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The Flint, Michigan Water Crisis: A Case Study in Regulatory Failure and

Environmental Injustice

Article  in  Environmental Justice · August 2016

DOI: 10.1089/env.2016.0014

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Original Articles

The Flint, Michigan, Water Crisis: A Case Study in Regulatory Failure

and Environmental Injustice

Lindsey J. Butler, Madeleine K. Scammell, and Eugene B. Benson

ABSTRACT

The Flint water crisis highlights numerous regulatory failures related to federal drinking water regulation, interpretation, and enforcement. The events that unfolded in Michigan, from the initial utilization of a corrosive water source to provide Flint’s drinking water to the inadequate response of numerous reg- ulators, demonstrate how the Safe Drinking Water Act (SDWA) can be wrongly interpreted, im- plemented, and weakly enforced, leading to dangerous exposure to unsafe drinking water. Our objective is to discuss these regulatory failures in Michigan in 2014–2015 in the context of other reported incidents of U.S. cities with high levels of lead in drinking water. Like the people of Flint, many of the affected residents are living in economically depressed areas with high rates of racial minorities. The recurring trend of unsafe drinking water in communities with this demographic profile qualifies this as an issue of environmental injustice.

INTRODUCTION

The development of engineered infrastructure todeliver potable water to societies may have begun as early as the Neolithic period. Archeologists most recently discovered that early civilizations dug wells to supply drinking water to their communities as early as 6500 BC.1 A characteristic of any successful society through- out history has been its ability to supply potable water to its citizens. Now, technological advancements allow for the delivery of water at rapid speeds to millions of people in dense urban areas. In the United States alone, more than 286 million people get tap water from a community water system. Large municipal water suppliers provide the majority of water to U.S. communities, with only 8%

of community water systems providing the water for 82% of the U.S. population.2 As the old adage goes, com- munity water systems are an extremely efficient way to distribute a health promoting substance to a community at once. They are also an extremely efficient way to distribute a poison.

Domestically, one of the greatest public failures of modern water supply began on April 10, 2014, in Flint, Michigan.3 In terms of threats posed by environmental contaminants, lead holds the title of the most well- established threats to children and pregnant women. Lead exposure in children may result in anemia, kidney dam- age, colic, muscle weakness, and brain damage. Exposure to the fetus during pregnancy can result in fetal death, premature delivery, low birth weight, and lower intelli- gence in later childhood.4 In adults exposed to high levels

Lindsey J. Butler is a PhD student at Department of Environ- mental Health, Boston University School of Public Health, Bos- ton, Massachusetts. Dr. Madeleine K. Scammell is an assistant professor at Department of Environmental Health, Boston Uni- versity School of Public Health, Boston, Massachusetts. Eugene B. Benson is an adjunct professor at Department of Environ- mental Health, Boston University School of Public Health, Boston, Massachusetts.

1Eli Ashkenazi. ‘‘Ancient Well Reveals Secrets of First Jez- reel Valley Farmers.’’ Haaretz.com, 9 November 2012.

2Centers for Disease Control and Prevention. ‘‘Public Water Systems j Drinking Water j Healthy Water j CDC.’’ http:// www.cdc.gov/healthywater/drinking/public/index.html (Last accessed on April 26, 2016).

3Matthew Davis, et al. ‘‘Flint Water Advisory Task Force Final Report.’’ Commissioned by Governor Rick Snyder March 21, 2016.

4‘‘ATSDR—Public Health Statement: Lead.’’ http://www .atsdr.cdc.gov/phs/phs.asp?id=92&tid=22 (Last accessed on April 25, 2016).

ENVIRONMENTAL JUSTICE Volume 9, Number 4, 2016 ª Mary Ann Liebert, Inc. DOI: 10.1089/env.2016.0014

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of lead occupationally, there is increased risk of peripheral neuropathy, increased blood pressure, and all cause car- diovascular mortality. The U.S. Department of Health and Human Services classifies lead and lead compounds as reasonably anticipated human carcinogens.5

Although the majority of lead exposure to children comes from the ingestion of lead paint chips and dust, the CDC estimates that 10%–20% of children’s exposure to lead is from their drinking water.6

Flint, Michigan: a man-made disaster

Flint, Michigan, has been overburdened with pollution dating back to the 1930s when the area’s booming auto industry manufactured batteries, paints, lacquers, enamels, and gasoline, releasing the by-products of these processes into the city’s air, water, and soil. The Flint River carried the toxic effluent of a city that was at one time an industrial mecca and economic powerhouse.7 Today, the economic landscape of Flint has changed dramatically. The popula- tion has dropped to about 100,000 people (from over 200,000 in the 1960s) and 41.6% of those people are living below the poverty level.8 Over the years, the auto industry has left Flint, taking with it the city’s economic success. The economic deprivation of Flint not only gave birth to a drinking water crisis but also exacerbated its effects.

In an effort to address the severe economic distress of the city of Flint, the state of Michigan used the Local Financial and Stability of Choice Act to replace the city’s government with an Emergency Manager on November 29, 2011.9,10 Emergency managers had been appointed by the state of Michigan in other cities suffering similar economic hardship, including Detroit. The law is designed to safeguard and assure the financial accountability of the local governments.10 However, the less tangible danger of such appointed and transient officials is in removing the sense of accountability held by elected officials. The re- moval of this accountability led the way for economic- driven decision making that failed to adequately protect the interests of the electorate, and public health.

In the months following the switch of water supplies, the corrosive water caused contamination of lead and bacteria throughout the water system. As the contami- nation became known, residents fought to have it miti- gated and were failed by multiple government agencies.

Further details of the timeline of the crisis and lack of response are provided supplementary to this article. We now discuss these particular failures in the context of similar failures to protect vulnerable populations from lead in drinking water across the country, and actions to prevent such failure in the future.

DISCUSSION

Safe Drinking Water Act

The purpose of the Safe Drinking Water Act (SDWA) passed by Congress in 1974 is to protect the nation’s public drinking water supplies and public health. Under the SDWA, the United States Environmental Protection Agency (EPA) has the authority to set national health- based standards for contaminants that could appear in drinking water from both anthropogenic and naturally occurring sources. Although the SDWA is a federal law and the EPA establishes mandatory standards for con- taminants, administration and enforcement of the law may be carried out by states. States can apply for ‘‘pri- macy,’’ which gives them the authority to enforce the SDWA in their state jurisdiction. In their application for primacy, the state must prove that it can adopt standards in the state equal or greater than those set by the SDWA and that it can make sure that community water suppliers are meeting those standards. Today, every state has SDWA primacy, with the exception of Wyoming.11

Failure of the SDWA in Flint

On February 3, 2016, the House Committee on Oversight and Government Reform convened to examine the federal administration of the SDWA in Flint, Mi- chigan. They determined that there was failure at every level of government. The EPA was made aware of the high levels of lead in Flint drinking water in April 2015 but did not act until January 2016 when fierce media attention prompted them to act. Under the SDWA, the EPA must step in and enforce the law when it is brought to their attention that the primacy state is not adequately enforcing the law. The Oversight Committee established that EPA staff member, Miquel del Toral, attempted to move the EPA to act on their obligation to assert control over the Flint crisis and the EPA failed to do so in a timely manner in direct violation of the SDWA.12

Lead and copper rule

Under the SDWA, the EPA sets National Primary Drinking Water Regulations, which are legally enforceable

5Centers for Disease Control and Prevention. ‘‘Lead in Drinking Water and Human Blood Lead Levels in the United States.’’ MMWR 2012; 61:2.

6Rebecca Renner. ‘‘Out of Plumb: When Water Treatment Causes Lead Contamination.’’ Environmental Health Perspec- tives 117 (2009): A542–A547.

7David Rosner. ‘‘Flint, Michigan: A Century of Environmental Injustice.’’ American Journal of Public Health 106 (2016): 200– 201.

8U. S. Census Bureau. ‘‘American FactFinder—Community Facts.’’ http://factfinder.census.gov/faces/nav/jsf/pages/community_ facts.xhtml (Last accessed on April 26, 2016).

9‘‘Order No. 3 Emergency Manager City of Flint Genesee County Michigan City Administartor.’’ April 10, 2015.

10Michigan State Legislature. Local Financial Stability and Choice Act, PA 436, 2013.

11OW US EPA. ‘‘Overview of the Safe Drinking Water Act.’’ Policies and Guidance. https://www.epa.gov/sdwa/overview- safe-drinking-water-act (Last accessed on April 27, 2016).

12‘‘Examining Federal Administration of the Safe Drinking Water Act in Flint, Michigan.’’ United States House Committee on Oversight and Government Reform, hearing date March 15, 2016. https://oversight.house.gov/hearing/examining-federal- administration-of-the-safe-drinking-water-act-in-flint-michigan (Last accessed on April 27, 2016).

94 BUTLER ET AL.

standards that public drinking water suppliers must meet. There are more than 80 contaminants on the list with a legally enforced maximum contaminant level (MCL) de- termined by the EPA to protect public health. They include microorganisms, disinfectants, disinfection by-products, inorganic chemicals, organic chemicals, and radionuclides. The contaminant levels are measured as they are leaving the treatment plant. There are two exceptions; lead and copper are regulated by treatment technology that requires the system to control the corrosiveness of the water. Unlike the other contaminants, lead and copper are also measured at the tap in a subsample of homes to monitor contami- nation of the water by these chemicals that may have oc- curred as the water moved through the pipe network.13

Before 1991, the MCL for lead in drinking water was 50 ppb, measured as the water entered the distribution sys- tem network. In 1991, the lead and copper rule (LCR) was passed to reduce levels of lead and copper in drinking water and to address that lead and copper likely enter the water from corrosion of plumbing materials after entering the pipe network, and hence, it is appropriate to measure these contaminants at the tap.14 The LCR applies to all commu- nity water supplies and sets a maximum contaminant goal for lead in drinking water at 0 and an action level (AL) at 15 ppb. The AL is based on the 90th percentile. If the 90th percentile level of tap water samples is above 15 ppb, then actions must be taken to address the lead levels. These ac- tions include water quality parameter (WQP) monitoring, corrosion control treatment, source water monitoring/treat- ment, public education, and lead service line replacement.15

The law states that the community water supply must take first-draw samples at homes that are at high risk of lead and/or copper contamination. A first-draw sample means that the water has been sitting for 6 hours in the plumbing before turning on the faucet. Homes at high risk include older homes that may have lead plumbing or are located in neighborhoods that have historically had high levels of lead in drinking water. The community water supply does not have to sample from all of the homes in the system. The number of samples is determined by the size of the system. For a system the size of Flint, they likely would need to sample for lead and copper at 100 homes on a standard sampling schedule and 50 homes on a reduced sampling schedule. A supplier qualifies for a reduced sampling schedule by having written state approval after having two consecutive 6-month sampling cycles where the 90th percentile was below the AL of 15 ppb. A system also has to conduct WQP testing at the tap in addition to the lead and copper sampling. WQP testing must be done at the entry point of the pipe network and at 25 taps (for a

large system on a standard schedule) or 10 taps (for a large system on a reduced schedule). The LCR also states that within 30 days of acquiring the results, the community water system must provide the results to the people who receive their water from the tap sampled, regardless of whether the system is above or below the AL.3

Failures of the LCR in Flint

On December 31, 2014, the first 6-month round of LCR sampling in Flint ended. As instructed by the LCR for a community supplier of its size, Flint Water Treatment Plant (FWTP) sampled 100 homes. According to the Flint Water Advisory Task Force (FWATF) final report, the 100 samples were not drawn from the homes that represented the highest risk of lead and copper contamination. This was the first violation of the LCR. The 90th percentile lead level at the end of this sampling round was 6 ppb; well below the AL of 15 ppb. However, in addition to a flawed sample selection strategy, appropriate sampling protocols were not followed at the tap. Under the LCR, the sample should be a first draw after the water has been stagnant in the pipes. The Michigan Department of Environmental Quality (MDEQ) improperly instructs all Michigan com- munity water suppliers to do a preflush of the tap the night before the sampling. This interferes with the validity of the first-draw sample and could explain why samples in that first 6-month cycle were lower than samples taken at the same locations on subsequent dates. Preflushing the night before sampling was the second violation of the LCR.16

The results of the first round of sampling disqualified the Flint Water Supply from the corrosion control ex- emption because it failed to achieve the required results. The law states that they should have implemented cor- rosion control technology. The MDEQ failed to inform the FWTP about this part of the legislation and the FWTP did not implement corrosion controls. The failure to implement corrosion control was the third and most egregious violation of the LCR.3

On February 27, 2015, MDEQ staffer Stephen Busch e-mailed the EPA reporting that the 90th percentile for the first sampling period was 6 ppb and Flint had an optimized corrosion control system. This was apparently dishonest, as Flint was not utilizing any corrosion con- trols at that point. Criminal charges have since been brought against Mr. Busch and two others.16,17

Inadequate response and environmental justice

As the House Committee on Oversight and Govern- ment Reform concluded in their proceedings on the

13OW US EPA. ‘‘Table of Regulated Drinking Water Con- taminants.’’ Overviews and Factsheets. https://www.epa.gov/ your-drinking-water/table-regulated-drinking-water-contaminants (Last accessed on April 27, 2016).

14OW US EPA. ‘‘Lead and Copper Rule.’’ Policies and Guidance. https://www.epa.gov/dwreginfo/lead-and-copper-rule (Last accessed on April 26, 2016).

15‘‘Lead and Copper Rule: A Quick Reference Guide’’ (US EPA). http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=60001N8P.txt

16Monica Davey and Abby Goodnough. ‘‘Emails Deepen Criminal Cases in Flint, but Charges May Be Tough to Prove.’’ The New York Times, 24 April, 2016. http://www.nytimes.com/ 2016/04/25/us/emails-deepen-criminal-cases-in-flint-but-charges- may-be-tough-to-prove.html

17Monica Davey and Richard Pérez-peña. ‘‘Flint Water Crisis Yields First Criminal Charges.’’ The New York Times, 20 April, 2016, http://www.nytimes.com/2016/04/21/us/first-criminal- charges-are-filed-in-flint-water-crisis.html

REGULATORY FAILURE IN FLINT 95

situation in Flint, government failed the residents of Flint at every level. During the hearing, Representative Jody Rice (R-GA) went on record as saying: ‘‘I don’t know Mr. Chairman, that there’s been more of a catastrophe in gov- ernment handling of an issue since Hurricane Katrina.’’20

The list of agencies that could have stepped in at some point and prevented the exposure in Flint homes for over 16 months includes the Emergency Manager, the MDEQ, the Environmental Protection Agency, the Michigan Depart- ment of Health and Human Services, the city of Flint, and the state of Michigan. There were numerous opportunities for regulatory agencies to do right by the residents of Flint. Perhaps the most perplexing question as the saga of Flint unfolded is ‘‘Why did it take so long for action?’’

It can be argued that the birth of this crisis, the inad- equate government response to the disaster, and the blatant disregard for the public health were, in part, the result of the racial and economic characteristics of Flint.21 The community of Flint is 62.6% people of color, 41.6% of individuals live below the poverty level, 54.5% of households with a child younger than 5years below the poverty level, 25.7% of adults older than 18 years have less than a high school education, and the median income in 2014 was less than half of the median income for the United States.8 What role did this play in the crisis?

On January 17, 2016, the National Association for the Advancement of Colored People (NAACP) released a statement regarding the Flint water crisis, which read, in part, ‘‘We must hold accountable Michigan’s public of- ficials who chose to balance the city’s budget at the ex- pense of the health of the citizens they serve. Even as children were showing up sick in doctor’s offices with rashes and cases of hair loss, state environmental officials and elected leaders refused to see the warning signs. Would more have been done, and at a much faster pace, if nearly 40% of Flint residents were not living below the poverty line? The answer is unequivocally yes.’’22

Communities with lead problems

As media outlets, including the New York Times, the Washington Post, USA Today, the Guardian, CNN, and others, conducted investigative reporting of the Flint water crisis, it became clear that although the narrative of Flint, Michigan, was dramatic, it was unfortunately not new. Stories from other cities both past and present highlight failures of implementation and enforcement of drinking water regulations and consequential contamination of

drinking water. Many of the impacted communities share Flint’s racial and economic characteristics.

Evidence of environmental injustice

From 2001 to 2004 in Washington DC, elevated blood lead levels were tied to widespread lead contamination in drinking water.23 A well-publicized cover up of the se- verity of this incident was revealed in 2003 by Professor Marc Edwards and others.24 Washington DC is 61.5% minority race and 18.2% of individuals live below the poverty line.8 In 2005, 10 of the community water sup- pliers for the city of Columbia, South Carolina, were found to be out of compliance with the LCR.25 Columbia, South Carolina, is 48.3% minority race and 24.2% of in- dividuals live below the poverty line.8 In 2006 in Durham and Greenville, North Carolina, elevated blood lead levels in children were traced to lead levels in drinking water of 20 ppb. When a child’s pediatrician recommended the child’s food stop being prepared in water from the mu- nicipal water supplier, the child’s lead levels returned to normal.26 Durham, North Carolina, is 53.6% minority race and 18.1% of people live below the poverty level. Greenville, North Carolina, is 43.7% minority race and 30.7% of individuals live below the poverty line.8 In July 2015, residents of Jackson, Mississippi, were warned about high lead levels in their drinking water, 6 months after the problem was first discovered.27 Jackson is 81.6% minority race and 29.9% of individuals live below the poverty line. In February 2016 in Ithaca, New York, the public drinking water was shut off at every school in the city due to the detection of high levels of lead in the water.28 Ithaca, New York, is 43.7% minority race and 30.7% of individuals live below the poverty line.8

These communities experienced environmental injus- tice. EPA defines environmental justice as ‘‘the fair treatment and meaningful involvement of all people re- gardless of race, color, national origin, or income, with respect to the development, implementation, and en- forcement of environmental laws, regulations, and poli- cies.’’ The EPA goal is ‘‘for all communities and persons across this nation.to enjoy the same degree of protec- tion from environmental health hazards and equal access

20‘‘Examining Federal Administration of the Safe Drinking Water Act in Flint, Michigan.’’

21Mike Ludwig. ‘‘Environmental Justice: What the Candi- dates Missed in Flint - and the Rest of the Country.’’ Truthout. http://www.truth-out.org/news/item/34552-environmental-justice- what-the-candidates-missed-in-flint-michigan-and-the-rest-of-the- country (Last accessed on April 25, 2016).

22NAACP. ‘‘NAACP Statement Regarding Flint, Michigan Water Crisis j Press Room.’’ January 17, 2016. http://www .naacp.org/press/entry/naacp-statement-regarding-flint-michigan- water-crisis1 (Last accessed on April 26, 2016).

23Marc Edwards, Simoni Triantafyllidou, and Dana Best. ‘‘Elevated Blood Lead in Young Children due to Lead- Contaminated Drinking Water: Washington, DC, 2001–2004.’’ Environmental Science & Technology 43 (2009): 1618–1623.

24Marc Edwards. ‘‘81st Water Science and Technology Board Meeting’’ (Washington, DC, April 19, 2016).

25Michael Wines and John Schwartz. ‘‘Unsafe Lead Levels in Tap Water Not Limited to Flint.’’ The New York Times, 8 Feb- ruary, 2016. http://www.nytimes.com/2016/02/09/us/regulatory- gaps-leave-unsafe-lead-levels-in-water-nationwide.html

26Renner. ‘‘Out of Plumb.’’ 27Wines and Schwartz. ‘‘Unsafe Lead Levels in Tap Water

Not Limited to Flint.’’ 28Geoff Herbert j [email protected]. ‘‘Drinking Water

Shut off at Ithaca City Schools after High Lead Levels Detected.’’ Syracuse.com, 26 February, 2016. http://www.syracuse.com/ news/index.ssf/2016/02/ithaca_schools_drinking_water_lead.html

96 BUTLER ET AL.

to the decision-making process to have a healthy envi- ronment in which to live, learn, and work.’’29

The successful implementation and enforcement of the SDWA, including the LCR, and equal access to the decision-making process irrespective of race and income were not achieved in Flint, Michigan. It was not achieved in Washington, DC, or Columbia, South Carolina, or Greenville and Durham, North Carolina, or Jackson, Mississippi, or Ithaca, New York. The failure of these laws is disproportionately impacting economically de- pressed communities of color.

Revisions to the LCR

In part, due to the historical inadequacies of the LCR, the EPA is currently considering long-term revisions. The primary goals of the revision are to (1) improve the effectiveness of the corrosion control treatment in re- ducing exposure to lead and (2) trigger additional actions that equitably reduce the public’s exposure to lead and copper when corrosion control treatment alone is not effective. The EPA has sought input from multiple stakeholders and formed the National Drinking Water Advisory Council (NDWAC) LCR Working Group. The NDWAC recommends that the EPA focus on five key issues (1) sample site selection criteria, (2) lead sampling protocols, (3) public education for copper, (4) measures to ensure optimal corrosion control treatment, and (5) lead service line replacement.30 In March 2011, the EPA held a public meeting seeking comment on environ- mental justice considerations for the proposed revision.31

Many of the proposed revisions could have possibly prevented the situation that contributed to the Flint water crisis. However, in addition to improved regulation, it is important to note that the success of the LCR relies on enforcement. In cases where state agencies fail to ade- quately enforce the LCR, the EPA must step in imme- diately.

CONCLUSION

Lead is a potent neurotoxicant. The long-term effects of lead exposure to a child can be devastating and irre- versible. A 2016 survey conducted by the American Water Works Association estimates that there are 6.1 million lead service lines in use in the U.S. public drinking water system and between 15 and 22 million people are getting their water from either a partial or full

lead service line.32 Some lead service lines have been in the ground for more than 100 years.

Our county’s public water supply infrastructure is aging and deteriorating and municipal water suppliers are under resourced to address this problem. In some cities, like Flint, Michigan, water for drinking, cooking, and bathing our children is being carried for miles through pipe networks that are falling apart and leaching lead, one of the most dangerous chemicals modern science has been able to characterize.

Legislation to address this problem must be improved, strengthened, and actively enforced.

In 1797, the poet Samuel Taylor Coleridge penned the lines, ‘‘Water, water everywhere, nor any drop to drink.’’33 In Flint, Michigan, 219 years later these words still rang true. Flint residents were surrounded by water but had not a drop to drink. As highlighted by the United Nations Sustainability Goals, access to clean, safe drinking water is a basic human right.34

What happened in Flint and other cities in recent U.S. history is a sad disregard for public health and a failure of the deliverance and protection of the basic right of eq- uitable access to safe drinking water.

ACKNOWLEDGMENTS

The FWATF, appointed by Michigan Governor Rick Snyder, published the final report in March 2016, sum- marizing what happened in Flint, assigning responsibil- ity, and offering recommendations for the future. The authors of this article rely heavily on the details provided in the FWATF report. In addition, authors relied on the exhaustive investigative reporting on Flint and other communities impacted by lead in drinking water by journalists.

AUTHOR DISCLOSURE STATEMENT

No competing financial interests exist.

Address correspondence to: Lindsey J. Butler

Department of Environmental Health Boston University School of Public Health

Medical Campus 715 Albany Street, Talbot 4W

Boston, MA 02118

E-mail: [email protected]

29OA US EPA. ‘‘Environmental Justice.’’ Collections and Lists. https://www.epa.gov/environmentaljustice (Last accessed on April 25, 2016).

30OW US EPA. ‘‘National Drinking Water Advisory Council (NDWAC) Lead and Copper Rule Working Group (LCRWG) Meetings & Summaries.’’ Announcements and Schedules. https://www.epa.gov/dwstandardsregulations/national-drinking- water-advisory-council-ndwac-lead-and-copper-rule-working (Last accessed on April 27, 2016).

31‘‘Federal Register, Volume 76 Issue 31 (Tuesday, February 15, 2011).’’ https://www.gpo.gov/fdsys/pkg/FR-2011-02-15/ html/2011-3383.htm (Last accessed on April 27, 2016).

32David A. Cornwell, Richard A. Brown, and Steve H. Via. ‘‘National Survey of Lead Service Line Occurrence.’’ Journal - American Water Works Association 108 (April 1, 2016): E182– E191.

33Samuel Coleridge. ‘‘Rime of the Ancient Mariner.’’ Poetry Foundation. http://www.poetryfoundation.org/poems-and-poets/ poems/detail/43997

34Florencia Soto Nino. ‘‘Water and Sanitation.’’ United Nations Sustainable Development. http://www.un.org/sustainabledevelopment/ water-and-sanitation/ (Last accessed on April 26, 2016).

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