Response 46124150

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Personal Information

What is your name?

Name (Required)
Michael Lawrence

What is your organisation?

Organisation (Required)
Bligh Tanner

Understanding the problem, options and unintended consequences

Do you agree with the description of the nature of the problem on page 12?

Please select one item
Yes
No

Are there any characteristics of the problem not described which should be described?

Please select one item
Yes
No
If yes, please specify:
There are differences in the way jurisdictions regulate drinking water. In Queensland the service provider is regulated to the customer meter, and as a result there is very little to no evidence available from water service provides that indicated whether there is lead leaching in customers own plumbing. Therefore a lack of data potentially disguises the true extent of lead in drinking water at the point of consumption (as opposed to the bulk supply). I also note that the report indicates that orthophosphate is added to reduce solubility of lead. There are very few (if any) water service providers in Australia that actually address this issue with orthophoshate. I am not aware of any having inspected/reviewed/audited several hundred water treatment plants on the East Coast in the past 10 years.

Is the scope of products listed on page 13 appropriate?

Please select one item
Yes
No

Do you agree with the description of the extent of the problem on page 33?

Please select one item
Yes
No
If no, please specify:
As above - however data would be available through the relevant state water regulators who should be able to provide details of the frequency of testing, and the extent of positive results for different providers.

Are there any other feasible options to address the problem?

Please select one item
Yes
No

Are you aware of any health consequences associated with using substitutes for lead in the manufacture of plumbing products in contact with drinking water?

Please select one item
Yes
No

Are there any incentives, other than regulation, that could be introduced that would be effective in increasing market demand for low lead plumbing products and materials?

Please select one item
Yes
No

Which is your preferred option?

Please select one item
(Required)
Option 1 - Retain the status quo.
Option 2 - Require 0.25% or less lead content.
Option 3 - A non-regulatory industry led labelling scheme.
Other

Why is this your preferred option?

The problem is the lead in contact with drinking water. Given the vast range of water chemistry that still is considered safe drinking water, not all safe water is going to prevent leaching in household plumbing where there are long residence times and differential quality depending on how close you live to the WTP. The providers should not have to add orthophoshpate to drinking water supplies when a known problem can be resolved by following the US lead.

Do you agree that a transition period is required for Option 2?

Please select one item
No, I do not believe a transitional period is required.
Yes, I believe a 3-year transitional period is suitable.
Yes, I believe a 5-year transitional period is suitable.

Which sector of the industry best describes you?

Please select one item
(Required)
Manufacturing
Plumbing Practitioner
Industry Association
Government
Other
If other, please describe the sector below:
Consultant -water industry. Lead water quality management system auditor.

Questions for others

Do you have data on lead levels exceeding 10 μg/L in drinking water?

Please select one item
Yes
No
If yes, please specify:
Drinking water service provider annual reports in Queensland should be publicly available for all providers and each should report if they have detected lead above the ADWG in those reports. The reports should also have an indication of the frequency of testing.

Are you aware of any studies on the occurrence of lead leaching into Australian drinking water from within the premises?

Please select one item
Yes
No

Do you have data on the frequency of elevated blood lead levels in Australia?

Please select one item
Yes
No