level downward.

B. The Costs of Inaction

The costs of childhood lead poisoning (from all sources) in the U.S. exceed $43 billion per year.7 Remediating drinking water sources of lead contamination would provide a return-on-investment ratio of at least 4:1, and perhaps as much 200:1 or more.8,9 EPA should also provide water systems adequate guidance and support to implement such measures.

Moreover, low-income communities are more likely to bear the burden of contaminated water supplies.10  While effective, affordable filtration is available,11 these communities may be unable to access it. Additionally, the Academy's recommendation that children favor water over sugar-sweetened beverages12 presumes potable water is available. Thus, concerns that low-income children may have higher intakes of sugar-sweetened beverages13 are compounded by the likely absence of a potable, healthy, low-cost option.

C. Conclusion

The Academy appreciates the opportunity to comment on the draft report related to "Peer Review Materials To Inform the Derivation of a Water Concentration Value for Lead in Drinking Water," and we will continue to be active at the intersection of public health and nutrition, both by encouraging research and by ensuring our members are engaged on these issues.  Please contact either Jeanne Blankenship at 312-899-1730 or by email at jblankenship@eatright.org or Pepin Tuma at 202-775-8277 ext. 6001 or by email at ptuma@eatright.org with any questions or requests for additional information.

Sincerely,

Jeanne Blankenship, MS, RDN
Vice President
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics

Pepin Andrew Tuma, Esq.
Senior Director
Government & Regulatory Affairs
Academy of Nutrition and Dietetics


1 The Academy approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation's food and nutrition experts.  The RD and RDN credentials have identical meanings and legal trademark definitions.

2 Cody MM, Stretch T. Position of the Academy of Nutrition and Dietetics: food and water safety. J Acad Nutr Diet. 2014;114(11):1819-29.

3 Childhood Lead Poisoning. WHO. Accessed February 28, 2017.

4 Olson E,. Fedinick KP. What's in your water? Flint and beyond: Analysis of EPA data reveals widespread lead crisis. Natural Resources Defense Council. Available at Accessed February 28, 2017.

5 Based on calculation of proportion of children in the U.S. as indicated at Federal Interagency Forum on Child and Family Statistics (accessed February 28, 2017) relative to 3.9 million people out of total U.S. population of 319 million.

6 Rauch SA, Lanphear BP. Prevention of Disability in Children: Elevating the Role of Environment. Future Child. 2012 Spring;22(1):193-217.

7 Childhood Lead Poisoning. WHO. Accessed February 28, 2017.

8 Schwartz j. Societal benefits of reducing lead exposure. Environ Res.  1994 Jul;66(1):105-24.

9 Childhood Lead Poisoning. WHO. Accessed February 28, 2017.

10 Olson E,. Fedinick KP. What's in your water? Flint and beyond: Analysis of EPA data reveals widespread lead crisis. Natural Resources Defense Council. Accessed February 28, 2017.

11 EPA Water Health Series: Filtration Facts. Accessed February 28, 2017.

12 Hard Facts About Soft Drinks. Accessed February 28, 2017.

13 Ogata BN, Hayes D. Position of the Academy of Nutrition and Dietetics: Nutrition Guidance for Healthy Children Ages 2 to 11 Years. J Acad Nutr Diet. 2014;114:1257-1276.