Tuesday, February 25, 2014

Consumer Confidence Reports - It's That Time Again!

July 1st of every year marks the day by which community water systems across these United States are required to have provided to their customers the previous year’s Consumer Confidence Report (CCR), more commonly known as the water quality report. Federal regulations promulgated by the Environmental Protection Agency (EPA) have a great deal to say about what is and isn’t to be included in the CCR, as well as how it is to be organized and what verbiage to use, and we all know that the Federal Government is not always the best when it comes to communicating in a simple, easy to understand fashion. Just look to the tax code for a good example of that. For that reason, I thought I might try to explain a few of the more confusing things related to CCRs, judging by the questions I get asked.
 Although every water company tests for a great many elements, chemicals, compounds, molecules, particles, and life forms in your drinking water, the CCR is only supposed to contain those items that were detected in the water served to the public at concentrations above a defined level. There is a lot packed into that sentence that we should look at a little more closely, one piece at a time.
 “Items that were detected” – in other words, if a water company tested for a hundred different things and didn’t find any of them, their CCR would be blank. So how do consumers know what the water company tests for and how often they test? They don’t, at least not based upon the information in the CCR. To find out, they can try calling their water company and hope they can contact someone who knows the answer, but it’s a much more difficult and complex answer than you might imagine, given the ever growing extent of drinking water regulations. Adding to the complexity is that not every item needs to be tested for every year. Some testing only needs to be done every other year, or every three, six, or nine years. And the frequency can vary depending upon the source of the water or other factors. The answer is complex, will be different for every water company, and could be different year to year for the same water company.
 “Served to the public” – so if someone is looking to the CCR to give some idea of what is in the local lake, river, or groundwater aquifer the water is drawn from, they’re probably out of luck. The CCR tells what’s in the water consumers drink, so if the source water is contaminated with high levels of perchlorate, for example, but the water company treats that water to completely remove the perchlorate before distributing it (which they had better!), then the CCR would not list perchlorate as a contaminant.
 “Concentrations above a defined level” – huh? No analytical test can measure down to zero. They all have what’s referred to as a reporting limit. Above the reporting limit, you can confidently say that the item you are testing for is present at a measured level; it can be quantified. Below the reporting limit, you can’t really measure the level accurately, or even say whether it’s actually present or not with any real confidence. The Federal or State government sets the reporting limit for most items they require to be measured based on their estimation of what can confidently be reported by a majority of laboratories. If the reporting limit is set at 5 ug/L for example, it is not required of any water company to report in their CCR any test results less than that, even if the laboratory that does their analytical work has the capability of reporting lower levels with confidence. So if your water company tested samples at 4 ug/L of this compound, whatever it may be, it would not be required to be reported in the CCR.
 CCR’s contain a wealth of information, but unfortunately the rules governing how they are produced can make deciphering them a bit of a challenge, and producing them even more of one. I’ve tried to shine some light on a few of those challenges in this post, although certainly not all – I’d need a few more pages for that. Feel free to contact me if you have any particular questions, or if you need help getting your CCRs done this year. You can reach me via  I’d love to help!