Recommendations for Improving the Washington DC Water and Sewer Authority Lead in Drinking Water Public Education Program

April 30, 2004

I. Introduction
Public information regarding the quality and safety of customer drinking water is a critical component to building consumer confidence and trust. By providing customers with relevant information about the safety of their drinking water, EPA and water systems empower citizens to make informed choices and to take precautionary measures to protect against health threats. Unlike most regulated contaminants, concentrations of lead are not typically high when drinking water leaves the treatment plant. Lead levels can vary at the tap from consumer to consumer and can come from sources including lead service lines, plumbing fixtures or lead solder used with copper pipes within homes. Therefore, the Lead and Copper Rule (LCR) contains special public education requirements for informing the public when lead levels are high, and for providing them with advice to reduce their lead exposure.

The purpose of this report is to present the findings of a preliminary evaluation of the effectiveness of the Washington D.C. Water and Sewer Authority's (WASA) education and outreach efforts carried out in response to elevated levels of lead in the District's drinking water during 2002 and 2003. WASA already began planning and implementing several changes to its public outreach and education efforts while this review was being conducted. The specific recommendations included in this report will assist WASA in expanding and refining these activities.

It is important to note that, while compliance with requirements is briefly discussed below, this evaluation is separate from the formal review of WASA's compliance with the public education requirements of the LCR. As part of this review, several activities were performed by EPA staff as part of an ad hoc team assembled to evaluate the effectiveness of the WASA outreach materials and methods of distribution. A quantitative evaluation was not possible during the limited timeframe of this review, as WASA did not track or measure the effectiveness of its education and outreach efforts on the lead issue. The activities of the team included:

1) A review of WASA's 2002 and 2003 outreach and education materials to evaluate content and means of delivery.

2) Informal interviews conducted with 30 individuals (public officials, non-profit/community groups, citizens) from March 23-25, 2004 to gather information on whether information reached the public, whether it was understandable, and their opinions on the overall effort. (Attachment 2)

3) A review of information and educational materials from other water systems that have exceeded the Action Level for lead in order to identify some exceptional outreach efforts as examples for WASA.

Upon completion of activities listed above, the team identified several areas for improvement in WASA's education and outreach programs. Four major findings emerged during the evaluation of the content and delivery of outreach materials. They are:

1) WASA failed to communicate a sense of urgency in its outreach efforts (print/broadcast materials, verbal communication with public, or other means).

2) WASA failed to adequately convey information to the intended audience due to ineffective materials, overly technical language, lack of attention to targeting populations of concern, and other factors.

3) WASA did not provide for sufficient involvement of the affected public in development of a communications strategy.

4) WASA lacked sufficient tracking or measures to determine success of outreach efforts.

These basic problem areas must be addressed if WASA is to implement a successful and effective public education and outreach effort in the future. The evaluation team believes strongly that following the EPA Lead in Drinking Water Regulation: Public Education Guidance (see specific recommendations in Attachment 1) would help WASA considerably in improving its efforts.

II. Areas for Improvement - WASA
In addition to following mandatory requirements and making use of EPA guidance, there are several other steps that WASA can take to move toward more effective public education and outreach on the subject of lead in drinking water. Additional measures will help the organization successfully convey important information to the affected public. Suggested activities include:

- Hiring internal or consultant expertise in the areas of marketing research and risk communications - Assistance is clearly needed in the area of risk communication. Help should be sought in assessing the audience to be reached, making recommendations for design and content of materials to be used, as well as delivery methods. Those hired could also assist with the other steps below, including a communications audit, strategic communications plans and tracking/measurement. Additionally, use of an outside consultant may help at least partially address the trust factor mentioned by some of those interviewed. (see Attachment 2)

- Conducting an internal communications audit - This audit should be comprehensive and bring in outside expertise such as the risk communications expertise mentioned above. An internal communications audit addresses the primary actors for developing and conveying WASA's messages – its managers and employees. This will also address communication with other institutions, such as D.C. Department of Health (DOH).

- Developing strategic communications plans - These should include basic communications plans explicitly aligned with WASA’s technical and compliance plans, as well as emergency plans. One specific recommendation is that these plans should pay particular attention to use of media tools and outlets for specialized audiences.

- Including stakeholders in decision-making - Greater inclusion of stakeholders to evaluate needs and include them in decision-making will help get the right message out successfully to the affected public. In order to build greater trust and public support, WASA must provide meaningful opportunities for such involvement.

- Measuring effectiveness - WASA should track its outreach through every step of the process. Did the message get out? (How many times were Public Service Announcements (PSAs) played and on which stations)?; Did it reach the intended audiences? Were they received in the affected areas?; Did the message have an effect? (Did the intended recipients understand the message? Did they change their behavior?) Establishing evaluation criteria at the outset are crucial so that quantitative and qualitative data are generated throughout the process. Lessons learned from each phase can then be used to adjust future actions as needed.

These and other, more specific suggestions are included below in Attachment 1.

A. Compliance with Lead and Copper Rule Public Education Requirements

Although this evaluation is separate from the Compliance Review of WASA’s efforts under the LCR, it is necessary to mention compliance in relation to outreach. Information reviewed to date in EPA Region III’s Compliance Audit of WASA shows that during the 2002 and 2003 reporting periods, WASA failed to comply with several of the public education requirements of the LCR. These include: failure to use the required language for public service announcements submitted to television and radio stations for broadcasting; failure to use the required language in notices inserted in water utility bills; failure to conduct PSAs every six months (one was missed); and failure to send written documentation on these efforts to EPA within the required timeframe. One of the first steps WASA must take toward improving effectiveness of the public outreach program is to fulfill all compliance requirements.

B. Using EPA Lead in Drinking Water Regulation: Public Education Guidance:

EPA developed this guidance with stakeholder input to assist systems with compliance and to highlight successful strategies systems may choose to implement in order to conduct an effective public education campaign. Once mandatory requirements are met, it is recommended that WASA make use of the EPA document, Lead in Drinking Water Regulation: Public Education Guidance (Original 7/1992; Revision 6/2002). This is a very thorough guidance document that, if followed, would have been and will be very useful to WASA in improving its public education and outreach activities. The document does not impose legally binding requirements. Rather, it includes a summary of the mandatory requirements, advice on various aspects of an outreach campaign, examples of efforts from various systems, and information resources for reference. The guidance is organized around the following topics:

1) Developing an Action Plan
2) Organizing a Community-Based Task Force
3) Preparing a Water Testing Program
4) Preparing Public Education Materials
5) Implementing the Program

Specific recommendations from this guidance document that could particularly benefit WASA's efforts are included in Attachment 2. From the documents available for review, the team concluded that WASA did not develop a strong action plan, nor did it organize a community based task force. Due to the absence of these first basic steps, WASA's outreach efforts were not nearly as effective as they could have been. Without a plan in place, it is difficult to move forward and to track progress. Without a broad range of community involvement, it is not possible to ascertain the best ways to successfully communicate the message. Community buy-in and trust are lost when a program is implemented without the necessary degree of stakeholder/community input.

C. Special Considerations for the District of Columbia

In addition to the general recommendations regarding compliance with the rule and using the advice put forth in the EPA guidance, there are characteristics unique to the District that must be addressed in order to design and implement a successful education/outreach program. These characteristics will greatly influence the choice of public outreach materials and mechanisms. Given the level of diversity in the District, it will be difficult, if not impossible for WASA to communicate any message uniformly. The sources of information which groups of individuals trust and depend upon vary. Therefore, it is imperative that the messages and their delivery are tailored to meet the needs of all communities. The review team strongly encourages that WASA seek input from affected communities as well as assistance from outside experts in order to gather this information, analyze it and incorporate it into their decision-making.

D. Benefit from the Experience of Other Systems

WASA should be aware of similar efforts being undertaken by other water systems nationally in order to learn from each others’ experiences. The evaluation team reviewed materials and outreach methods used by several other water systems that have had an Action Level exceedance. Based on that review, the team recommends that, in particular, WASA should review materials and methods used by the Madison, Wisconsin Water Utility, the Portland, Oregon Water Bureau and the Barrington, Illinois systems. The team believed that these systems produced good, clear materials, with appropriately urgent language, and performed good follow-up/tracking of the effectiveness of their efforts, as well as other activities that could serve as good examples for WASA.

III. Areas for Improvement - EPA Region 3 Oversight

In order to fully ensure a more effective communications program in the future, EPA will also have to make some improvements in its own efforts. In addition to steps that EPA has already taken, such as issuing new Standard Operating Procedures to ensure timely and thorough review of all reports and materials in relation to the Lead and Copper Rule, the review team has suggested several actions below to be considered by EPA Region 3:

- When an Action Level is exceeded, ensure that the water provider is in possession of the EPA guidance document, and strongly encourage the use of that document.

- Set milestones for public outreach and education and assure that all milestones are met on schedule.

- Obtain written agreement from WASA to receive drafts of education materials, and a timeline for their submission. Review these drafts for compliance with requirements, as well as effectiveness of materials and delivery. This review should not delay notifications to the affected public.

- Determine criteria and measures for evaluation in order to determine if outreach efforts have been effective.

- Review drafts of public education materials for compliance with requirements, as well as effectiveness of materials and delivery. This review should not delay notifications to the affected public.

- Institute an internal process that ensures that materials are reviewed in a timely manner by a team consisting of staff with technical, compliance and outreach expertise. The process should also ensure that management is immediately alerted to issues of concern.

- When a lead Action Level is exceeded, acquire outside expertise to assist in evaluating outreach efforts.

IV. Suggestions for National Action

EPA has committed to conducting a comprehensive national LCR compliance review. Data obtained through this review will be used to evaluate rule effectiveness and to help identify opportunities for revisions to guidance and/or regulations. These efforts will strengthen the public health protection afforded by the LCR.

- Consider different recommended language in the guidance for varying levels of exceedances. For example, should there be additional activities recommended based on the level of exceedance and how widespread the problem is, or other considerations.

- Consider requirements for promptly notifying individuals when test results show elevated lead levels in the tap water for a particular home.

- Consider re-examining current guidelines regarding flushing times for usefulness and applicability.

- Review existing EPA publications regarding lead in drinking water for potential improvements, particularly regarding practical tips for communicating message to the public.

V. Summary

Based on the evaluation of WASA's public outreach and education efforts regarding lead in drinking water in 2002 and 2003, there is room for continued improvement. Attention to communicating urgency, involving stakeholders and measuring effectiveness will go a long way towards institutionalizing effective public education and outreach activities into the framework of WASA's business practices. Attached are very specific recommendations WASA can take toward success with its outreach and education efforts.

Attachment 1: Recommendations for WASA

I. General

Mandatory Requirements - Produce all required materials, with all mandatory language, on time. However, do not limit materials to mandatory language. WASA should make a determination as to whether mandatory language sufficiently and effectively communicates the issue and its importance and develop additional language in conjunction with EPA and DOH where necessary.

Stakeholders (affected community members) develop a consultation plan which identifies the stakeholders to be consulted; why you want to consult with them (e.g. message development) and when you plan to consult them.

EPA Review - Submit all materials in draft format in a timely manner to EPA for review.
WASA has verbally agreed to begin submitting drafts of written and broadcast educational materials for EPA staff review.

Tracking - Track effectiveness of outreach efforts. Tracked information should be included in required reports. At a minimum, consider simple questions such as:

- Did articles appear in the local papers? What was the population reached (number of persons based on circulation, special populations reached by specialty publications, etc.)?
- Did the PSAs actually run on the radio and on TV? Did they run at various times/days to reach different audiences?
- Was EPA approval sought to use alternative language that would have provided a more powerful message with greater impact on the public?
- Was there an increase in citizen inquiries to indicate the public understood the information?

Customer Survey - WASA (perhaps with DOH) should survey customers about its past and current outreach efforts to improve future efforts. The survey does not need to be a census of all customers, but it should be created, executed and reported to minimize sample bias and maximize the action orientation of the findings. The survey results would be a baseline for any future surveys done after improved outreach. The use of focus groups may be helpful, as may the use of an independent consultant to conduct these feedback activities

Risk Communication - Hire a full-time staff member or consultant specializing in risk communication and/or public education and outreach to assist in these efforts

II. EPA Guidance
The recommendations below are organized in the categories presented in the EPA Guidance Document. Each section includes pertinent information taken directly from the Guidance document, and also recommendations made by the review team members. Page numbers reflect page in 2002 EPA Guidance.

A) Developing an Action Plan
Development of a comprehensive action plan should be a top priority for WASA. As mentioned above, WASA began making improvements, including an enhanced plan for public outreach. This is a start, but the plan needs to be much more comprehensive with input from various stakeholders, including members of the affected communities. Additionally, it is essential to include measures of effectiveness/success in the action plan, individuals/organizations accountable for each deliverable, and a timeline for activity completion.

Defining your program audience (page 18)

- All WASA product users should be reached, including businesses, residents in apartments, vulnerable populations, and non-English-speaking residents.
- Formulate a strategy for how the unique groups, e.g. pregnant mothers, will be reached.

Providing water testing services (page 18)

- WASA needs to ensure that testing is organized (answering citizen requests, timely sampling), sampling protocol is followed, and that test results and follow-up information are provided as quickly as possible.

Identifying the types of education materials that will be used (page 19)

- WASA is not limited to brochures, radio/TV PSAs, and bill inserts and should consider other materials and delivery methods.
- With an issue of this magnitude, protection of public health requires more sensitivity to this issue and creativity in outreach efforts. Some possibilities:
- More frequent outreach than required by the Federal regulations.
- Stronger language to convey the urgency of the public health problem.
- Posters on the Metro or other public transit.
- Scrolling banners on local television news broadcasts.
- Email listserve through the WASA website alerting subscribing customers of updates.
- Colorful quick reference postcard or magnet with pertinent information (contact information, flushing instructions, etc.) sent to customers.
- Additional types of materials should be developed in conjunction with EPA, community organizations, and public affairs experts.
- Target materials for special populations (different versions of materials for different groups).
- Hold workshops/presentations at schools, churches, community centers and other locations on water testing, using filtering devices, information on blood lead testing, and other issues.
- Take advantage of annual distribution of the Consumer Confidence Report to inform all residents of sampling results, actions to remedy the situation and progress.

Determining how and when to distribute information (page 19)

- Brochures should be delivered to schools directly, instead of to a central location for future distribution.
- All communication methods at a system’s disposal should be used to inform the greatest possible segment of the population.
- There should be a schedule for dissemination of information (water testing program, educational material development, distribution of educational materials).
- Community members can assist in preparing, printing and distributing information.

In addition to a basic outreach and education action plan, WASA should develop an emergency communications plan to be put into use in critical situations. The plan should identify the specific individuals with specific duties to be carried out immediately during such a situation.

B) Working With a Task Force
It is imperative that WASA identify and organize a task force. As the guidance states, the task force should be "comprised of community members representing the public, private and civic sectors." Early, frequent consultation with such a task force will help build trust and offer WASA the advantage of a wider pool of practical ideas about improved service.

Who to include on your task force (page 21)

- Some possibilities that should be considered for membership to the task force in addition to WASA staff/managers are representatives from: DC Department of Health, Metropolitan Washington Council of Governments, City Council, Mayor's Office, EPA Region III, Board of Education, school representatives, Lead Emergency Action for the District (LEAD), Moms on the Hill (MOTH), neighborhood associations, environmental groups, environmental justice groups, media representatives, medical facilities, and clinics.

- Representatives should include those with technical expertise as well as those skilled in risk communication, and public education/outreach.

- EPA's public involvement brochure, "How to Identify People to Involve," offers specific suggestions about which stakeholders may be most appropriate for this task force.

Using the task force to help you conduct successful public education program (page 22)

- WASA should use its task force to help develop, review and revise the action plan. Task force members can assist with laying out the plan, communicating it to their networks, as well as potentially carrying out action items in the plan.

C) Preparing Public Education Materials
As stated above, the first step in preparing the public education materials should be to follow the requirements of the Lead and Copper Rule. Additionally, WASA should:

- Use task force members and the communities with which they are associated to aid in distribution and delivery of materials.

- All materials must acknowledge the problem and convey the sense of urgency missing from WASA's previous outreach and education efforts. The importance of these issues must be communicated clearly to the media and the community in a timely manner.

- Materials should include clear potential health risk information, as well as clear steps to be taken by the effected public and information on what is currently being done to address the issue.

- Language should be easily understandable by the intended audience, and should be concise.

Printed materials (pages 26-27)
Pamphlets, brochures, mailers, and posters
Content

- Although standard language exists, WASA can and should negotiate additional language with the primacy agency (EPA Region III) as long as the minimum information is included
- Standard language may be reorganized to highlight the most important information; in this case that may be revised flushing instructions and information on lead service line replacement activities (front panel) and contact information (back panel).
- Specialized materials should be developed to target vulnerable and hard to reach populations.

Format

- The guidance highlights that the physical presentation of this information is extremely important.
- Use large fonts and pictures to explain/tell the story.

Delivery methods

- Ensure that bill inserts are delivered to all non-bill paying customers (i.e., those in apartments).
- Direct delivery to facilities that serve vulnerable populations is essential.
- Use task force members and their organizations to ensure that the materials are reaching their intended audiences.
- Check that the materials are getting to their intended audience.
- Post ads in community/neighborhood newsletters, church bulletins, and other publications read by groups of its customers.
- Post flyers on bulletin boards in libraries, post offices, schools, churches, restaurants, youth and community centers, and other appropriate facilities.

Tools and methods for promoting mass media coverage (pages 27-29)

- There should be media representation on the community-based task force so that the media serve as partners in this effort, are involved in an open process, and can be given accurate information in a proactive manner. Additionally, the media can assist in obtaining the desired outreach.
- Provide reporters with complete, accurate information and develop a media strategy with city/local public affairs/public relations representatives, as the media strategy may be the most important piece of the public education program.
- Press conferences and other outreach to the media should be used from the outset.

Delivery method
Local newspapers

- WASA should meet with editorial staff at local papers prior to beginning public education activities.

Radio and television stations

- According to the guidance, "radio and television coverage of the lead in drinking water issue [may be] the best way to get the message delivered to a mass audience at no cost" for large community water systems.
- WASA's public education report does not describe how TV and radio were utilized (broadcast frequency, duration of broadcast, etc.), thus, it is difficult to determine if they utilized the guidance. Part of the action plan should include details about intended use of broadcast media, as well as plans for evaluation and measurement of outreach effectiveness.

Public service announcements
Format

- WASA is not limited to the minimum language specified in the regulations
- WASA should amend this language to include more specific details on testing, health effects, and contact information.
- Video segments can be produced and distributed to local TV stations for even more effective outreach
- The PSA should be broadcast on non-English radio and/or television stations, as appropriate, to reach non-English-speaking residents.

Delivery method

- Repeat PSAs every six months on (at least) five radio and five television stations with the largest audiences in the community, but WASA is not limited to that requirement.
-Request a schedule of when the PSA was aired to ensure that a large segment of the population was reached by the announcement.
- Work with media representatives to determine the best way to ensure that the information is aired.

D) Implementing the Program
By performing the steps outlined above with the time and attention they require, WASA will protect public health by distributing clear, accurate information to all of its customers in a timely manner. A well-developed action plan and an involved task force will help ensure successful implementation of the public education program under the Lead and Copper Rule.

Pacing program activities (pages 32-33)

- Tasks outlined in the action plan should be paced over several months to increase the likelihood that customers will see or hear at least one of the outreach materials (not all activities should occur at the very end of the 12 month public education period); for example, deliver a mailer and follow up with PSAs/newspaper ads.
- WASA should work with schools, DC DOH, and other agencies before beginning public education activities so that all related agencies have information on hand to respond to inquiries.

Providing water tests or information on water testing (page 33)

- Have adequate laboratory support staff available.
- Produce a pictorial description of how customers should take water samples.
- Provide test results rapidly and include additional information or contacts in the results letters.

Responding to public inquiries (page 34)

- Tracking questions posed to hotline staff (DOH call-in number, WASA Lead Services Hotline, etc.) can be used to help determine where the public education program needs to be strengthened.
- Ensure capacity of hotlines. Have a plan to increase capacity in critical situations.
- Have a minimum response time, and keep track of whether it is met.

Attachment 2: Summary of Interviews Conducted Regarding WASA's Public Education on Lead in Drinking Water

I. Purpose
To supplement EPA's evaluation of WASA's public education materials and outreach in response to elevated levels of lead in large numbers of DC homes, EPA had discussions with 30 Washingtonians during March 23-25, 2004 to learn about their recent experience in learning about the subject. (Therefore, these opinions were expressed prior to some of WASA's enhanced efforts such as frequent public meetings and press releases.) EPA also asked for ideas to improve outreach about this important public health concern. The results of these interviews will be considered for direct use in the District, provided to WASA for its use, and will be provided to the EPA Office of Water to help it evaluate the effectiveness of the public education requirements of the Lead and Copper Rule.

Because of the relatively small number of people who participated in the interviews, and the non-random approach to meeting them, EPA is not attempting to draw conclusions about the views and recommendations of the tens of thousands of people who are potentially affected by the lead situation. The pattern of the responses, however, identified a number of clear findings about how the interviewees learned about the lead situation, what they have done in response, and how they would like to see outreach improved.

If a thorough, random, representative sample of residents is to be surveyed, it should be done by WASA or the District, via an independent research organization.

II. Who was interviewed
Three categories of people were interviewed: interested residents who attended a public meeting about lead in District drinking water; representatives of involved citizen and environmental organizations; and elected DC Council members or their staff. As these people are already actively involved and knowledgeable, they are not by themselves representative of the broader, much larger group of people potentially affected by the elevated lead levels. Most interviews were in person, and a few, by prior arrangement, were done by phone.

- A quarter lived in households with pregnant women or children under six.
- About a third knew they had lead service lines (more than a third did not yet know).
- Almost all did not yet know if their tap water had elevated lead levels.
- A quarter of the people do not have Internet access at home or at work.
- Half get most of their local news from the major news media, while almost a third get much of their community information from e-mail subscriptions (listserves).

III. Findings
A) Shared Facts and Opinions
There were a number of facts and opinions that were shared by most interviewees:

- Initial awareness occurred when it was publicized by the news media in late January and early February.
- About half had an immediate sense of the urgency of the situation; this was conveyed in the news rather than by WASA outreach directly.
- Most interviewees were aware of WASA’s flushing instructions for affected residents, and for pregnant women and young children. About half became quickly aware of the elevated lead levels in some homes, while a third quickly learned about the potential health effects, ways to reduce family exposure, how to have water tested, how to have blood tested, and how to get additional information. Most felt that their awareness came largely from the news media.
- Most contacted WASA to learn whether they had lead service lines, and about half of these people felt that WASA’s response was helpful.
- Of the 25 who expressed their level of satisfaction with WASA's early public education campaign, a high majority were somewhat to very dissatisfied. About a third said that they no longer trusted WASA as a source of information and solver of the elevated lead problem.

B) Actions by Customers
Other than contacting WASA to learn about their service line, most had not yet:

- had water or blood tested.
- started to routinely flush their tap water before drinking and cooking.
- installed a water filter.
- begun to use bottled water for drinking and cooking.

C) Recommendations to WASA
Recommendations for improving community outreach were readily expressed:

- About half want more information from newspapers, TV, radio, and WASA or DC DOH mailings–a few asked for more in Spanish.
- The most recommended other means of delivering information are:
- Posters on Metro buses, trains and stations.
- Internet.
- Alerts on billing envelopes (though many do not receive WASA bills).
- Other suggestions include:
- Separate letters--not with bills--on colored paper.
- Door-to-door visits.
- Using churches, schools, libraries, community organizations, rec centers, mobile vans, health care professionals, government offices, and grocery stores for disseminating information and as information repositories.

Recommendations for Improving the Washington DC Water and Sewer Authority Lead in Drinking Water Public Education Program

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