Letter to CEO Dr. Maxwell About Lead in PGCPS Water 2/26/2018

Dear CEO Dr. Kevin Maxwell, 

I have been receiving more questions about lead in the school water from parents across the District.

I was looking at the PGCPS Water Quality page and saw that new lead in water tests were posted by PGCPS. More water sources were found to have lead. I very much appreciate that the county is taking more time to address this issue but far more needs to be done. I first raised this issue well over a year ago now and began my inquiries alongside other parents in January 2016. It is now February 2018 and their is still unsafe levels of lead in our water supply. 

Here are my questions about the school water lead levels now reported by the county.  

1. Where are the Fairmont Heights , the Ardmore, , the Henry Wise,  the Bowie High Annex-  lead in water 2018 PGCPS tests ? 

The document PGCPS placed online states that lead tests on these schools and others were done in 2018 but I cannot find any levels documented. The fields are blank. Can you update that spreadsheet found on this page to include the lead test numbers please http://www.pgcps.org/water-quality-program/ 

2. Who made the decision for 10 ppb to be the PGCPS lead in water threshold? What staff? What is their expertise in the issue of children's health please? PGCPS is currently allowing 10ppb in the water and I and others would like documentation of how you came up with this number. What scientific documentation was used to recommend 10 ppb as the lead in water threshold for the school? Please share the medical documentation that supports the use of this threshold as well so the community can understand why the county is allowing this level of lead in the water. 

3. There are many times where a water tap showed high levels and then retests were done. Which test are you using for a cut off? Are you using the first or second draw  test? it is unclear from the spreadsheets that you posted. 

4. If a test shows a number over 10 ppb and then retests to a number  under the PGCPS threshold, what is your course of action? For example if a tap reads at 12ppb at first draw and then retests at 20 ppb.. what does pgcps do? Is the water turned off? 

5. Are parents being informed of the lead tests in these schools? I would like to share with you that in other states, parents are sent a paper that looks like this -Barryingtom Elementary School lead letter for parents http://www.chsd.us/admin/reports/water_reports/Barryton%20Lead%20Copper%20Notification.pdf and they are told the exact numbers of the exact taps. Why are PGCPS parents not receiving such letters in their school? Please explain why PGCPS is not informing parents of  the same information as given to parents in other school districts? 

6. Send me the current list of ALL the schools with water shut offs and specifically which fountains are being shut off in each school AND the date of shut off. I think the best way to do this is to integrate this information into the spreadsheet PDF of lead tests you have online on your water quality page. Please add date of water shut off or if the water source is left on please state "Water left on"  and have the date for each action right there next to the lead level numbers. . 

7. Are bathroom and kitchen taps being tested? Please confirm this because children often cup hands and drink from the sink. Some school lead tests are only like 7 taps so Im sure there are more water sources in the school. Where are these numbers? 

8. Some taps are testing at very high levels on the first draw but then going down on the second draw. 

For example a tap at Fort Washington Elementary tested at 1390 ppb in 008A on the first draw in  and then on the second draw it tested at 20.8. So the lead number had an over 1000 times variation just by virtue of timing. 

For example at tap at Rose Valley Elementary tested at 2830 ppb   on the first draw in  and then on the second draw it tested at 32.7  

For example a tap at Allen Wood Elementary tested at 60 ppb on the first draw in  and then on the second draw it tested at 10.9. 

Forest Heights Elem had a tap that read at 9480 and then on the second draw was 3260. These numbers are quite astounding. 

Forest Heights Elem also had  a tap that read at 11 800 and then on the second draw was 20.2 These numbers are quite astounding. 

Indian Queen  Elem had a tap that read at 192, 000 (yes, this is not a typo) and then on the second draw was 615. That is a 312 times decrease in lead in the water with the second draw. These numbers are quite astounding. 

The above information  shows the variations in lead levels depending on the time of the test. These variations are large. 

Some taps are testing at lower levels on the first draw but then the numbers went up the second draw. 

For example Doswell E Brooks room 023A had a first reading of 25.1 ppb and t went up to 226 ppb  on the second draw.  

For example Kettering Middle room 134A had a first reading of  44.5 and it went up to  309 on the second draw. 

For example a tap at University Park Elementary had a first reading of  94.5 and it went up to  159 on the second draw. 

For example a tap at Pointer Ridge Elementary had a first reading of  16.3 and it went up to 31.7 on the second draw. 

Thus, it seems safe to say that if lead is found, the number can vary widely depending on when the sample is taken. The number can be double, triple or even almost ten times more on the second draw- or less.  10 ppb as a threshold is not protective- even for that limit-  as the tap could read higher or lower at any time. We do not know when a child or pregnant woman could drink it. 

Can you respond this concern please. 

9. I am asking PGCPS to immediately update their threshold to 0ppb as the allowable amount of lead in the water. If a tap tests higher and has lead- then the water should be not used for drinking, signs should be placed at the source to inform children and staff. Taps should be tested at least two times. Fresh lead free water should be provided to the children and staff. Below is the documentation that supports this. Please respond as to why you have not taken these steps. We have been asking for over a year now. Thank you for your immediate consideration of this issue. 

The EPA, the American Academy of Pediatrics  and the CDC  state there is no safe level and 0 ppb is the health standard. This means only 0 ppt is safe. However current regulations do not enforce this health based standard. Instead the only law we have states that schools need to be under 20 ppt and water to homes needs to be 15ppb  and under . These 25 year old regulations do  not ensure safety for our school children.

0 ppb: EPA Health Limit- Maximum Contaminant Level Goal- A Health Standard- for Lead in Water Limit

Read it here EPA DRINKING WATER STANDARDS AND HEALTH ADVISORIES TABLE https://www.epa.gov/sites/production/files/2015-09/documents/dwstandards2012.pdf

below 1 ppb: American Academy of Pediatrics Recommends below  1 ppb for Schools.

The American Academy of Pediatrics (AAP) Report on prevention of Lead Toxicity states "state and local governments should take steps to ensure water fountains in schools do not exceed water lead concentrations of 1ppb." Please download the AAP report by clicking here

0.2 ppt  California's Office of Environmental Health Hazard Assessment (COEHHA)

The COEHHA revised the state's public health goal for drinking water to 0.2 parts per billion, a fraction of the threshold established by the EPA. "A revised Public Health Goal (PHG) of 0.2 ppb (or 0.2 µg/L) for lead in drinking water is established, on the basis of new studies relating neurobehavioral deficits to lower lead concentrations in the blood than previously reported."

Read it here https://oehha.ca.gov/media/downloads/water/chemicals/phg/leadfinalphg042409_0.pdf

10: The EPA states that 3Ts of adressing lead in schools are:

• Training school officials to raise awareness of the potential occurrences, causes, and health effects of lead in drinking water; assist school officials in identifying potential areas where elevated lead may occur; and establishing a testing plan to identify and prioritize testing sites.
• Testing drinking water in schools to identify potential problems and take corrective actions as necessary.
• Telling students, parents, staff, and the larger community about monitoring programs, potential risks, the results of testing, and remediation actions.

"There is no safe level of lead exposure for children. Researchers have found that children can have health effects when exposed to even the lowest levels of lead, so it is critical to prevent exposure. Infants, young children and pregnant women are at greatest risk. Health effects can include damage to the brain and kidneys, reduced IQ and other behavioral and neurological impairments. The effects of lead have been linked to reduced performance in schools which compounds the disadvantages for children. Ensuring lead-free drinking water in schools helps not only the at-risk child but the entire school community. "

Read the EPA letter to the State of New York here that this quote is from here 

http://www.p12.nysed.gov/facplan/documents/Lead-DrinkingWater-EPAlettertoNYSSuperintendentswAtt_05-26-16.pdf

The letter states that the EPA has a voluntary program that guides schools and districts through the process of sampling, and communicating the results and remediating" Is PGCPS taking advantage of this program? 

11.  Scientific research shows that lead in combination with wireless radiation can exacerbate the effects of lead.

For example, Research investigating cell phone radiation in combination with the lead- which is a known neurotoxin- has found that children with blood lead levels had higher ADHD like symptoms if they also had higher cell phone use. This finding has lead the researchers to consider a potential synergetic effect between lead and radio frequency (RF) fields, meaning the RF exposure increased the effects from the lead exposure.  In fact, multiple research studies have found that electromagnetic fields such as Wi-Fi and cell phone radiation can increase the effects of a known toxic exposure.  Researchers have repeatedly found a tumor promotion effect from this type of radiation.

Radiofrequency wireless and cell phone radiation exposure has also been shown to affect the permeability of the blood-brain barrier (BBB), as well as altering the expression of microRNA within the brain, which researchers state could lead to adverse effects such as neurodegenerative disease. When the BBB is more permeable, more toxins circulating in the blood can reach the brain- this applies to lead of course.

In 2009,  Dr. Leif Salford a neurosurgeon at Lund University Hospital  and Chairman of the Department of Neurosurgery presented his published research studies that found blood-brain barrier (BBB) leakage after very very low levels of exposure to radiofrequency radiation. These studies have been confirmed and expanded on by researchers from China who concluded, “these results demonstrated that exposure to 900 MHz EMF radiation for 28 days can significantly impair spatial memory and damage BBB permeability in rat by activating the mkp-1/ERK pathway.”  

Therefore the combination of lead plus wireless could exacerbate the effects of lead in children, even at low levels and cause more damage to the brain. I have shared with you and the school board that over 150 doctors recommend that wireless exposure be reduced to pregnant women. Read more here https://ehtrust.org/science/pregnancy-wireless-and-electromagnetic-fields/

Currently many schools in internationally  are removing the wireless from schools and governments are issuing new directives to remove wireless radio frequency from schools. For example Cyprus has removed wireless from elementary schools. France has turned the Wi-Fi off as well so that OFF is the default setting. Many countries have banned Wi-Fi from kindergarten such as France, Israel, Ghent Belgium etc. Read about that here https://ehtrust.org/policy/international-policy-actions-on-wireless/

12.   I understand that some schools have ALL water off in an abundance of caution even those taps that are lower than 10ppb. Yet in other schools these taps are left on under 10 ppb. I think this is not fair. All schools should be afforded this protection. 

For example, Glenridge Elementary had all the water  turned off- even before they had the water tested! (And when it was finally tested --many many faucets were found to be too high by the way. As I understand it, the decision to turn the water off was because a PG parks childcare was on site. There was concern that any lead could be unsafe so they took action proactively. The fact that ANY lead was found- be it at 7 or 8 was a potential problem for staff and it made sense to turn it all off. I did a public information request and found this out, as well as talk to staff.  Is this still the case? 

Why are Glenridge children  treated differently than other children in the PGCPS community? 

So please clarify why some schoolchildren are being afforded this protection of a 0 ppb lead threshold and other  school children have the 10 ppb threshold for PGCPS action. Please also send me the list of schools that are using the 0ppb as a threshold. 

13. Families Against Chemical Toxins has offered to help by paying for filtered water sources in schools that are experiencing lead in their water.  See  http://www.familiesagainstchemicaltoxins.org . Can this be offered to schools that want to ensure healthy drinking water in their schools? I was contacted by the organization. 

14,  Some parents have told me that their children are NOT getting access to drinking water all day. Children must have unrestricted access to safe water throughout the day. Please state in the spreadsheet what the plan is for each school in terms of providing safe drinking water for each school. 

Children and pregnant teachers and staff are most at risk from lead exposure. There is no safe level of lead. Please ensure the drinking water is safe by lowering the lead threshold to 0ppb and ensuring children and staff have access to water throughout the day. 

Please inform the parents and teachers and fully share information about this process by sending a letter home with the lead readings to the parents of each school. We need more information as to hat is being done in each school.

Thank you so much for your attention and thoughtful consideration of this matter. I look forward to the answers to these questions.