NEW ROCHELLE, NY -- In a letter to parents of students at George M. Davis Elementary School, Principal Michael Galland offered reassurance to parents, claiming that the elevated level of lead found in a water sample taken from one drinking fountain on March 29, 2016 was not that bad by comparing the result with the Flint Water Crisis in Michigan.
“The presence of lead in the water from this one water fountain was measured at 47.2 pbb, or parts per billion. (The levels at Flint, Michigan were 10,000 ppb.) The EPA threshold number is 15 ppb.”
“Not Flint” has been a common refrain from New Rochelle school officials, a refrain repeated by parents and even elected city officials, in public meetings and in the media.
Comparing Davis School to Flint is comparing apples to watermelons; Davis is about results in a particular section of a school impacting a narrow group of students whereas Flint is about a citywide water system impacting over 100,000 residents. If, however, officials want to keep making that comparison, it would first be necessary to work through the data to make apples to apples comparisons.
Let’s start here: it is entirely misleading to say that the lead levels in Flint “were 10,000 ppb” as if all the lead level were this high. In fact, most levels were below the EPA threshold level and one sample had this sort of off-the-chart results.
The Genesee (MI) County Health Department reported what CNN called “one, worst-care result”, Rosemary Vernon’s home tested at more than 10,000 ppb on February 6, 2016 - a water-lead level of 13,200 ppb. This sample is not even remotely the norm.
Writing about Flint, Michigan, USA Today said “the struggling city of about 100,000 people passed the government’s required lead tests. But one resident’s vocal complaints (Rosemary Vernon) spurred extra tests at her home, revealing shocking levels of lead contamination: 104 to 13,200 ppb. The crisis worsened as independent researchers (from Virginia Tech) tested 300 samples across the city, revealing homes with high lead levels that the government-mandated tests missed. More than 10% contained at least 27 ppb of lead. Since then, regulators conducted another 15,000 tests. More than 1,000 samples show lead above the 15 ppb limit, and more than 400 show dangerous levels above 40 ppb."
To say that the Flint results were 10,000 ppb is to ignore that the crisis in Flint, Michigan is not about one shocking water-lead levels but that systemwide there was a high percentage of water-lead levels about 5 ppb and above the EPA action threshold of 15 ppb.
On March 1, 2016, The Flint Journal reported that 37 of 423 (9%) recently tested sites had results above the 15 ppb limit. Eight of the samples exceeded 100 ppb (2%).
“More than 8 percent of homes continue to exceed the federal action guidelines for lead, according to the most-recent round of water sampling data from the state.”
Put another way, 92% of homes did not exceed the federal action guidelines for lead. Given this, again, it is important to understand that the Flint Water Crisis is not about every home having lead levels over 10,000 ppb but that a large number of homes (8%) had elevated levels of lead over the EPA threshold of 15 ppb.
The crisis has been largely defined by two major independent studies: (2) the Hurley Medical Center study which looked at elevated levels of lead in the blood of children in Flint; (2) the Virginia Tech Research Team study, a team lead by an expert on municipal water quality operating under a National Science Foundation grant which collected and analyzed 813 water samples taken by Flint residents in 300 homes. Talk of the Sound downloaded and analyzed this data (see below).
The Flint Water Crisis was initially about discolored water after the water source was switched, then it was about chemicals in the water meant to address the water discoloration, some of those chemicals released lead in corroded pipes, This was not immediately identified as a problem because the lead in the water does not give off an odor or taste.
Flint turned into a lead issue as the result of blood testing after a pediatrician began noticing elevated blood-lead levels in children.
The Hurley Medical Center blood level study was initially dismissed by the Michigan Department of Environmental Quality which claimed Flint water tested within acceptable levels. The report was later published in the February 2016 issue of American Journal of Public Health. Today, the report is seen as definitive on the issue and state officials have apologized for dismissing it. The study found that the average proportion of Flint children with elevated blood-lead levels more that doubled from 2013, before the Flint water source changed, until 2015, after the water source changed. This study on blood-lead levels took the story from a local water problem to a national and global news story.
The Virginia Tech Research Team study was the first to offer an independent look at water-lead levels on a large scale and found that at least a quarter of Flint households had levels of lead above the federal level of 15 ppb — and that one sample was 1,051 ppb.
“Of the 252 first draw samples collected by Flint residents and analyzed at VT, 40.1% were over 5 ppb, which suggests a serious lead in water problem according to our experience and criteria. Forty two samples (16.7% of the 252 samples collected) also exceeded 15 ppb lead action limit, suggesting a very serious lead in water problem. That is, the Flint Citizen Science study to date, is finding results worse than the EPA standard which is applied to sampling “worst case” homes. The highest lead sampled in first draw so far was 158 ppb, and the highest sample after 45-seconds of flushing was 1,051 ppb. The 90th percentile lead level is currently 25.2 ppb, which is over the EPA standard applied to homes with “worst case” lead plumbing, and in a range where water consumption has caused lead poisoning in children and led to adverse pregnancy outcomes. Needless to say, these data are very worrisome, especially considering that our survey did not target “worst case” lead plumbing systems as is required for EPA sampling.”
The Flint Water Crisis is fundamentally different than the Davis School situation. In Flint, water at the source was contaminated with various chemicals, and efforts to address those issues caused lead in pipes to be released. It was a city-wide event, at the source, which unfolded on a known timeline and bears little relation to the situation at Davis Elementary where school officials do not know what caused lead to be in the water or for how long lead was in the water.
Making the comparison between Flint and Davis, and concluding that Davis is not a problem because Flint had one off-the-chart sample, is like saying that being exposed to repeated x-rays is not a problem because it is not as if the person were residing in a home at Chernobyl. They are both a problem, in their own way.
As school officials continue to make the comparison anyway, it is worth nothing that on a relative basis the situation at Davis Elementary School is far worse than Flint.
Before exploring that further, it should be noted that the Newark School lead crisis was cited by New Rochelle Schools Superintendent Dr. Brian Osborne as the proximate cause of his decision to test all the water in the district. It is also cited in the Louis Berger study commissioned by the district.
"As a pro-active and voluntary measure, the CSDNR requested that Louis Berger conduct testing of drinking water for all schools in the district. The request was in response to public concerns raised by the revelation of elevated levels of lead in drinking water in the Newark, NJ schools. Louis Berger conducted the district-wide testing of all of the CSDNR schools on March 23 and March 29, 2016.
That test was then expanded after elevated levels of lead were found in two samples at Davis (13 ppb and 47 ppb), where the second sample exceeded the EPA threshold of 15 ppb).
On March 9, 2016, the New Jersey Department of Environmental Protection released the results of water-lead testing at 31 schools in the Newark School District. Unlike the Virginia Tech study the NJDEP did not provide a database containing the full set of results but rather a summary document indicating only up to 4 samples but only for samples that exceeded the EPA threshold of 15 ppb. Talk of the Sound was able to obtain the original lab reports for water testing at each school. In order to compare the data from Flint, Newark and Davis, each report was manually entered into a database by Talk of the Sound.
In a letter to parents on April 29th, Davis Principal Michael Galland again sought to reassure parents by fundamentally mischaracterizing the results of the first sample.
"The district initially tested water at various locations in each school and found that a drinking fountain in our library hallway contained levels of lead in the water that slightly exceeded the EPA threshold of 15 parts per billion (ppb)...We received the results of the additional tests over this vacation week. In all, 35 additional drinking fountains and sinks were tested. 28 tests produced results below the EPS threshold of 15 ppb and seven results were above the threshold.
The sample from the drinking fountain in the library hallway was 47.2 which is not "slightly" exceeding but more than three times the EPA threshold and in excess of what the Virginia Tech Research Team considers "dangerously high".
Galland failed to provide the data on the other seven results above the EPA threshold -- and with good reason as some of them are shockingly high (18 ppb, 18.4 ppb, 21 ppb, 65.1 ppb, 111 ppb, 117 ppb, and 701 ppb). Of the 36 "first draw" test results, 8 (25%) were above the EPA threshold, 4 (11%) were above the "dangerous" threshold, 3 (8%) were above 100 parts per billion. These are big numbers by any measure.
With all three data sets, sorted and organized, some comparisons can be made.
The highest reading in the Virginia Tech study of Flint, Michigan was 1,051 ppb level, the next highest level was 259.8. The highest reading in the NJ DEP study of Newark Schools was 1,390 ppb, the next highest level was 558. For Davis School, the highest level was 701 ppb, the next highest level was 117. What this data shows is that there were no results like the one off-the-charts sample at the home of Rosemary Vernon and even when there is one high level, the next highest level is well below even that high level. While the media likes to report the highest level recorded, the data shows that even where there is one outlier, the next highest result is far lower.
To compare Flint and Newark with Davis, four thresholds can be compared.
5 ppb: suggests a serious lead in water problem, according to the Virginia Tech Research Team
15 ppb: is the action threshold, according to the EPA
20 ppb: is the action threshold for schools, according to the EPA
40 ppb: "dangerous level of lead", according to the Virginia Tech Research Team
Flint (Virginia Tech Study)
211 of 813 above 5 ppb = 26%
75 of 813 above 15 ppb = 9%
59 of 813 above 20 ppb = 7%
26 of 813 above 40 ppb = 3%
Newark (NJ DEP Study)
117 of 284 above 5 ppb = 41%
55 of 284 above 15 ppb = 19%
42 of 284 above 20 ppb = 15%
18 of 284 above 40 ppb = 6%
Davis (Louis Berger Study)
27 of 36 above 5 ppb = 75%
8 of 36 above 15 ppb = 22%
6 of 36 above 20 ppb = 17%
5 of 36 above 40 ppb = 14%
By any of these measures, - and the numbers speak for themselves - the levels at Davis, on a relative basis, are far worse than Flint or Newark, 2 to 4 times worse.
Comparing an entire municipal water system or even 31 schools in one district to Davis is not the comparison Talk of the Sound would make and we are actively discouraging that comparison.
Those who are making that comparison, in a misguided attempt to reassure parents and staff, would do well to consider that the comparison is not a favorable one. The Davis data is far worse than Flint and Newark.
What makes the comparison even less appropriate is that while the problem in Flint and Newark is widespread, the issues at Davis are isolated in a particular section of the building (and Davis is just one building out of 11 tested in New Rochelle). The Davis situation can be entirely resolved by replacing pipes, sinks and fountains in one section of the building, if that is deemed necessary.
The unique concern at Davis is two-fold: (1) there was no baseline testing prior to March 2016 going back to the construction of the building in 1952 and so no way to know how long lead in the water at Davis has been a problem or how many students were effected over the years; (2) there has been no blood-level testing so no way to know what the impact has been on students and staff and how far back it goes.
The current position of the district, based on statements by the Westchester County Department of Health and an expert doctor, is that there is no need for blood-lead testing of students or staff. The district has offered no reasoning behind the conclusion that blood-lead testing is not necessary.
The district currently recommends that if parents are concerned they should consult their pediatrician. The problem with this is that by minimizing the issue as has been indicated here, the district is telling parents there is no reason to be concerned and thus no reason for blood-testing. Even if parents do have their children tested, the district will not have access to that data and cannot make the sort of assessment made in the Hurley Medical Center study which was so important in the Flint Water Crisis.
Testing blood-lead levels is not part of a standard blood work up during an annual physical so few parents would have this sort of information about their child. Many might assume lead testing is being done. Given that blood-lead level testing is simple, quick and cheap, it is difficult to understand why testing would be actively discouraged, as has been the case, when the cost of testing is extremely low and the cost of undetected lead poisoning in children and pregant women is extremely high.