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CWWA meeting with Health Canada Regarding Proposed Guideline on Lead in Drinking Water

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A small group of CWWA members and staff met with Health Canada in mid-February to discuss the proposed draft Guideline on Lead in Drinking Water. This initiative was led in part by the AWWA Canadian Affairs Committee. In attendance were: 

Klas Ohman, Associated Engineering and Chair of CWWA’s Drinking Water Quality Committee
Reid Campbell, Halifax Water and member of the AWWA CAC
Michèle Grenier, Executive Director, Ontario Water Works Association 
Ian Douglas, City of Ottawa
Michèle Prevost, École Polytechnique

Representing Health Canada were members of the policy team who developed the guideline: Greg Carreau, France Lemieux and Michèle Giddings.

Proposed Changes
This Guideline would see the Maximum Allowable Concentration (MAC) for lead in drinking water significantly lowered, and the recommended sampling protocol changed to eliminate the practice of taking a flushed sample.

Our Concerns
CWWA recognizes that there is ample evidence that lead exposure, even at low levels, has health impacts and that lowering the MAC and maintaining lead at as low a level as possible is an important goal in ensuring the health of Canadians. 

However, we have several concerns regarding the implementation of the Guideline.

These changes would put many Canadian utilities suddenly out of compliance with the national Guideline, and depending on their provincial regulator, possibly with their regulatory authority. Many of our members are unsure how their provincial regulator will adopt the Guideline, and how quickly sampling protocols will be updated.

Many utilities are currently using the Health Canada corrosion control document to help develop corrosion control programs. This document does not align with the new proposed Guideline or sampling protocols. During the meeting, Health Canada indicated that they are aware of the disparity and that they will be revising the corrosion control document, however, it is expected to take some time before a revision is published.

Lead in drinking water is a complex problem, and will take time and money to fix. In some cases corrosion control can be very effective in lowering levels, but in others, extensive infrastructure replacement will be necessary to achieve the MAC - which is not only costly, but requires cooperation and investment from customers as well. 

CWWA and our members are concerned that the media could use the publication of the new guideline to paint water utilities as unsafe. When the Guideline is published, it will need a careful communication strategy from Health Canada, CWWA and our members to explain the complexity of the issue, and demonstrate what individual utilities are doing to meet the new MAC. 

Meeting Outcome
Our meeting with Health Canada was very positive. They recognize the sensitivity of the issue, and are committed to doing their part in effectively communicating the complexities of the situation. They indicated that, at this time, they don’t know how quickly individual provinces plan to require utilities to meet the MAC. They did point out that even in those who immediately adopt new guidelines as law, they tend to be slower to change sampling protocols, and that with most provinces allowing a substantial flush before sampling, utilities shouldn’t find themselves contravening legally binding limits immediately.

The need for Health Canada to engage Health Authorities before the Guideline is published was stressed. Health Authorities will be an important partner in communicating the risks and engaging customers on the health impacts of lead in drinking water. Ensuring that they are armed with the best information is going to be crucial to maintaining public confidence in water supplies.

At this time there is no clear indication of when the Guideline will be finalized and published. In the meantime CWWA encouraged Health Canada to work with Infrastructure Canada and other funding partners to create dedicated funds to help implement the lead Guideline – either by funding utilities, or programs to assist homeowners finance their share of service main replacement.

Next Steps
CWWA will continue to work with AWWA’s CAC to provide support to members. Our Water Quality Committee will be developing a formal issue analysis paper and position statement. The Association and partners will also be developing support materials to assist our utility members in answering questions on lead to their councils, public and the media. CWWA will also work with provincial/territorial/regional associations to engage their provincial regulators on a coordinated rollout 

The lowered MAC is coming and our members should be doing all they can to be prepared to answer customer inquiries and demonstrate their plans to address lead in their systems.

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