Policy and Position Statements

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Safe and Reliable Drinking Water Position Statement

I. ASTHO believes that everyone in the United States should have access to safe and reliable drinking water regardless of their geographic location, income, education, racial, or ethnic background.

ASTHO supports continued efforts by federal, state and local agencies responsible for safe and reliable drinking water to assure the protection of the public’s health. The following principles outline what ASTHO believes should be the focus of future efforts by the U.S. Environmental Protection Agency (EPA) and state and territorial (S/T) health and environmental agencies to protect public health by ensuring safe drinking water.

II. Overarching Public Health Principles

Support for uniform standards to protect health

To promote health equity and environmental justice, ASTHO believes that there should be one consistent set of drinking water standards for the protection of all Americans. In the past, proposals were considered that had the potential to create a two-tiered system of maximum contaminant levels for water systems based on affordability. However, a two-tier system would result in health disparities across communities and states. Uniform optimum public health protection standards for everyone in the United States and U.S. territories must remain the focus.

Support for primary prevention, source water protection and other cost-effective approaches to protect public health

The United States has one of the safest drinking water supplies in the world, but there are still continued and emerging challenges that need to be addressed. These challenges include an aging infrastructure, emerging chemical and microbial contaminants, nutrient overloading, harmful algal blooms, and climate change. To confront these issues, the United States needs to use primary prevention methods to protect drinking water systems by preventing contamination of drinking water supplies, improving water treatment and distribution infrastructure, developing sustainable and reasonable regulations for all water systems, increasing data sharing to better inform public health policy, and developing effective methods for communicating water quality information and any health risks associated with drinking water supplies.

ASTHO supports future regulatory initiatives by EPA that maintain a clear focus on cost-effective health risk reduction and meaningful opportunities to protect human health. When pursuing strategies to regulate contaminants by groups rather than one at a time1, EPA should consider the most toxic contaminants in each group when developing these regulations.

ASTHO and its partners, including those organizations represented on the National Drinking Water Advisory Council,2 strongly support the use of multiple statutes to protect drinking water, such as the Federal Insecticide, Fungicide, and Rodenticide Act, the Resource Conservation and Recovery Act, and the Clean Water Act, to more carefully examine the fate and transport of harmful chemicals through the environment, and to prevent them from entering water bodies in the first place.

Support for health advisory levels to enhance public health protection

As stated in ASTHO’s contribution to the National Conversation on Public Health and Chemical Exposures3, scientists need a better understanding of chemicals, their fate and transport, and how they can impact human health. When health risk assessment and exposure analysis reports are available, ASTHO urges EPA to consider creating more health advisory levels as developed by some states, similar to the California Health Advisory Levels, which can be used to assure adequate health protection when traces of uncommon, potentially toxic chemicals are detected in drinking water.

Support for enhanced collaboration between state and local governments

ASTHO strongly supports enhanced collaboration between state and local government agencies to ensure safe drinking water. S/T health agencies and departments of environmental quality or natural resources need to enhance collaboration and coordination of public health and environmental programs and resources to enhance drinking water protection. However, land-use and development decisions are largely made at the local level and play an important role in determining how various contaminants enter water bodies from point and non-point sources impacting drinking water sources. Therefore, local governments are also a key component in source water primary protection efforts.

It is also important to implement a Health in All Policies approach throughout these efforts. This could include, for example, reaching out to new partners and stakeholders outside of health that can influence programs or policies impacting water quality or quantity, or conducting a health impact assessment of proposed changes to a water system to better understand potential health impacts of the decision.

III. Protection from Nutrient Contamination

Nutrient contamination is a nationally important issue that needs to be addressed through greater primary prevention efforts at all levels of government. High nitrate levels in drinking water have been linked to methemoglobinemia (a decrease in the oxygen-carrying capacity of red blood cells), which causes serious illness and sometimes death in infants, as well as other potential human health effects4. In addition, nutrient fed algal blooms can release harmful algal toxins and also serve as organic matter that can react, in a water treatment system, to form carcinogenic disinfection by-products. Nutrient overloading in U.S. waterways has been caused by a number of sources, including: row crops, agricultural livestock activities, municipal wastewater treatment systems, urban and suburban stormwater runoff, and air deposition.

Preventing nutrient overloading will require collaboration at all levels of government including, but not limited to, the following:

  • State and federal governments should use the enforcement capacity of the Clean Water Act and Safe Drinking Water Act to address nutrient pollution.
  • ASTHO supports increased waste disposal oversight on concentrated animal feeding operations. The U.S. Department of Agriculture must be an involved federal partner, working in close collaboration with EPA and the U.S. farming community, to implement best management practices to reduce contamination from row crops and agricultural livestock activities. On the state level, states can utilize water quality trading* and regional collaboration to improve shared water bodies (e.g., Chesapeake Bay).
  • Local governments and development groups should utilize health impact assessment tools and smart growth principles to help inform future land-use and development decisions to protect drinking water sources.

*The water quality trading approach requires a target load or water quality standard in order to generate “credits” or have some idea of how many pounds are available for trading in a particular watershed. The process is usually implemented through a National Pollutant Discharge Elimination System (NPDES) permit.

IV. Small Water Treatment System Sustainability

Small systems serving communities with populations of 3,300 or fewer, represent 94 percent of total regulated community water systems in the United States and serve roughly 13 percent of the population.5 Small systems typically have more limited economies of scale, as compared to larger systems, and often face challenges in terms of their technical, managerial, and financial capacity.  State drinking water program administrators must be extremely sensitive to the needs of small water systems and work closely with these systems in the implementation of the requirements of the Safe Drinking Water Act. Due to the economic and technical challenges, small systems comprise a large proportion of compliance problems and significant resources are utilized to build small system capacity.6

Affordability issues must also be considered in the rule making process itself with appropriate time frames for the implementation of new drinking water rules that impact small water systems. However, as noted earlier, two-tier regulatory levels – one for small systems and a different, more protective level for other systems, should not be an outcome of the rulemaking process. Additionally, infrastructure financing options, such as state revolving loan funds and capital loans to help address new requirements, should continue to be made available to assist small systems in order to achieve compliance with new health-based standards and greater financial viability. In order to improve system capacity with limited resources, S/T health agencies should encourage water system partnerships (ranging from shared equipment and management to acquisition) where feasible.

V. Increased Data Sharing and Effective Communication

ASTHO believes that sharing water monitoring data with all levels of government and the public will help strengthen the public’s understanding of scientific bases of water quality and support better public health policy.

  • ASTHO recommends that EPA work closely with S/T health and environmental agency partners to improve data sharing capabilities, communications, and technology between states and the federal government, without putting an onerous burden on already strained state resources and staff.
  • ASTHO recommends that EPA work toward gathering sufficient data and information to reduce the uncertainty of the potential for human health effects in the rule development process, wherever possible and appropriate.
  • Careful and thoughtful communication of the data to the public is absolutely necessary to provide context and understanding of the information provided. Federal, state, and local health agencies must work together to employ thoughtful risk communication and messaging when water quality data is posted publicly­­­­­­­­­­­­­­­­­­.

VI. Recognize Importance of Federal Funding for Safe Drinking Water Oversight

States and territories are highly reliant on sustained federal funding to support the on-going oversight of public water supplies. ASTHO recognizes that funding for two federal programs administered by EPA are particularly important: the Public Water Supply Supervision grant and the Drinking Water State Revolving Fund, as authorized under the Safe Drinking Water Act. These funds are essential to ensure the on-going oversight of the public water systems that serve our citizens.


Approval History

ASTHO Position Statements relate to specific issues that are time sensitive, narrowly defined, or are a further development or interpretation of ASTHO policy. Statements are developed and reviewed by appropriate Policy Committees and approved by the ASTHO Executive Committee.  

Environmental Health Policy Committee Review and Approval: January 2016
Executive Committee Review and Approval: March 2016
Policy Expires: March 2019


Notes

  1. Environmental Protection Agency, Office of Water. A New Approach to Protecting Drinking Water and Public Health. March 2010. Available at: http://www.epa.gov/safewater.
  2. EPA National Drinking Water Advisory Council. Letter to Administrator Lisa Jackson. September 8, 2010. Available at: http://water.epa.gov/aboutow/ogwdw/ndwac/upload/letter_ndwac_admin-09-08-10-drinking-water-strategy.pdf.
  3. Association of State and Territorial Health Officials. Chemical Exposures: State Ideas for Safeguarding Health. August 2010. Available at: http://www.astho.org/Display/AssetDisplay.aspx?id=5150.
  4. State-EPA Nutrient Innovations Task Group. An Urgent Call to Action: Report of the State-EPA Nutrient Innovations Task Group. August 2009. Available at: http://www.epa.gov/waterscience/criteria/nutrient/nitgreport.pdf.
  5. Environmental Protection Agency. Providing Safe Drinking Water in America: 2007/2008 National Public Water Systems Compliance Report. June 3, 2010. Available at: http://www.epa.gov/compliance/resources/reports/accomplishments/sdwa/sdwacom2007.pdf.
  6. Environmental Protection Agency. Providing Safe Drinking Water in America: 2007/2008 National Public Water Systems Compliance Report. June 3, 2010. Available at: http://www.epa.gov/compliance/resources/reports/accomplishments/sdwa/sdwacom2007.pdf.