Guest Blog: Dr. Susan Masten (Michigan State University)
Michigan Governor Gretchen Whitmer recently held a round-table discussion in Flint on April 10, 2019 in which Kettering University’s Dr. Laura Sullivan (FACHEP) made specific claims about Flint’s water quality, sampling methodologies, perceived disregard for Flint’s poor and public schools, and potential manipulation in protocols by state officials when conducting tests in Flint schools. In this blog, I will investigate the veracity of Dr. Sullivan’s claims.
Dr. Sullivan Comment 1: There are parts of Flint that are not being tested at the same sort of regularity as others and it tends from what I can see to be the parts of Flint where the people are the poorest which turns out because of blight and water age the parts of Flint that might actually have the worst water and so I would like there to be a sort of conscious effort to make sure that when water is being tested and we are reporting that you know we’re under the 15 ppb or 10 ppb whatever threshold in parts of Flint that we can say with confidence that we’ve evaluated water in the parts of Flint that are being overlooked or just not given the kind of attention that they probably need more than any other parts of Flint.
Dr. Masten’s Response: I would like to know what evidence Dr. Sullivan has that some areas of Flint are not being tested as regularly as others. In fact, it seems to me that a conscious effort has been made to ensure that sampling programs cover all areas of Flint. As one example, the map below (Figure 1 bottom; dated May 2018) illustrates the revised monitoring program for chlorine residual and E. coli. The map shows that the new monitoring stations are evenly distributed across the city, and monitoring stations are located in poorer areas and areas with a high percentage of racial minorities. To my knowledge, there is no evidence to support the implication that the poorest parts of Flint are being systematically ignored.
As to the question of water age, a major effort has already been made to address the issue of water age. The January 2018 report on hydraulic modeling illustrates that monitoring stations #3 and #4 are located in the southwest corner of the city which has very high water age (see Figure 2). The 4th quarter data (the most recent quarterly data available) indicate that the chlorine levels are within an acceptable range (1.08 to 1.82 mg/L), while phosphate levels, turbidity and iron are similar to those in the rest of the city. Unfortunately, the system is oversized and as the report concludes “because of Flint’s low customer demands and a large number of dead ends, widespread solutions for high water age may not be possible.” However, very clearly conscious efforts are being made to address this issue.
Dr. Sullivan Comment #2: The other part of my question is related to the testing of the water in schools. Just, I don’t know exactly what caused this oversight, but the lead and copper rule and the Safe Drinking Water Act does not talk about testing water in schools. And it wasn’t until we were into this crisis then looked around the room and said “Ok, so who is testing the water in schools? Then we realized that,” … but the problem is then in my view the protocol for developed by people in a room and it involved pre-flushing lines before water was tested and there is research that says that that can mask the presence of lead. So what I am hoping for and I know because this is something that might not naturally fall under DEQ because it is the schools and it might be a different department that something can be created to make sure that whatever methods are used to test water in schools are informed by current research and not by people in a room who are thinking about what is possible or what is rational or whatever and that the people, teachers, and parents are brought in to the loop before that testing is taken on, and oh yeah, we’ll talk to you once we get the results, but really, this is all the trust thing; the people are part of this at the beginning, it is so much easier for them to trust.
Dr. Masten’s Overall Response: Dr. Sullivan seems to imply that the State of Michigan and the authorities have not taken the issue of lead in water in Flint schools seriously, are manipulating the school sampling protocol, or are otherwise undeserving of the public trust. Unfortunately, Dr. Sullivan’s inaccurate remarks only serve to feed the distrust that she would like to see addressed. Let’s go through Dr. Sullivan’s comments point by point:
Sullivan 1: “I don’t know exactly what caused this oversight, but the lead and copper rule and the Safe Drinking Water Act does not talk about testing water in schools….
Response 1: The Safe Water Drinking Act only applies to community and non-community water systems. Flint Community Schools are neither a community nor a non-community water system. To require testing in Flint schools would require new legislation, such as that introduced in the Michigan House in 2018 to mandate school testing for lead. As that bill was not taken up by the House, there are no laws in Michigan that require lead testing in schools. Although water lead testing is not required by law, the U.S. EPA has been encouraging schools (such as FCS) to conduct voluntary water lead testing since 1990.
Sullivan 2: we… looked around the room and said, ok, so who is testing the water in the schools?”
Response 2: MDEQ completed an initial screening of Flint public schools for lead in the water on October 2, 2015. I am not aware of any evidence that suggests that this initial screening was prompted by questions from Dr. Sullivan. It should be noted that additional testing was done in late 2015 and early 2016, and an aggressive program to replace outdated fixtures was initiated in 2017. Extensive testing was conducted again in early 2018.
Sullivan 3: “the protocol was developed by people in a room and it involved pre-flushing lines before water was tested and there is research that says that that can mask the presence of lead.”
Response 3: The protocol that was used in Flint schools was based on advice from U.S. EPA personnel. It is important to note that samples were always taken prior to flushing. The samples collected after flushing provide additional information, not to “mask the presence of lead.” For example, in the 2018 sampling event, 250 mL samples of unfiltered water were taken before flushing. Flushing was then done and after overnight stagnation additional samples were taken. This additional sampling was done to standardize the stagnation time. Additional sampling was planned; however, the FCS personnel determined that it was unnecessary,
Sullivan 4: “So what I am hoping for and I know because this is something that might not naturally fall under DEQ because it is the schools and it might be a different department that something can be created to make sure that whatever methods are used to test water in schools are informed by current research and not by people in a room who are thinking about what is possible or what is rational or whatever.”
Response 4: School testing is not under the jurisdiction of MDEQ.
Dr. Sullivan is wrong when she says the methods used in 2018 were not based on current research. If Dr. Sullivan has evidence to suggest this was not the case, I would like to see it.
Sullivan 5: “..and that the people, teachers, and parents are brought in to the loop before that testing is taken on, and oh yeah, we’ll talk to you once we get the results.”
Response 5: Teachers and parents have enough to do, without conducting original research on lead in school water sampling and developing testing protocols. Also, the protocols should be standardized so that results are comparable and meaningful. It would be impossible to do this if every school devised their own unique sampling protocol.
The inaccurate and unsubstantiated comments made by Dr. Sullivan at this round-table only serve to foster distrust by suggesting that MDEQ is incompetent and working overtime to cover up problems with Flint’s water. My own experience personally witnessing and working on this problem contradicts this assertion. Every effort was made to use the best science to devise a plan to sample lead in schools. What happened in 2014 and 2015 was ill-fated and is the subject of ongoing litigation and criminal cases, which will hopefully hold responsible parties accountable, but the best interests of the people of Flint are not served by constant unfounded criticism of legitimate efforts made to rectify problems.