&EPA
United States
Environmental Protection
Agency
Office of Water
Washington DC 20460
EPA 570/9-88-002
March 1988
Handbook for
Special Public Notification
for Lead
For Public Drinking Water
Suppliers
-------
Handbook for Special Public Notification
for
LEAD
lor
Public Drinking Wafer Suppliers
Off ice of Water
United States Environmental Protection Agency
Washington, D.C.
March 1988
EPA 570/9-88-002
-------
ACKNOWLEDGEMENT
This handbook was prepared for U.S. Environmental Protection Agency under Grant No.
T007287-01. Ms. Patricia Ritchey and Ralph Langemeier, EPA Project Officers, Region 7,
provided valuable guidance to the project. This handbook was compiled under the direction of
Sandra Hick,Ed.D., Division of Continuing Education, the University of Kansas with assistance
from Rex Buchanan, Assistant Director of Public Affairs, Geological Survey, the University of
Kansas.
The authors wish to thank Mr. Carl Reeverts and Mr. Craig Damron, EPA Office of Drinking Water,
Washington, D.C. for their significant assistance in developing and reviewing this handbook.
-------
CONTENTS
Page
1
Special Public Notification for Lead 1
Purpose and Content of this Handbook 2
Special Public Notice for Lead 3
Overview 3
2 What Information Must be Included in 8
the Special Public Notification for Lead
A Checklist of Public Notice Requirements Pertaining to Lead 1 3
3 Guidelines for Presentation of Information 14
Types and Examples of Special Public 19
Notice for Lead
Notices by Mall 20
Formal letter 22
Notices by Hand Delivery 24
Doorknob hanger 2 5
Posted Notices 27
Posted notice 29
Newspaper Notices 31
News release 36
Legal notice 38
Proof of Publication 39
40
A. Glossary 41
B. Mandatory Health Effects Language 42
C. Checklist of Public Notice Requirements Pertaining to Lead 43
D. Checklist of Currently Available Methods for Mitigating 44
Lead Content In Drinking Water
E. Safe Drinking Water Act - Section 1417: "Lead Ban" Requirements 45
F. Federal Register • Primary Drinking Water Regulations 47
G. EPA Regional Organization 52
H. State Public Notice for Lead 53
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Introduction
Special
Public Notification
for Lead
Congress has made clear the purpose
of the special public notification requirement for
lead. As stated in the Safe Drinking Water Act,
notice is to be given to persons who "may be
affected by lead contamination of their drinking
water," where such contamination results from
either:
(1) the lead content In the construction
materials of the public water
distribution system; and/or
(2) a water supply that Is corrosive
enough to cause leaching of lead.
The federal government, through the
Environmental Protection Agency, has
established specific regulations for notifying the
public.
Handbook for Special Public Notification for Lead
-------
Introduction
NOTE!
Purpose and Content
of this Handbook
The purpose of this handbook is to take
you, step by step, through the process of
making the special public notification pertaining
to lead in drinking water. This book tells you:
• What information you must
provide to the public about
lead, even when there has been
no violation of the drinking
water standards for lead;
• The different types of notices,
along with examples of each;
• The kind of information that
should be included in a public
notice.
This handbook also includes a:
• glossary of technical
terms and acronyms
(Appendix A);
• copy of the portion of the
statute that pertains to
the special notice for
lead (Appendix E); and
• copy of the portion of the federal
regulations (Appendix F)
pertaining to special public
notification for lead.
States may add additional requirements or elect
to give the notice themselves (Appendix H).
Before sending the special lead notice to your
customers, contact your state regulatory
agency to ensure its acceptability.
EPA
Special Public
Notification
Handbook
for Lead
Handbook for Special Public Notification for Lead
-------
Section 1 Special Public Notice for Lead
1 Special Public Notice for Lead
Overview
The Safe Drinking Water Act Amendments of 1986
established special public notification requirements pertaining to
lead.
This special, public notification requirement
applies to all community and non-transient
non-community public water systems.
The law requires that this notice be
given even if there is no violation of
the Drinking Water Standard for
Lead.
Systems that have violated the Maximum Contaminant Level
(MCL) for lead (established at 0.05 milligrams per liter [mg/l]
or parts per million)* must notify their customers according to
the General Federal Public Notification Requirements or their
state counter-parts. The general federal public notification
requirements are described in the General Public Notification
Handbook to be published separately.
Notices of an MCL violation
must be made In addition to
the Special Notice for Lead.
'NOTE: EPA is currently revising its requirements pertaining to
lead, and expects to reduce the standard significantly.
Handbook for Special Public Notification for Lead
-------
Section 1 Special Public Notice for Lead
Exceptions
Consecutive Systems
Methods of Notice
Notification is required unless the system can
prove that there is no lead-containing material in the
water system, including the residential and
nonresidential portions. Systems that may be able to
meet this requirement should discuss public notification
responsibilities with their state regulatory agency.
Generally speaking, water systems should assume that
they must make the special notification to their
consumers.
In the case of consecutive systems the owner
or operator of a public water system which provides
water to another community or non-transient non-
community water system is expected to provide one-
time notice by letter to the receiving system. The
receiving system, in turn, must provide its customers
public notice concerning lead according to the lead
public notification requirements.
The regulations give systems several options for
making this notice: mail, hand-delivery, newspapers,
and posting. Systems can use additional means of
notice (electronic media, for example) at their discretion
or at the direction of their state regulatory agency.
When the state is the primacy agent state regulations
can be more stringent and may require additional or
expanded notice. The kind of notice required
depends on the type of system giving the notice.
A breakdown of public water systems is given
in the diagram on the following page. The definitions of
the different types of water systems and examples of
each can be found in the Glossary (Appendix A).
Notification requirements by each type system follow
the diagram. Contact your primacy agent, State or
EPA, if you are not sure what category you belong in.
When in doubt ask.
mail
hand delivery
newspaper
posting
Handbook for Special Public Notification for Lead
-------
Section 1 Special Public Notice for Lead
PUBLIC
WATER SYSTEM
A system for the
provision of piped
water for human
consumption If such
system has at least 15
service connections or
regularly serves an
average of at least 25
Individuals dally at least
60 days out of the year.
A public water system that
pipes water for human
consumption to at toast
15 service connections
used by year-round 5
resident^ or one that .,
regularly serves at least
25 year-round residents
(&#,» mu nictpallty, \
subdivision).
NON-COMMUNITY
WATER SYSTEM
A public water system
that Is not a community
water system (e.g.,
Schools, factories^
nursing homes, rest
stop).
TRANSIENT
NON-COMMUNITY
WATER SYSTEM
A water system thai I*
not a non-transient
non-community system
(e.g., rest stop).
NON-TRANSIENT
: NON-COMMUNITY
WATER SYSTEM
A non-community
public water system
that regularly serves at
least 25 of the same
persons over six
months per year (e.g.,
schools, factories,
nursing homes).
Handbook for Special Public Notification for Lead
-------
Section 1 Special Public Notice for Lead
COMMUNITY
WATER SYSTEM
Community public water systems may give
notice by:
• mail,
• hand delivery, or
• newspaper.
If systems choose newspapers, they must publish that
notice once a month for three consecutive months,
with the first notice coming no later than June 19,
1988. They need only provide notice once if they do
it by hand delivery or mail, and either method must be
complete by June 19, 1988. The mail notice
requirement can be satisfied by including a notice
mailed with the water bill or by a separate mailing.
COMMUNITY WATER SYSTEM
METHOD OF NOTICE
Mail or Hand Delivery
Newspaper
Need to provide only once, but must be
completed by June 19,1988.
Mail notice can be satisfied by including
with water bill or as a separate mailing.
Publish once a month for three consecutive
months.
First notice no later than June 19,1988.
Handbook for Special Public Notification for Lead
-------
Section 1 Special Public Notice for Lead
Non-transient non-community water systems
can give notice by :
• mail,
• hand delivery, or
• newspaper.
They have the additional option of giving notice by
posting
by June 19,1988 —
continuously for three
consecutive months.
If a non-transient non-community
water system (such as a system that
provides water for a school or
daycare center) chooses posting,
the posters must be in conspicuous
locations and visible continuously for
a minimum of three months.
NON-TRANSIENT
NON-COMMUMTY
WATER SYSTEM
REST
STOP
^
c T NON-TRANSIENT NONKXJMMUNITY WATER SYSTEM 7*
•
.
w
METHOD OF NOTICE
i Mall or Hand Delivery
c
C 1
c 1 ^
i \
1 [
[
c
"Ml Need to provide only once, but must be
~-h completed by June 19, 1988.
3
]
:
3
p
J
p
H
]
]
1
Mr Mall notice can be satisfied by Including :
| with water bill or as a separate mailing. \
"
•
c Newspaper :j
c
c ID ^ •
r l^=lr
c
[ Posting
: »±
L •»
C
c
c
:
_ . . . ...
- - Publish once a month for three conseci
=.= months.
-1 First notice no later than June 19, 1988.
live
r
J
^
|
_ Posted continuously tor three consecutive :
. months.
"
1 Posting to begin no later than June 19, ISHH. c
c
TRANSIENT
NON-COMMUNITY
WATER SYSTEM
Transient non-community water systems (rest
stops, interstate carriers, etc.) are not required to give
special notice for lead.
The following chapters of this book include
more information on each of the methods of
notification.
Handbook for Special Public Notification for Lead
-------
Section 2 What Information Must be Included In the Special Public Notice for Lead
What Information Must be Included in the
Special Public Notice For Lead
The regulations concerning the special notice for
lead allow water systems the freedom to include a
variety of information specific to their situation.
However, certain types of information must go into any
public notice, no matter what form it takes. The
following section discusses the kind of information that
must be included, although its order and emphasis
depends on the specific circumstances of each system.
Notices must contain Information about sources of lead In drinking water. The notice
should be clear concerning possible sources of lead in
the water system itself. It should distinguish between
possible lead contamination in the water system, and
lead contamination caused by the plumbing system
(lead pipes, solder, etc.) within the consumer's home.
In other words, even though a water system may
provide lead-free water to the consumer, consumers
should know that their homes may contain sources of
lead contamination.
Notices must Include Information about potential adverse health effects. Readers want to
know the possible adverse health effects of lead and
how they should respond. This section of the notice is
easily misunderstood. Because this is such a difficult
and problematic area, the EPA has established
language on the health effects of lead (shown in
Appendix B). This language, word for word, must
be Included in any lead-related notice. The
language should not be modified or broken up by
inserting paragraphs or statements of your own.
c Appendix
I B
c $$«
I Mandatory
c Health
1 Effects
[ Language
i
i
i
[
i
i
i
i
i
i
i
Handbook for Special Public Notification for Lead
-------
Section 2 What Information Must be Included In the Special Public Notice for Lead
Notices must Include Information about reasonably available methods of mitigating known
or potential lead content In drinking water. The regulations require that you include information on
the reasonably available methods of mitigating lead
content in drinking water, and then tell consumers
which of those methods are being used to mitigate lead
content in their drinking water (Item 4, below). A
checklist of currently available methods is given In
Appendix D. Include all the items that apply in your
public notice.
Appendix 0
Method*
to
Mitigate Lead
*
Notices must contain Information about the steps being taken to correct the problem. In
addition to informing consumers about the methods currently available for mitigating lead content in
drinking water, notices should tell consumers what their
water system is doing to correct the problem (see the
Appendix D checklist). For example, if the system is
replacing lead pipe as part of its regular repairs, that
information should be in the notice. Corrosion control
measures are particularly important.
Appendix D
Methods
to
Mitigate Lead
JLJ Notices must include Information about alternative water supplies, when there is a need to
use them. In most situations, the public does not need
to seek alternative water supplies, and that should be
made clear. When it is necessary to seek alternative
water supplies, this should be emphasized early in the
notice. Readers not only want information, they want
to know how they should respond.
Notices must Include a phone number of the owner, operator, or designee of the public
john watercrest
555-1378
water system. The phone number gives customers a source of further information. In either case, it
is helpful if the notice shows a name along with the
phone number. The contact person must be able to
supply facts about lead and how to correct the problem.
Such a source should be well informed and able to
answer a variety of questions, including the availability
of testing for lead and the costs of such a test. That
contact person may not attempt to frustrate the purpose
of public notification or to minimize its importance. It is
permissible, by the way, for the notice to designate
certain office hours when that person is available to
answer questions.
Lead Questions
10am-2pm
Monday & Wednesday
***
Handbook for Special Public Notification for Lead
-------
Section 2 What Information Must be Included In the Special Public Notice for Lead
I and Yob
Drinking
Water
Such sources may wish to maintain a supply of
the EPA pamphlet "Lead and Your Drinking Water" to
provide additional information to consumers. Informa-
tion on how to obtain copies of the booklet is available
from:
Drinking Water Booklet
EPA
Washington, DC 20460
and the EPA regional offices shown in Appendix G.
Notices must contain specific advice about learning If lead-containing materials were used
In home plumbing or the water distribution system. The severity of the problem may depend on
the age of the plumbing. Notices should explain both
the sources of lead in drinking water and the testing
that is necessary to determine lead levels. Customers
should be advised to check to see if lead pipes, solder,
or flux have been used in plumbing and to be sure that
new plumbing and plumbing repairs use lead-free
materials. Notices can inform customers that the only
way to be sure about the amount of lead in household
water is through testing at a competent laboratory.
Testing is especially important for apartment dwellers
where flushing may not be effective in reducing lead in
water from lead-soldered central piping. It may also be
appropriate to include information about testing. The
EPA pamphlet "Lead and Your Drinking Water" may
be especially helpful here.
WHERE TO GET TEST?
COST OF TEST?
Notices must give specific advice on minimizing exposure to water that Is likely to be
contaminated with lead. Consumers need specific information about actions they can take to reduce
known or potential lead content in their water. For
example, notices can mention that the cold-water
faucet should be used for drinking, cooking, and
preparing baby formula, and to run the water until it
gets as cold as it is going to get before each use.
Notices can point out that if there has been recent
heavy water use in the house, such as a shower or
doing laundry, flushing the pipes should take five to 30
seconds; otherwise it may take as long as several
minutes. The "note" in the federal regulations
(Appendix E) gives additional suggestions for providing
this information.
10
Handbook for Special Public Notification for Lead
-------
Section 2 What Information Must be Included In the Special Public Notice for Lead
Notices must not contain unduly small print.
This is especially important for legal notices in
newspapers and for posters. See Section 3 for
guidelines.
MUM Ilium Mil
Notices must not create problems that frustrate the purpose of public notification. Notices
should inform consumers of possible problems and
provide them with information for making decisions
about the safety of their drinking water. Do not use
language that might confuse customers. Do not
underplay the seriousness of the situation.
Notices must be conspicuous. Posters must be large and placed in locations where the
public will see them. Newspaper notices should be
large and use design techniques to attract attention.
Notices by mail or hand delivery should be tailored for
that use. For more information on designing and
writing notices, see Section 3 of this Handbook.
O
Q
_^^^^^^^^A
Notices must not contain unduly technical language.
technical words and phrases. When they are
necessary, define them. Notices must be written in
language that is easy to understand. Anything else will
defeat the purpose of public notification. Again, see
Section 3 of this Handbook.
This is extremely important. Avoid
E = MC-
Handbook for Special Public Notification for Lead
11
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Section 2 What Information Must be Included In the Special Public Notice for Lead
Where appropriate, notices must be multi-lingual. Where a non-English speaking population
makes up a significant portion of the water-consuming
public, the notices should be in the appropriate
language, as well as English.
I
I
SPANISH
Finally, the law allows considerable freedom
about additional Information that can be Included In
a notice. Obviously, notices must contain a great deal
of information. Because of the importance of this
information in helping consumers make decisions about
their water supplies, the information must be presented
in clear, non-technical terms. Section 3 of this book
contains requirements and guidelines for methods of
presenting technical information in the most appropriate
manner.
12
Handbook for Special Public Notification for Lead
-------
Section 2 What Information Must be Included In the Special Public Notice for Lead
A Checklist of
Public Notice Requirements
Pertaining to Lead
The following checklist will help you determine if
all requirements have been met for your public
notification of lead. Use this checklist as you develop
your own notice. (See Appendix C for a copy that
may be duplicated for your use.)
Checklist
of
Public Notice Requirements
Pertaining to Lead
HOW TO USE:
• Check each item that appears in the notice you have prepared. When all items are checked your notice
should meet the requirements set for a Special Public Notification for Lead.
• The notice provides a clear and readily understandable explanation of
if 1. potential sources of lead in drinking water
itf 2. potential adverse health effects (mandatory health effects language)
0 3. reasonably available methods of mitigating known or potential lead content in drinking water
0 4. the steps the system is taking to mitigate lead content in drinking water
NA 5. necessity for seeking alternative water supplies, if any
• The notice Includes
Sf 6. the telephone number of the owner, operator, or designee of the public water system as a source of
additional information
yt 7. specific advice about determining if materials containing lead have been used in homes
if 8. specific advice about how to minimize exposure to water likely to contain high levels of lead
• The notice
iff 9. uses print that is easily read
M 10. content creates no problems that would frustrate the purpose of notice
if 11. design is clear and conspicuous
U 12. contains non-technical language
NA 13. contains multi-lingual information, where appropriate
NA—Not applicable for this public notice example.
Handbook for Special Public Notification for Lead
13
-------
Section 3 Guidelines tor Presentation of Information
3 Guidelines for Presentation of Information
The law provides specific requirements about
the ways in which information is to be presented to the
public. Keep in mind that how a notice is written
depends on the type of medium being used.
TYPE OF MEDIUM USED:
Mail
Hand delivery
Newspaper
Posting
Section 4
page
20
24
31
27
That is, a notice for posting or direct mail may be
different than a similar notice for a newspaper.
Examples of different notices for different media are
shown in examples discussed in Section 4.
14
Handbook for Special Public Notification for Lead
-------
Section 3 Guidelines for Presentation of Information
All of those notices have certain aspects in
common. They must be clearly written. If notices
contain language that is too technical, and thus unclear
or unfamiliar to readers, it almost guarantees that
consumers will not read it. While owners and operators
of a water system are familiar with the complex terms
and language involved in drinking water treatment,
most of their customers are not.
Customers must be able to understand and make
judgments about water quality and safety;
they can only do that if they are provided the
information in a manner that is
• clear
• accurate, and
• precise
To meet this requirement:
MAKE IT CLEAR
Don't use complicated words if they can be avoided.
The subject of water quality, and its regulation, is
complicated enough. Save technical words or phrases
for times when they are necessary for understanding
or for future education. If such terms are necessary,
define them.
Handbook for Special Public Notification for Lead
15
-------
Section 3 Guidelines lor Presentation of Information
Don't assume that your audience knows the
meaning of technical phrases. Also, avoid
acronyms or abbreviations.
Notices should be so clear that readers can
understand them. Remember, It take years to learn
the nature of water quality and Its treatment. Don't
expect average readers to know the things that you
know.
PRESENT INFORMATION
IN ORDER
OF IMPORTANCE
Many readers, particularly newspaper audiences, read
only the first few paragraphs of a story, letter, or
notice. Those paragraphs, therefore, should contain
the most Important Information; the first few
paragraphs can also pique audience interest and
increase the chance that they will read further.
16
Handbook for Special Public Notification for Lead
-------
Section 3 Guidelines for Presentation of Information
The first few paragraphs should also include details
about the source of Information, indicating that they
are being supplied by a water system. That not only
provides information to readers, but it gives the notice
additional credibility and lets readers know that they
should be concerned. Less important information can
generally wait until later.
BE CONCISE
Regardless of whether you use a letter, mail insert,
legal notice or poster, be concise. It sounds simplistic,
but studies have shown that short words are easier to
understand than long words.
Make it short!
Short sentences are easier to understand
than long sentences. Short paragraphs
are easier to read and understand than
long paragraphs. Long news releases
stand a better chance of being cut or
rewritten, or not used at all, than short
ones.
Thus, be concise
Handbook for Special Public Notification for Lead
17
-------
Section 3 Guidelines lor Presentation of Information
Include all of the necessary Information, but don't
clutter up a story or notice with every available piece of
information.
Note: To check the understandability of a notice, you
may wish to show copies to a few typical consumers
before mailing or publishing it. Those consumers may
help you pinpoint portions of the notice that they do not
understand.
18
Handbook for Special Public Notification for Lead
-------
Section 4 Types and Examples of Special Public Notice for Lead
Types and Examples of
Special Public Notice for Lead
Types of Public Notice
The following section discusses different types
of public notice, along with examples of each. Each
medium of public notice is different, whether it is
Mail Delivery,
Hand Delivery,
Newspaper or
Posting.
Your notices must be written and designed so that they
will have maximum impact and should be tailored for
each medium as much as possible. In every case,
however, the notices must include all the information
called for by the Checklist in Section 2 and
Appendix C.
Handbook for Special Public Notification for Lead
19
-------
Section 4 Types and Examples of Special Public Notice tor Lead
Notices by Mail
Mall delivery is one of the most effective
means of public notice.
Mail delivery can be made with the customer's
bill. Two common forms of such notices are:
formal letters from the system manager,
or
a bill stuffer or mall Insert,
often on stiff paper. Another option that may be
available to public water systems is to give the notice
through the 'Town Newsletter," as tang as the
newsletter is mailed to all customers served by the
water system and the notice is conspicuous in the
newsletter. Mail delivery notices must contain the
required information discussed in Section 2 of this
handbook.
20
Handbook for Special Public Notification for Lead
-------
Section 4 Types ana Examples of Special Public Notice tor Lead
Perhaps the biggest problem with these notices is
providing the necessary information and getting the
customer's attention at the same time. Various design
techniques can help. Important information can be
highlighted in boldface type. Using several type styles
will generally make a notice more readable.
Information should not clutter up the entire page of a
notice; white space around the type generally makes
the information more readable. As in all notices, a
source for additional Information should be included.
With the advent of computerized desktop-publishing
and word-processing systems, larger water systems
may have more flexibility in designing such
announcements.
Boldface type: LEAD
Type styles; Chicago
Geneva
Monaco
A Formal Letter sample for the Madison
Water Department follows... »-
Note: The circled numbers on the
example correspond to items found in the
Checklist of Public Notice Require-
ments Pertaining to Lead, Appendix C.
NA means not applicable in this situation.
Handbook for Special Public Notification for Lead
21
-------
Section 4 Types and Examples of Special Public Notice for Lead
Example: Formal Letter or Bill Stuffer
ADISQN ISlTY IWATER DEPARTMENT
Madison City Hall
Madison City, Kansas 4444
(132)555-1767
To Customers of the Madison Municipal Water Supply:
The Safe Drinking Water Act passed by Congress in 1986 requires all water systems to notify their
customers about possible lead contamination In drinking water. Madison water is currently well below
the current EPA standards for lead In drinking water, although the Water Department will continue to
carefully monitor water quality. Water systems can take steps to make sure that lead does not become
problem In their distribution system, such as replacing lead pipe and service connections. As part of
your system's treatment process, the pH level and mineral content of the water are adjusted to deliver
minimally corrosive water. The effect of this practice Is to produce water that dissolves lead more
slowly than corrosive water. In addition, the Madison Water Department will replace any lead pipe that is
found In the Water Department system during regular maintenance or repair. However, concerned
customers may want to check their water as it comes from the tap to make sure that It Is safe.
The EPA has provided the water department with the following Information:
The United States Environmental Protection Agency (EPA) sets drinking water standards and has
determined that lead is a health concern at certain levels of exposure. There is currently a standard of
0.050 parts per million (ppm). Based on new health information, EPA is likely to lower this standard
significantly.
Part of the purpose of this notice is to inform you of the potential adverse health effects of lead.
This is being done even though your water may not be in violation of the current standard.
EPA and others are concerned about lead in drinking water. Too much lead in the human body
can cause serious damage to the brain, kidneys, nervous system, and red blood cells. The greatest risk,
even with short-term exposure, is to young children and pregnant women.
Lead levels in your drinking water are likely to be highest:
• if your home or water system has lead pipes or
• if your home has copper pipes with lead solder, and
> if the home is less than five years old, or
> if you have soft or acidic water, or
>• if water sits in the pipes for several hours
Lead piping and lead solder are two of the most common sources of lead In domestic drinking water.
Lead-containing materials can often be spotted through home Inspection; plumbers can also Inspect your
home for lead-containing materials. The only way to be sure about your water's lead content Is to have
the water tested; the Madison Water Department has Information about water testing and can tell you how
to reduce the risk from lead contamination. Using water from the cold-water tap and flushing your
household system for a few minutes before each use, for example, can help lower exposure to lead.
22 Handbook for Special Public Notification for Lead
-------
Section 4 Types and Examples of Special Public Notice for Lead
Example: Formal Letter or Bill Stuffer
Madison City Water Department
page 2
Flushing may take even less time If there has been recent heavy water use, such as bathing or doing
laundry. Other steps are also helpful, Including refraining from use of hot water for cooking or drinking;
and replacing lead pipes and service connections. The Water Department does not recommend that you
seek alternative water supplies unless your water tests above the minimum levels established by law.
The Water Department can supply more Information, Including copies of Informational flyers
provided by the EPA. Contact Susan Brown at 555-1767 for more Information.
"IN A
Handbook for Special Public Notification for Lead 23
-------
Section 4 Types and Examples of Special Public Notice for Lead
Notices by Hand Delivery
Hand delivery of a public notice is also
effective. One common method of hand delivery is the
use of doorknob flyers: flyers with specially designed
paper hooks that fit over doorknobs.
Public
Notification
of
BfttAnllat
rOienDffl
SOl»C«
Lead In
Drinking
Water
0
Water System
Clty.Sttto
555-5555
rjM^w
•* a
^^
The same general guidelines for
• type style,
• size, and
• layout
apply to both doorknob flyers and mail notices. In fact,
the same information and design can often be used for
both. Local printers should be able to provide the
paper necessary for use in doorknob flyers.
See the example of a Doorknob Flyer that follows.
Note: The circled numbers on the
example correspond to 'items found in the
Checklist of Public Notice Require-
ments Pertaining to Lead, Appendix C.
NA means not applicable in this situation.
24
Handbook for Special Public Notification for Lead
-------
Section 4 Types and Examples of Special Public Notice for Lead
Example: Doorknob Hanger—front side
ADISON
WATER DEPARTMENT
NOTIFICATION FOR LEAD
IN DRINKING WATER
SITUATION
The Safe Drinking Water Act passed by Congress In 1986 requires all water systems
to notify customers about possible lead contamination In drinking water.
Madison water Is currently well below the current EPA standards for lead In drinking
water. The Water Department will continue to carefully monitor water quality. Water
systems can take steps such as replacing lead pipe and service connections, to make
sure that lead does not become a problem In their distribution system. As part of your
system's treatment process, the pH level and mineral content of the water are
adjusted to deliver minimally corrosive water. The effect of this practice Is to
produce water that dissolves lead more slowly than corrosive water. In addition, the
Madison Water Department will replace any lead pipe that Is found In the system
during regular maintenance or repair.
LEAD INFORMATION
The United States Environmental Protection Agency(EPA) sets
drinking water standards and has determined that lead is a
health concern at certain levels of exposure. There is currently
a standard of 0.05O parts per million (ppm). Based on new
health information, EPA is likely to lower this standard
significantly.
Part of the purpose of this notice is to inform you of the
potential adverse health effects of lead. This is being done even
though your water may not be in violation of the current
standard. EPA and others are concerned about lead in drinking
water. Too much lead in the human body can cause serious
damage to the brain, kidneys, nervous system, and red blood
cells. The greatest risk, even with short-term exposure, is to
young children and pregnant women.
Lead levels in your drinking water are likely to be highest:
• if your home or water system has lead pipes or
• if your home has copper pipes with lead solder, and
- if the home is less than five years old, or
- if you have soft or acidic water, or
- if water sits in the pipes for several hours.
INFORMATION
For more Information concerning testing, how to reduce the risk
from lead contamination, and EPA Informational flyers contact:
Susan Brown
Madison City Hall or call
555-1767
OVER (IT
NA
Handbook for Special Public Notification for Lead
25
-------
Section 4 Types and Examples of Special Public Notice tor Lead
Example: Doorknob Hanger—back side
GENERAL INFORMATION ABOUT LEAD
IN YOUR DRINKING WATER
Lead piping and lead solder are two of the most
common sources of lead In domestic drinking water.
The severity of the problem may depend on the age
of your plumbing. Lead containing materials can
often be spotted through home Inspection;
plumbers can also Inspect you home for
lead-containing materials.
If you are concerned about your water's lead content It
should be tested.
The Madison City Water Department has Information
about water testing and can tell you how to reduce the
risk from lead contamination.
TIPS FOR REDUCING LEAD
Using water from the cold-water tap and flushing your household
system for a few minutes before each use can help lower exposure to
lead.
Flushing may take even less time If there has been recent heavy
water use, such as bathing or doing laundry.
Other steps are also helpful, Including:
Refraining from use of hot water for cooking
or drinking, and
Replacing lead pipes and service connections.
For more information please contact:
Susan Brown
Madison City Hall
or call 555-1767
26
Handbook for Special Public Notification for Lead
-------
Section 4 Types and Examples of Special Public Notice tor Lead
Posted Notices—
For Non-Transient Non-Community
Water Systems Only!
Posted notices are yet another method of
informing the public about violations. They are,
however, for non-transient non-community water
systems only! These notices must contain the same
required Information as other forms of notice. Like
mailed notices, these posted notices should be
designed to attract attention, use:
• drawings,
• large amounts of white
space around the type, and
• boldface, and
• other type faces as necessary.
Public
Notification
(or
Lead
These notices should be widely
posted at the locations where
customers are most likely to see
them.
Public
Notification
for
Lead
Posters that are too small, or placed in poor locations,
frustrate the purpose of the law.
The posters must be in place three consecutive
months to satisfy the law.
Handbook for Special Public Notification for Lead
27
-------
Section 4 Types and Examples of Special Public Notice for Lead
A common problem with posted notices is using
type that is too small to read comfortably at a distance.
The headings of notices should be no smaller than 18
point type. The body of the notice should be 12 point
or larger. Avoid type smaller than 10 point.
Point Sizes for Comparison
24 point
A common problem
18 point
A common problem
12 point
A common problem
10 point
A common problem
8 point
A common probwm
An example of two Posted Notices follow. Posting of
both notices is necessary to meet notification
requirements. Please note they have been reduced in
size to fit the page format.
Note: The circled numbers on the
example correspond to items found in the
Checklist of Public Notice Require-
ments Pertaining to Lead, Appendix C.
NA means not applicable in this situation.
28
Handbook for Special Public Notification for Lead
-------
Section 4 Types and Examples of Special Public Notice tor Lead
Example: Posted Notice
WATER DEPARTMENT
PUBLIC NOTIFICATION FOR LEAD IN DRINKING WATER
StTOATlOH
J
C
LEAD
J
The Safe Drinking Water Act passed by Congress in 1986 requires all water
systems to notify customers about possible lead contamination in drinking water.
Madison water is currently well below the current EPA standards for lead in
drinking water. The Water Department will continue to carefully moniter water
quality. Water systems can take steps such as replacing lead pipe and service
connections, to make sure that lead does not become a problem in their distribution
system. As part of your system's treatment process, the pH level and mineral
content of the water are adjusted to deliver minimally corrosive water. The effect
of this practice is to produce water that dissolves lead more slowly than corrosive
water. In addition, the Madison Water Department will replace any lead pipe that is
found in the system during regular maintenance or repair.
The United States Environmental Protection Agency(EPA)
sets drinking water standards and has determined that lead is
a health concern at certain levels of exposure. There is
currently a standard of 0.050 parts per million (ppm). Based on
new health information, EPA is likely to lower this standard
significantly.
Part of the purpose of this notice is to inform you of the
potential adverse health effects of lead. This is being done
even though your water may not be in violation of the current
standard.
EPA and others are concerned about lead in drinking water.
Too much lead in the human body can cause serious damage
to the brain, kidneys, nervous system, and red blood cells. The
greatest risk, even with short-term exposure, is to young
children and pregnant women.
Lead levels in your drinking water are likely to be highest:
• if your home or water system has lead pipes or
• if your home has copper pipes with lead solder, and
- if the home is less than five years old, or
- if you have soft or acidic water, or
- if water sits in the pipes for several hours
For more Information concerning testing, how to reduce the risk from lead
contamination, and EPA Informational flyers contact: Susan Brown
Madison City Hall or call
555-1767
See second page of this posted notice for addtiona! lead related information.
)NA
INA
Handbook for Special Public Notification for Lead
29
-------
Section 4 Types and Examples of Special Public Notice for Lead
Example: Posted Notice (continued)
Page 2 of posted notice.
GENERAL INFORMATION ABOUT LEAD
IN YOUR DRINKING WATER
Lead piping and lead wider are two of the most common sources of lead in domestic
drinking water. The severity of the problem may depend on the age of your plumbing.
Lead-containing materials can often be spotted through home inspection; plumbers
can also inspect your home for lead-containg materials.
If you are concerned about your water's lead content H should be
tested. The Madison City Water Department has information
about water testing and can tell you how to reduce the risk from
lead contamination.
TIPS FOR REDUCING
Using water from the cold-water tap and flushing your household system for a few
minutes before each use can help lower exposure to lead.
Flushing may take even less time H there has been recent heavy water use, such as
bathing or doing laundry.
Other steps are also helpful, including:
Refraining from use of hot water for cooking or drinking
Replacing lead pipes and service connections.
For more information please contact:
Sw$a*i Brown
Madison City Half or call
SSS-tTET s^ , ^-
30
Handbook for Special Public Notification for Lead
-------
Section 4 Types and Examples of Special Public Notice for Lead
Newspaper Notices
Newspapers are probably the most common
means of public notice. Newspapers are generally
considered a credible source of news by readers, and
are an important means of communication in many
local communities. If systems use newspapers for the
special lead notice, the notice must be published:
The DAILY
D
DI
• Once a month for three consecutive months,
• With the first notice no later than
June 19,1988.
The requirement for newspaper notice can be satisfied
either by:
buying space In the newspaper, usually In
the legal notices or classified ads section.
a story by a reporter, If It has the
required Information. Even so,
such a story must be
followed by two additional
notices, which can be legal
notices, or
a news release that Is actually printed
(providing the printed version Includes the
required Information),
The DAILY
Wednesday
June 1.1988
CLASSIFIED
Legal Notice
Notice Related to Lead
Contamination of
Drinking Water from the
Greenville Water
Department
The DAILY
Wednesday
June 1,1986
LEAD NEWS RELEASE
Handbook for Special Public Notification for Lead
31
-------
Section 4 Types and Examples of Special Public Notice for Lead
Legal Notice
Notice Related to Lead
Contamination of
Drinking Water from the
Greenville Water
Department
Because of the competition for reader attention,
legal notices are not the most effective means of
public notification, though they are acceptable and
often used.
To make them more effective, legal notices should be
as large as possible. They should be designed to
attract reader attention, using bold faced type and white
space in parts of the ad to make the notice more
readable.
To help attract reader attention, each notice should be
different from the one before. More recent notices, for
example, can include updates on progress in replacing
lead-containing pipe. Water systems may also want to
poll their customers to find out how effective the notices
are, and revise them accordingly.
In some cases, particularly in smaller towns
where competition for newspaper space is less severe,
newspapers may also use news releases provided by
the water supplier. However, news releases must still
be well written and clear to make sure the
Information Is conveyed accurately.
Here are the Steps for Writing a News Release.
STEP!
News releases should be written
on letterhead paper that supplies the name, address,
and phone number of the public water system.
HILLS WATER DISTRICT
Route 5
Batesvllle, Arkansas 33333
(703)555-5511
DATE OF RELEASE: July 5,1987
SOURCE: FredWIIholm,
Water District Manager
(703) 555-5511
The name and phone number (even if it is the same
as the water system) of the person who is the source
of the story should also appear at the top of the
release, along with the date of the news release.
32
Handbook for Special Public Notification for Lead
-------
Section 4 Types and Examples of Special Public Notice tor Lead
Most releases should include a
headline ... a line that describes, in as few words as
possible, the essence of the story.
POTENTIAL LEAD CONTAMINATION IN DRINKING WATER
Providing a headline yourself may prevent someone
else from adding an inaccurate headline in the story.
HUH! The news release should begin by
showing the location of the story. That is, if the water
system is located in Batesville, the town's name should
be indented and shown in capital letters.
BATESVILLE—Though there is no evidence of detectable levels
of lead ...
i^J After the location is shown, the
story itself can begin. As mentioned previously, the
most Important information should be shown at the
beginning of a story, followed by an attribution, which
shows the source of the story.
BATESVILLE—Though there are no detectable levels of lead
delivered to the home due to contamination or corrosion in the
water supply produced by the West Hills Water District, concerned
customers may want to check their tap water for traces of lead,
according to water district manager Fred Wilholm.
Handbook for Special Public Notification for Lead
33
-------
Section 4 Types and Examples of Special Public Notice for Lead
Some news reporters try to include everything about a
story in the first sentence. In a technical story,
however, that is generally difficult.
The first sentence (known as the "lead" In news
writing) often becomes too long and unwieldy. In
general it is sufficient to put the most Important
Information first, and leave less important information
for later.
STIP5
After the "lead," the following
paragraph could contain more specific information
about exact measurements of the levels and what the
allowable levels are. For example:
Tests throughout the West Hills water system show that samples
of water leaving the plant contain no detectable levels of lead
because of the materials used in the distribution system, Wilholm
said. But customers may want to check water from their taps to
make sure that their water is not contaminated by household
plumbing.
That paragraph could be followed by the
mandatory language about the health effects of
lead, followed by information about the cause and
remedy of the situation.
Appendix B
Mandatory
Heafth Effects
language
water samples below
minimum standard
water system required to
make a public notice for lead
Further local information would be helpful.
34
Handbook for Special Public Notification for Lead
-------
Section 4 Types and Examples of Special Public Notice for Lead
A finished Release and a Legal Notice would look like
this:
Note: The circled numbers on the
example correspond to items found in the
Checklist of Public Notice Require-
ments Pertaining to Lead, Appendix C.
NA means not applicable in this situation.
Handbook lor Special Public Notification for Lead
35
-------
Section 4 Types and Examples of Special Public Notice for Lead
Example: News Release
T HILLS WATER DISTRICT
Route 5
Batesvllle, Arkansas 33333
(703)555-5511
DATE OF RELEASE: July 5, 1987
FOR MORE INFORMATION CONTACT: FRED WILHOLM, WATER DISTRICT MANAGER (703-
555-5511)
CUSTOMERS NOTIFIED OF POTENTIAL LEAD CONTAMINATION
BATESVILLE—Though there are no detectable levels of lead delivered to the home due
to contamination or corrosion In water supply produced by the West Hills Water District,
concerned customers may want to check their tap for traces of lead, according to water
district manager Fred Wllholm.
Tests throughout the West Hills water system show that samples of water leaving the
plant contain no detectable levels because of materials used In the distribution system,
Wllholm said. The Water District does not recommend that customers seek alternative water
supplies, Wllholm said, unless water tested at a specific house showed that it was above the
maximum allowable level. Lead pipe, lead connections, and lead solder are among the most
common sources of lead In drinking water, said Wllholm. Lead levels can generally be
reduced by replacing pipe and connections with lead-free materials. As part of your system's
treatment process, the pH level and mineral content of the water are adjusted to deliver
minimally corrosive water. The effect of this practice Is to produce water that dissolves lead
more slowly than corrosive water. In addition, the West Hills Water System has begun a ff
program to replace any lead service-connections that deliver water to their customers; ^
replacement should be complete within the next year.
Even though there Is no evidence of contamination In water from the Water District, lead (~T
can be Introduced Into the water supply through domestic plumbing, and customers might
want to check water from their taps to make sure It Is not contaminated by lead materials
used In household plumbing.
According to Wilholm, the water system has been required to make the following public
notice.
The United States Environmental Protection Agency (EPA) sets drinking water standards
and has determined that lead Is a health concern at certain levels of exposure. There Is
currently a standard of 0.050 parts per million (ppm). Based on new health Information, EPA is
likely to lower this standard significantly.
Part of the purpose of this notice Is to Inform you of the potential adverse health effects
of lead. This Is being done even though your water may not be In violation of the current (T
standard. ^—
-add on-
36 Handbook for Special Public Notification for Lead
-------
Section 4 Types and Examples of Special Public Notice for Lead
Example: News Release
Add one
West Hills Water District
EPA and others are concerned about lead In drinking water. Too much lead In the
human body can cause serious damage to the brain, kidneys, nervous system, and red blood
cells. The greatest risk, even with short-term exposure, Is to young children and pregnant
women.
Lead levels In your drinking water are likely to be highest:
• If your home or water system has lead pipes or
• If your home has copper pipes with lead solder, and
> If the home Is less than five years old, or
> If you have soft or acidic water, or
> If water sits In the pipes for several hours.
Wllhom said that while West Hills water was safe, customers who are concerned about
lead may want to have their water supply tested by a reputable laboratory. Where lead may be
a problem in drinking water, Wllhom recommended that customers use only their cold-water
faucet for drinking, cooking, or making baby formula. He said they should run the water to
flush the system until the water gets as cold as possible before each use. When there has
been recent major water use In the house, such as laundry or showering, that may only take
five to thirty seconds. Otherwise, flushing the system may take up to several minutes. In
some cases, customers may need to consider replacing lead pipes, having their water treated
with systems that will remove lead, or using bottled water.
Wilholm advised customers to check to see If lead pipes, solder, or flux might have been
used In their plumbing and to make sure that new plumbing or plumbing repairs used lead-
free materials. Lead Is a soft, gray metal. Pipes made of lead can be easily scratched by a
key or screwdriver; those scratches will be shiny.
For more Information contact Fred Wilholm at the West Hills Water District, 555-5511.
-30-
)NA
Handbook for Special Public Notification for Lead 37
-------
Section 4 Types and Examples of Special Public Notice for Lead
Example: Legal Notice
Notice Related to Lead Contamination of Drinking Water From the Greater Greenville
Water Department
The Greater Greenville Water Department notifies its customers, as required by 1986
amendments to the Safe Drinking Water Act, that they should consider testing household
water supplies for lead content. Water provided by the system is currently well below current
standards for lead contamination. Lead content can be reduced by replacing lead pipe or
connections with lead-free materials. As part of your system's treatment process, the pH
level and mineral content of the water are adjusted to deliver minimally corrosive water. The
effect of this practice is to produce water that dissolves lead more slowly than corrosive
water. Because the Greenville water system does not contain any lead pipe or service
connections, the Department has no plans to replace pipe at this time. Any repairs or
additions to the system will continue to be made with lead-free materials.
However, lead piping and lead solder used in household plumbing may contaminate domestic (T]
water supplies. Visual inspection by home owners or a plumber can generally reveal the ^
presence of lead in the plumbing system. Because lead is a soft, gray metal, pipes made of (7
lead will scratch easily and the scratches will be shiny. To be sure about their water quality, ^T
customers may want to have their own water tested as it comes from the tap. Unless those (5.
tests reveal lead levels above the maximum allowable by law, the Department does not
recommend that customers seek alternative water supplies.
The Department provides the following information from the U.S. Environmental Protection
Agency.
The United States Environmental Protection Agency (EPA) sets drinking water standards and has
determined that lead is a health concern at certain levels of exposure. There is currently a standard
of 0.050 parts per million (ppm). Based on new health information, EPA is likely to lower this
standard significantly.
Part of the purpose of this notice is to inform you of the potential adverse health effects of lead.
This is being done even though your water may not be in violation of the current standard.
EPA and others are concerned about lead in drinking water. Too much lead in the human body
can cause serious damage to the brain, kidneys, nervous system, and red blood cells. The greatest
risk, even with short-term exposure, is to young children and pregnant women.
Lead levels in your drinking water are likely to be highest:
• if your home or water system has lead pipes or
• if your home has copper pipes with lead solder, and
>• if the home is less than five years old, or
>• if you have soft or acidic water, or
> if water sits in the pipes for several hours.
The water department advises customers that they can take a number of steps to mitigate
the problems of lead contamination in drinking water, including using only water from the
cold-water tap for cooking or drinking, running the tap for a few minutes to flush the system
before using water for cooking or drinking, or replacing lead pipes. Visual inspection can
often reveal lead pipes or solder, though testing is the only way to be certain if your water is
safe. The Water Department has additional information about testing and about steps that
consumers can take to reduce the lead content in their water. For more information, contact
Bruce Peters, Public Information Officer at the Department, at 555-1146 between the hours of
8 a.m. and 5 p.m.
I3)NA
38 Handbook for Special Public Notification for Lead
-------
Section 4 Types and Examples of Special Public Notice for Lead
Proof of
Publication
Water systems using newspapers to give
public notice may be required to prove to the
primacy agent that notification has been published.
This can generally be arranged through newspaper
advertising offices, which can offer you:
tearsheets,
copies of the pages showing your
advertisement, or
through a certification process by which the
paper can offer proof that your advertisement
was published.
Newspaper advertising offices can provide tearsheets
or certification of your advertising, but you should
Tear Hera
PROOF SHEET
Lead News Release
Request those items
at the time that you
place the
advertisement.
Request those items at the time that you place the advertisement.
Your state regulatory agency may require or request
proof that the notice was given. Such proof can be
obtained from your newspaper. Keep the proof (or a
good copy) on file in case this is requested.
Handbook for Special Public Notification for Lead
39
-------
APPENDICES
-------
APPENDIX A
GLOSSARY
MCL - Maximum contaminant level, the highest acceptable levels for contaminants as established
by the National Primary Drinking Water Regulations.
NATIONAL PRIMARY DRINKING WATER REGULATIONS - The source of standards for
drinking water. They contain an MCL or treatment technique, and monitoring and reporting
requirements.
PRIMACY AGENT - The agency that is responsible for regulation of the states' water supply
systems. In nearly all cases, this is the state agency that regulates water supply systems. In states
where no state agency administers the public drinking water program, EPA is the primacy agent.
PUBLIC WATER SYSTEM - A system for the provision of piped water for human consumption
if it has at least 15 service connections or regularly serves an average of at least 25 individuals daily
at least 60 days out of the year. Such a system includes: (1) any collection, treatment, storage
and distribution facilities under control of the operator of such system and used primarily in
connection with such system, and (2) any collection or retreatment storage facilities not under
such control which are used primarily in connection with such system. A public water system is
either a community water system or a non-community water system.
1. COMMUNITY WATER SYSTEM A public water system that pipes water
for human consumption to at least 15 service connections used by year-
round residents, or one that regularly serves at least 25 year-round
residents (e.g., municipalities, subdivisions).
2 . NON-COMMUNITY WATER SYSTEM A public water system that is not
a community water system (see community water system.).
a. NON-TRANSIENT NON-COMMUNITY WATER SYSTEM -A
public water system that is not a community water system and that
regularly serves at least 25 of the same persons over six months per
year (e.g., schools, factories).
b. TRANSIENT NON-COMMUNITY WATER SYSTEM - A non-
community water system that is not a non-transient non-community
water system (e.g., rest stop).
Handbook for Special Public Notification for Lead 41
-------
APPENDIX B
MANDATORY HEALTH EFFECTS LANGUAGE
The following language is required for use in the one-time public notice related to lead. It
must be reproduced word for word in the public notice.
The United States Environmental Protection Agency (EPA) sets drinking
water standards and has determined that lead Is a health concern at certain
levels of exposure. There Is currently a standard of 0.050 parts per million
(ppm). Based on new health Information, EPA Is likely to lower this standard
significantly.
Part of the purpose of this notice is to inform you of the potential
adverse health effects of lead. This Is being done even though your water
may not be In violation of the current standard.
EPA and others are concerned about lead In drinking water. Too much
lead In the human body can cause serious damage to the brain, kidneys,
nervous system, and red blood cells. The greatest risk, even with short-term
exposure, Is to young children and pregnant women.
Lead levels In your drinking water are likely to be highest:
• If your home or water system has lead pipes or
• If your home has copper pipes with lead solder, and
> If the home is less than five years old, or
> If you have soft or acidic water, or
>• If water sits In the pipes for several hours
42 Handbook for Special Public Notification for Lead
-------
APPENDIX C
CHECKLIST OF PUBLIC NOTICE REQUIREMENTS
PERTAINING TO LEAD
Checklist
of
Public Notice Requirements
Pertaining to Lead
HOW TO USE:
• Check each item that appears in the notice you have prepared. When all items are
checked your notice should meet the requirements set for a Special Public
Notification For Lead.
• The notice provides a clear and readily understandable explanation of
Q 1. potential sources of lead in drinking water
Q 2. potential adverse health effects (mandatory health effects language)
Q 3. reasonably available methods of mitigating known or potential lead
content in drinking water
Q 4. the steps the system is taking to mitigate lead content in drinking
water
Q 5. necessity for seeking alternative water supplies, if any
• The notice Includes
Q 6. the telephone number of the owner, operator, or designee
of the public water system as a source of additional information
Q 7. specific advice about determining if materials containing lead have been
used in homes
Q 8. specific advice about how to minimize exposure to water likely to
contain high levels of lead
• The notice
Q 9. uses print that is easily read
Q10. content creates no problems that would frustrate the purpose of
notice
Q11. design is clear and conspicuous
Q12. contains non-technical language
Q13. contains multi-lingual information .where appropriate
Handbook for Special Public Notification for Lead 43
-------
APPENDIX D
CHECKLIST OF CURRENTLY AVAILABLE
METHODS FOR MITIGATING LEAD CONTENT
IN DRINKING WATER
CHECKLIST OF CURRENTLY AVAILABLE
METHODS FOR MITIGATING LEAD
CONTENT IN DRINKING WATER
Q 1. Monitoring and testing of the corrosivity level of your system's water on a routine basis
(indicate frequency) to assure your customers of minimally corrosive water.
Q 2. Monitoring and testing of the lead content of your system's water to determine the
levels of lead delivered to the service connections in your customers' homes. Even if
the levels of lead are not detectable or below the lead MCL, customers should be
informed that tap water may contain lead leached from pipes and solder in their home
plumbing.
Q 3. As part of your system's treatment process, the pH level and mineral content of the water
are adjusted to deliver minimally corrosive water. The effect of this practice is to produce
water that dissolves lead more slowly than corrosive water.
Q 4. The practice of using lead or lead-based materials in the water distribution system has
been discontinued.
O 5. The water distribution system is being surveyed for the extent to which lead lines and
other lead-containing materials were used.
Q 6. A replacement program for lead and lead containing materials has been started for your
system. The start and completion dates should be indicated in your letter.
Q 7. All plumbers, builders, contractors and others who work within your system's service area
have been notified of the federal ban on lead and advised to use only lead-free solder
and materials.
Q 8. Other
44 Handbook for Special Public Notification for Lead
-------
APPENDIX E
SAFE DRINKING WATER ACT
SECTION 1417: "LEAD BAN" REQUIREMENTS
"SEC. 1417. PROHIBITION ON USE OF LEAD PIPES, SOLDER AND FLUX
"(a) IN GENERAL -
"(1) PROHIBITION. - Any pipe, solder, or flux, which is used after the enactment of
the Safe Drinking Water Act Amendments of 1986, in the installation or repair of -
"(A) any public water system, or
"(B) any plumbing in a residential or nonresidential facility providing water
for human consumption which is connected to a public water system,
shall be lead free (within the meaning of subsection (d)). This paragraph shall not apply
to leaded joints necessary for the repair of cast iron pipes.
"(2) PUBLIC NOTICE REQUIREMENTS -
"(A) IN GENERAL - Each public water system shall identify and provide notice
to persons that may be affected by lead contamination of their drinking water
where such contamination results from either or both of the following:
"(i) The lead content in the construction of materials of the public
water distribution system.
"(ii) Corrosivity of the water supply sufficient to cause leaching of lead
The notice shall be provided in such manner and form as may be reasonably
required by the Administrator. Notice under this paragraph shall be provided
notwithstanding the absence of a violation of any national drinking water standard.
"(B) CONTENTS OF NOTICE. - Notice under this paragraph shall provide a clear
and readily understandable explanation of -
"(i) the potential sources of lead in the drinking water,
"(ii) the potential adverse health effects,
"(iii) reasonably available methods of mitigating known or potential lead
content in drinking water,
"(iv) any steps the system is taking to mitigate lead content in drinking
water, and
"(v) the necessity for seeking alternative water supplies, if any.
"(b) STATE ENFORCEMENT. -
"(1) ENFORCEMENT OF PROHIBITION. - The requirements of subsection (a)(1)
shall be enforced in all States effective 24 months after the enactment of this section.
States shall enforce such requirements through State or local plumbing codes, or such
other means of enforcement as the State may determine to be appropriate.
"(2) ENFORCEMENT OF PUBLIC NOTICE REQUIREMENTS. - The requirements of
subsection (a)(2) shall apply in all States effective 24 months after the enactment of
this section.
"(c) PENALTIES. - If the Administrator determines that a State is not enforcing the
requirements of subsection (a) as required pursuant to subsection (b), The
Administrator may withhold up to 5 percent of Federal funds available to that
State for State program grants under section 1443(a).
"(d) DEFINITION OF LEAD FREE. - For purposes of this section, the term "lead free"-
"(1) when used with respect to solders and flux refers to solders and flux
containing not more than 0.2 percent lead , and
"(2) when used with respect to pipes and pipe fittings refees to pipes and pipe
fittings containing not more than 8.0 percent of lead".
Handbook for Special Public Notification for Lead 45
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APPENDIX E
E. continued.
Page 2
Sections of Public Law 99-339 Which Do Not Amend the Safe Drinking Water Act
SEC. 109. (C) BAN ON LEAD WATER PIPES, SOLDER, AND FLUX IN VA AND INSURED OR
ASSISTED PROPERTY.-
(1) PROHIBITION. - The Secretary of Housing and Urban Development and the
Administrator of the Veterans' Administration may not insure or guarantee a mortgage or
furnish assistance with respect to newly constructed residential property which contains
a potable water system unless such system uses only lead free pipe, solder, and flux.
(2) DEFINITION OF LEAD FREE. - For purposes of paragraph (1) the term "lead
free" -
(A) when used with respect to solders and flux refers to solders and flux containing
not more than 0.2 percent lead, and
(B) when used with respect to pipes and pipe fittings refers to pipes and pipe
fittings containing not more than 8.0 percent lead.
(3) EFFECTIVE DATE.- Paragraph (1) shall become effective 24 months after the
enactment of this Act.
(d) LEAD SOLDER AS A HAZARDOUS SUBSTANCE. -
(1) IN GENERAL. - Section 2(f)(1) of the Federal Hazardous Substances Act is
amended by adding the following at the end thereof:
"(E) Any solder which has a lead content in excess of 0.2 percent.".
(2) LABELING. - Section 4 of the Federal Hazardous Substances Act is amended by
adding the following at the end thereof:
"(k) The introduction or delivery for introduction into interstate commerce of any lead solder
which has a lead content in excess of 0.2 percent which does not prominently display a warning label
stating the lead content of the solder and warning that the use of such solder in the making of joints or
fittings in any private or public potable water supply system is prohibited.".
(8) EFFECTIVE DATE. - The amendments made by this subsection shall become
effective 24 months after the enactment of this Act.
46 Handbook for Special Public Notification for Lead
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APPENDIX F
APPINPOX
FEDERAL REGISTER • SECTION 141.34:
EXCERPTS: SPECIAL PUBLIC NOTIFICATION
REQUIREMENTS FOR LEAD • October 28, 1987
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Parts 141,142, and 143
[WH-FRL-3254-6]
Drinking Water Regulations; Public
Notification
AGENCY: Environmental Protection
Agency (EPA).
ACTION; Final rule.
SUMMARY: This action under section
1414(c) of the Safe Drinking Water Act
(SDWA). 42 U.S.C. 300f et seq.. amends
the general public notification
regulations found at 40 CFR 141.32, and
amends the public notification
requirements for exceedances of the
National Secondary Drinking Water
Regulations for fluoride found at 40 CFR
143.5, to make them consistent with the
new general public notification
requirements. These changes apply to
owners and operators of public water
systems which fail to comply with
certain requirements of the National
Primary Drinking Water Regulations
(NPDWRs), or certain monitoring
requirements, and owners or operators
of public water systems which have a
variance or exemption. EPA is
establishing requirements regarding the
manner, form, content and frequency of
the public notice.
In addition, EPA is promulgating new
public notification requirements
regarding lead contamination of
drinking water to implement section
1417(a)(2) of the SDWA. The new public
notification requirements for lead
require public water systems to identify
and provide notice to persons who may
be affected by lead contamination in
their drinking water, where such
contamination results from the use of
lead in the construction materials of the
distribution system. These notification
requirements, which apply to owners
and operators of community and non-
transient non-community water systems,
apply in addition to the general public
notification requirements for lead. EPA
is today establishing requirements
regarding the content, form, manner, and
frequency of the lead notice.
Finally, EPA is amending the State
implementation regulations found at 40
CFR Part 142, Subpart B to require
States to adopt, at a minimum, the
general public notification requirements
found in revised § 141.32, and
procedures for implementing
§ 141.32(b)(3)(iii), which allows States to
extend the public notification time
frames for certain Tier 2 monitoring
violations from three months to one
year.
EFFECTIVE DATE: The amended general
public notice requirements under new 40
CFR 141.32, will take effect April 28,
1989. The public notice requirements for
lead found at 40 CFR 141.34, the
amended public notification
requirements for violations of the
Secondary Maximum Contaminant
Level (SMCL) for fluoride found at 40
CFR 143.5, and the amended State
implementation requirements found at
40 CFR Part 142, Subpart B will take
effect November 27,1987. The
redesignation of 40 CFR 141.32 as 40
CFR 141.36 and the new introductory
text are effective November 27,1987.
Section 141.36 expires April 28,1989. In
accordance with 40 CFR 23.7, this
regulation shall be considered final
Agency action for the purposes of
judicial review at 1:00 p.m. eastern time
on November 12,1987.
Handbook for Special Public Notification for Lead
47
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APPENDIX F
C. Public Notification Requirement^ for
Lead
EPA proposed in the April 6,1982
Federal .Register notiqerto establish a
new section.in SubpartH § 141-34
Public Notice Requirements Pertaining
to Lead, in response to section M17Ja}(2)
of the SDWA
-------
APPENDIX F
corrosi vity tetead ba*ed on-actual
water samples.'However. aH-waters are
capable of leaching lead to .seme degree.
The rate of leaching depeadson many
factors, including the typfeafiilwBitHBg
materials, amount of'leatf surfaced
contact with water, the age*>f the
material, the chemistry and temperature
of the water, and the amount of flushing
of the plumbing. EPA is currently
studying these parameters in the course
of developing a revised NPDWR for
lead. However, available studies have
been unable to correlate any easily
measured water quality parameters with
lead concentrations at the consumer's
tap. These studies also demonstrate that
even with optimal treatment there is still
a high probability of leaching lead.
Therefore, based on current information,
EPA has concluded that all community
and non-transient non-community water
systems should provide the lead public
notice unless they can demonstrate to
the State that there is no lead-containing
material in the water system, including
the residential and nonresidential
portions' of the system. This requirement
is reflected on the final rule.
Additional information may become
available in the course of developing the
monitoring requirements for lead—the
revised NPDWR for lead is scheduled
for promulgation in mid-1988—that
allows a public water system to
determine that Its water is "non/
corrosive" to lead. If so, EPA would
consider amending this public
notification rule.
Third, a large number of public water
system; States, and other cqmmenters
suggested that the Agency should allow
States to give the lead notice oh behalf
of public water systems, at least in some
cases. ERA agrees that notification by
the State may be sometimes appropriate,
as* long as the State notice on behalf of
the water systems contains all the
elements listed under § 141.34(cJ and (d)
(including system-specific information
about what each system is doing to
mitigate the lead content in drinking
water and whether there is any need to
serve alternative supplies) and meets
the requirements under 141.34(b). See
discussion1 under II.c.3 below.) In order
to make State notification a more viable
option, the final rule revised the manner
of notice from requiring mail and
newspaper notice to allowing water-
systems to give notice either by mail,
newspaper, or hand delivery (also;
posting is an additional option for non-
transient non-conwranity water
systems). If a State-chooses to give
statewide notice«fcthe behalf of the
public water systems covered by this
rule, the State could, for example, use
newspaper advertisements.in
newspapers serving the area, that ate of
sufficient size and location in the
newspaper that ihey waHld^Iifceiy Attract
widespread attention. In addition, the
State should use public service
announcements, on radios and
television serving the area, that are
aired atauch times and frequency as are
necessary to reach the consumers for
which the notice is intended.
EPA disagrees with the commenters
who stated that the rule should transfer
some of the legal responsibility for the
lead notice to the States. The statute
and legislative history clearly place the
responsibility for fulfilling this
requirement on the public water system.
Thus, while EPA is allowing States to
provide the lead notice on behalf of the
water system, under the conditions of
§ 141.34(f), described below, the water
system remains^legally liable for
ensuring the notice takes place.
Fourth, several States and public
water systems thought that public notice
should be required only where there
was a clear-indication that the drinking
water would potentially .have lead
concentrations above the maximum
contaminant level set by EPA. The
commenters suggested that EPA and the
State use data collected under the 1980
corrosivity monitoring requirement to
determine which systems should be
required to give public notice. ERA
disagrees with this interpretation of the
statutory requirement; it believes that
the statute and legislative history
require public water systems to give
notice to persons that may be affected
by lead contamination'; the Act clearly
requires lead notice even if there is no
MCL violation!
Lastly, one commenter asked about
the applicability of the lead-notice
requirements id consecutive systems.
EPA expects' the owner or operator of a
public water system which is subject to
the public-notification requirements for
lead, and which provides water to
another community or non-transient
non-community water system, to
provide one-time notice by letter to the
receiving system. The receiving system,
in turn, must provide its customers
public notice concerning lead in
compliance with the lead public
notification requirements.
2. Frequency of Notice
Section 1417(b)(2) of the Act states
that the public notice requirements for
lead "shall apply in all-states effective
24 months after the enactment of this
section." In the April 6,1987, notice EPA
proposed to codify this provision by
requiring the owner or operator of each
community water systems to issue the
initial natice^er lead no later than June
19.1988. EPA also proposed that each
system give notice annually for five
years from the initial notice or the
effective-date of the lead ban, -whichever
was later. (The lead ban is mandated by
sections 1417 (a){l) and (b){l)) of the
Safe Drinking Water Act.) EPA
proposed a five-year span because.
experience indicates that lead levels are
substantially decreased five years after
the last application of new lead solder
in water supply systems.
Several 'commenters objected to the
proposed requirement for a repeat
notice each year for five consecutive
years; most thought a single notice was
sufficient and that repeat notices would
be costly and difficult for the State to
enforce. Several commenters thought
that repeat notices were unnecessary
because of the lead ban and other
outreach activities. Two commenters, on
the other hand, thought that the notice
should be repeated each year until the
lead ban was in effect in the community
served by the water system. EPA agrees
that the five-year repeat notice
teqatfemenHfl probably not generally
necessary and that a mandatory five-
year notice would be costly to
implement Certainly the. statute does
not require ongoing notice. In addition,
EPA expects to-promulgate a revised
NPDWR for lead by June, 1988, and to
be in effect by December, 1989 (18
months after promulgation). The revised
NPDWR will more directly control lead
in drinking water. Therefore, EPA has
changed the final rule to require a single
year notice, to begin-on or before June
19,1988. If the owner or operator
chooses to give newspaper notice, such
notice is to.be given once a month for
three consecutive months. The mail and
hand delivery options require one-time
notice. If a non-transient non-community
water system chooses posting, it is to be
contkrae«»{ot-three months.
3. Manlier of Notice
Section 1417 of the SDWA requires
the Administrator to prescribe the
manner and form of the public notice for
lead. In the April 6,1987 notice, EPA
proposed that notice to the consumer be
given by mail delivery (direct mail or
with individual water bills) and by
newspaper notice.
In the April 8,1987 proposal, EPA also
requested comment on an option to
reqwre-thMpublic water systems
supplement mail notice with hand
delivery of notices to individual units or
posting at multiple family dwellings,
apartment complexes, and other
locations where individual consumer
may not receive a water bill.
Handbook for Special Public Notification for Lead
49
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APPENDIX F
EPA received numerous comments on
the manner of notice proposed in the
April 6,1987 notice. Most of the
commenters on this aspect of the
proposal objected to the requirement for
a mail notice, believing that the-mail
notice was both costly and less effective
than other forms of communication (i.e.,
newspaper, electronic media). Many of
these commenters also thought that a
mail notice should be tailored to- the
severity of the problem in the individual
water system, with more notices
required where a lead problem is
known.
EPA agrees that the form of the notice
should be tailored to the problems in the
individual water system and has
decided to make the requirement more
flexible. Therefore, the final rule
requires that water systems give one
notice, using an option of mail notice,
newspaper notice, or hand delivery.
Posting is an additional option for non-
transient non-community water systems.
If the water system chooses the
newspaper notice, it must give notice
once per month for three consecutive
months. If posting is chosen by the non-
transient non-community water system,
it must be continuous for three months.
The mail or hand delivery options
require single-time notices.
4. Form and Content of Notice
Section 1417(a)(2){B) of the Act
specifically requires that public notices
for lead be written in a clear and readily
understandable manner. The Act states
that notices must include information
concerning potential sources of lead in
drinking water, potential adverse health
effects, reasonably available methods of
mitigating known or potential lead
content in drinking water, any steps the
system'is taking to mitigate lead content
in drinking water, and the necessity for
seeking alternative water supplies, if
any.
EPA proposed in the April 6,1987
notice a list of general requirements for
the content of lead public notices. In
addition to the statutory requirements
outlined above, EPA proposed to require
that community water systems include
specific advice hi the notice on hbw to
minimize exposure to water likely to
contain high levels of lead. The April 8,
1987 proposal also set out language on
the health effects of lead that would be
mandatory for all lead notices. The
Agency believes that requiring specific
language will ensure accurate and
consistent toxicological information in
every puWk'notieeand simplify the
preparation of ite4ndivWk»l notices.
The proposal gavffithe community water
systems the flexibility to draft the
remainder of-the notice to best reflect
the specific circumstances of the
individual systems.
EPA received numerous comments on
this portion of the proposal. Many
commenters asked for more complete
guidelines on what specific advice EPA
thought they should provide consumers.
Several asked for "boilerplate language"
or a publication that would meet the
requirements to be inserted with the
water bill. Three commenters
recommended boilerplate language to be
included in EPA guidelines. EPA agrees
and is developing a sample public notice
to be distributed as part of a public
notification handbook. The Agency has
recently published Lead and Your
Drinking Water, which also is available
for this purpose. Also, many
commenters objected to the specific
health effects language included in the
April 6,1987 proposal, viewing the
proposed language as too technical,
confusing, and (in some parts)
unnecessarily alarming. EPA agrees
with this comment and has revised the
mandatory language to be more
educational, simple, and objective.
§ 141.34 Public notice requirements
pertaining to lead.
(a) Applicability of public notice
requirement. (I) Except as provided in
paragraph (a)(2) of this section, by June
19,1988. the owner or operator of each
community water system and each non-
transient, non-community water system
shall issue notice to persons served by
the system that may be affected by lead
contamination of their drinking water.
The State may require subsequent
notices. The owner or operator shall
provide notice under this section even if
there is no violation of the national
primary drinking water regulation for
lead.
(2) Notice under paragraph (a)(l) of
this section is not required if the system
demonstrates to the State that the water
system, including the residential and
non-residential portions connected to
the water system, are lead free. For the
purposes of this paragraph, the term
"lead free" when used with respect to
solders and flux refers to solders and
flux containing not more than 0.2
percent lead, and when used with
respect to pipes and pipe fittings refers
to pipes and pipe fittings containing not
more than 8.0 percent lead.
(.b) Manner of notice. Notice shall be
given to persons served by the system
either by (1) three newspaper notices
(one for each of three consecutive
months and the first no later than June
19,1988); or (2) once by mail notice with
the water bill or in a separate mailing by
June 19,1988; or (3) once by hand
delivery by June 19,1988. For non-
transient non-community water systems,
notice may be given by continuous
posting. If posting is used, the notice
shall be posted in a conspicuous place
in the area served by the system and
start no later than June 19,1988, and
continue for three months.
(c) General content of notice. (1)
Notices issued under this section shall
provide a clear and readily
understandable explanation of the
potential sources of lead in drinking
water, potential adverse health effects,
reasonably available methods of
mitigating known or potential lead
content in drinking water, any steps the
water system is taking to mitigate lead
content in drinking water, and the
necessity for seeking alternative water
supplies, if any. Use of the mandatory
language in paragraph (d) of this section
in the notice will be sufficient to explain
potential adverse health effects.
(2) Each notice shall also include
specific advice on how to determine if
materials containing lead have been
used in homes or the water distribution
system and how to minimize exposure
to water likely to contain high levels of
lead. Each notice shall be conspicuous
and shall not contain unduly technical
language, unduly small print, or similar
problems that frustrate the purpose of
the notice. Each notice shall contain the
telephone number of the owner,
operator, or designee of the public water
system as a source of additional
information regarding the notice. Where
appropriate, the notice shall be
multilingual.
(Note (Optional Information): Each notice
should advise persons served by the system
to use only the cold water faucet for drinking
and for use in cooking or preparing baby
formula, and to run the water until it gets as
cold as it is going to get before each use. If
there has recenlty been major water use in
the household, such as showering or bathing,
50
Handbook for Special Public Notification for Lead
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APPENDIX F
flushing toilets, or doing laundry with cold
wiiler, flushing the pipes should take 5 to 30
seconds: if not, flushing the pipes could take
HS long as several minutes. Each notice
should also advise persons served by the
system to check to see if lead pipes, solder, or
flux have been used in plumbing that
provides tap water and to ensure that new
plumbing and plumbing repairs use lead-free
materials.
The only way to be sure of the amount of
lead in the household water is to have the
water tested by a competent laboratory.
Testing is especially important to apartment
dwellers because flushing may not be
effective in high-rise buildings that have lead-
soldered central piping. As appropriate, the
notice should provide information on testing.]
(d) Mandatory health effects
information. When providing the
information in public notices required
under paragraph (c) of this section on
the potential adverse health effects of
lead in drinking water, the owner or
operator of the water system shall
include the following specific language
in the notice:
"The United States Environmental
Protection Agency (EPA) sets drinking water
standards and has determined that lead is a
health.concern at certain levels of exposure.
There is currently a standard of .0.050 parts
per million (ppm). Based on new health
information, EPA is likely to lower this
standard significantly.
"Part of the purpose of this notice .is to
inform you of the potential adverse health
effects of lead. This is being done even
though your water may not be in violation of
the current standard.
"EPA and others are concerned about lead
in drinking water. Too much lead in the
human body can cause serious damage to the
brain, kidneys, nervous system, and red
blood cells..The greatest risk, even with
short-term exposure, is to young children and
pregnant women.
"Lead levels in your drinking water are
likely to be highest:
• if your home or water system hns lead
pipes, or
• if your home has copper pipes with lead
solder, and
—if.the home is less than five years old, or
—if you have soft or acidic water, or
—if water Bits in the pipes for several
hours."
(e) Notice by the State. The State may
give notice to the public required by this
section on behalf of the owner or
operator of the water system if the State
meets the requirements of paragraph (b)
and the notice contains all the
information specified in paragraphs (c)
and (d) of this section. However, the
owner or operator of the water system
remains legally responsible for ensuring
that the requirements of this section are
met.
(f) Enforcement by the State. AH
States shall enforce the requirements of
this section by June 19,1988, as required
by section 1417(b)(2) of the Act. If the
Administrator determines that a State is
not enforcing these requirements, the
Administrator may withhold up to five
percent of the State program grant fund
under section 1443(a) of the Act.
Handbook for Special Public Notification for Lead
51
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APPENDIX G
ENVIRONMENTAL PROTECTION AGENCY
REGIONAL OFFICES
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGIONAL ORGANIZATION
EPA Regional Offices
EPA Region 1
Water Supply Branch
JFK Federal Building
Boston. MA 02203
(617) 853-03610
Connecticut, Massachusetts,
Maine, New Hampshire. Rhode
Island, Vermont
EPA Region 2
Water Supply Branch
26 Federal Plaza
New York. NY 10278
(212) 264-1800
New Jersey. New York. Puerto
Rico. Virgin Islands
EPA Region 3
Water Supply Branch
841 Chestnut Street
Philadelphia, PA 19107
(215) 587-8227
Delaware. Maryland,
Pennsylvania,
Virginia, West Virginia, District of
Columbia
EPA Region 4
Water Supply Branch
345 Courtland Street. N.E.
Atlanta, GA 30365
(404) 881-8731
Alabama, Florida. Georgia.
Kentucky. Mississippi. North
Carolina, South Carolina.
Tennessee
EPA Region 5
Water Supply Untndi
230 South Dearborn Street
Chicago, 1L 60604
(312) 353-2650
Illinois. Indiana. Michigan.
Minnesota. Ohio. Wisconsin
EPA Region 6
Wiler Supply Branch
144S Ron Avenue
Oillu, TX 75202
(214) 655-6444
Arkansas, Louisiana, New Mexico,
Oklahoma, Texas
EPA Region 7
Water Supply Branch
726 Minnesota Avenue
Kansas City, KS 66101
(913)236-2815
Iowa. Kansas. Missouri, Nebraska
EPA Region 8
Water Supply Branch
One Denver Place
999 18th Street, Suite 1300
Denver, CO 80202-2413
(303) 293-1413
Colorondo. Montana, North
Dakota,
South Dakota, Utah, Wyoming
EPA Region 9
Water Supply Branch
215 Fremont" Street
San Francisco, CA 94105
(415) 974-0912
Arizona, California, Hawaii,
Nevada, American Samoa, Guam,
Trust Territories of the Pacific,-
Norlhern Mariana Islands
EPA Region 10
Water Supply Branch
1200 Sixth Avenue
Scatllu. WA 98101
(206) 442-4092
Alaska. Idaho, Oregon,
Washing" ton
52
Handbook for Special Public Notification for Lead
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APPENDIX H
STATE PUBLIC NOTICE FOR LEAD
The public notice requirement for lead gives states the option of giving public notices on
behalf of public water systems. These notices, however, must contain all of the same information
that is required in notices given by individual systems. In other words, regardless of the
method used, state notices must meet the same standards and requirements as
notices prepared by Individual water systems. General guidelines are as follows:
Listing of Public Water Systems
A listing of all community and non-transient non-community public water systems, with
system-specific (Appendix D) information and a telephone number for each, is preferred.
Where the notice involves a large number of systems, categorization is allowed. That is, the
notice should list, by method used to mitigate lead content, the public water systems(with
telephone numbers) utilizing that method. For example, the notice could list, under one
heading, all systems that are replacing lead pipe during regular repairs; under another
heading, all systems that have banned the use of lead solder. Systems taking no specific
measures related to lead except, for example, conducting routine monitoring would not have
to be listed. However, the notice must clearly state that certain systems are not listed and the
reasons why. A state telephone contact number(and preferably the name of an individual)
should be provided not only as a source of additional information concerning the lead notice,
but also to assist consumers in reaching systems not listed.
Non-Transient Non-Community Water Systems
The notice should indicate that non-transient non-community water systems are not
currently required to monitor for lead. The state may wish to indicate those systems that may
be monitoring (if any). States are responsible for including in the notice system-specific
(Appendix D) information and system telephone numbers for non-transient non-community
water systems, in the same manner as community water systems.
As in the case of local systems, the statewide notice and source of information cannot be used to
frustrate the purpose of the notice.
Under all circumstances public water systems remain legally liable for giving
public notice. They cannot assume that states will give notice on their behalf. If there is any
doubt, public water systems should contact their state regulatory agency. Likewise, states
intending to give statewide notices are encouraged to contact EPA for assistance. EPA regional
offices shown in Appendix G can provide information and state contacts.
*U.S. Government Printing Office 1988 - 516-002/80067
Handbook for Special Public Notification for Lead 53
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