Sunday, May 4, 2014

The Revised Total Coliform Rule

Are we looking at more work for local public health without funding to do it? Consider the revised total coliform rule (rTCR): whenever this happens it is bad for the health of the public.

When you find coliform bacteria in a water sample it is an indication that the water could be contaminated. These bugs themselves do not cause illness, but they are universally present in our bowels, so where they go bad guys like E. coli or salmonella may not be far behind. Last year the Environmental Protection Agency (EPA) published a new rule which tightens up the kind and number of inspections that health departments have to do when they discover coliforms. The details are complicated, and if you want to read about them, they are here.   And here is the beautiful detail of the rule from the Federal Register, including projected health benefits and costs.

The new rule is based on good science, so if it is implemented it is likely to reduce illness and even save lives.  But as EPA noted when it published the rule, the increased inspections are going to be costly.  According to EPA’s calculations, the savings from reduced illness and death will outweigh the increased cost, so that seems like a good deal for the country.

The problem is that there is no way for EPA to capture that savings and send it to States who can send it to local health departments (LHDs) to pay for the increased inspections. If somebody does not die of a gastro-intestinal illness, lots of people save money (although they don’t know it)—the insurance company, the family, the employer—but they are not passing that savings on to the health department who employs the sanitarian who finds the contaminated well and gets it cleaned up. They don’t know something bad didn’t happen.

Michigan convened a Revised Total Coliform Workgroup to discuss how to implement the new rule. We know that EPA is going to twist our arms until we do so, so we need to start planning for it. The workgroup’s Final Report (I can't find it on-line) says “All Workgroup members agreed that the rTCR will require more time and resources to administer than the current Total Coliform Rule (TCR) does, especially at noncommunity water supplies (NCWS). The need for additional resources could be a critical issue for many of Michigan’s LHDs.”  (Noncommunity water supplies are places with wells that serve water to the public like a rural school or church.)

Indeed resources will be an issue. The Final Report estimates that there will be over 3 hours of additional work per noncommunity water supply. Considering all the rural facilities that serve water to the public, a health department like MMDHD might need a whole FTE to complete this work. But the State of Michigan has not been given additional dollars to add to our contract.

There are two main ways LHDs supplement State dollars going into their water programs.  One is general fund dollars from county governments.  But in most places in Michigan those dollars are frozen or declining.  Another is fees.  In most of the State county boards of commissioners will not support a jump in the fees charged to places like schools and churches for their well permits.  As far as they are concerned these wells are safe now and they don't want to charge more for what looks to them like the same result.

Fearing the worst, a few LHDs in Michigan have asked if they can drop their noncommunity watersupply programs without losing their accreditation.  I suspect the answer is "No". On top of that, there are good reasons the public should insist on monitoring.  A lot of these systems are aging. They are developing cracks and filling up with gunk where the bugs can grow once they get in.  To leave the public without protection would be nuts. But for all levels of government to simultaneously fail to address the question of how to pay for that protection is nuts, too.

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