When issuing its interpretive memorandum allowing electronic delivery of Consumer Confidence Reports (CCRs) earlier this year, EPA was hesitant in its commitment to any additional CCR changes, largely due to resource constraints. While those constraints remain at the forefront of any activities it pursues, EPA has begun an evaluation of the language used in CCRs and potential changes that would make CCRs into a more effective communication tool.
EPA began its assessment of CCR language by holding a series of short conference calls with several stakeholders to get preliminary feedback on potential issues for further consideration. Separate calls were held with drinking water utility (including AMWA and several member utilities), state and non-governmental organization stakeholders. The main points raised in the utility conversation revolved around the need to make CCRs less technical and more readable for the general public while doing a better job of presenting the risk of drinking water “contaminants” in relative terms. Utility representatives expressed particular concern that the use of the word “contaminant” to characterize low, legal levels of naturally substances present in drinking water may actually undermine public confidence in drinking water quality.
The next steps EPA will take in its evaluation of CCR language are unclear at this point. A certain amount of language in CCRs is mandated by regulation and would require a rule revision to change, which is a time-consuming and resource-intensive process. More immediate and affordable follow-up activities could involve additional stakeholder discussions, webinars or training on CCR communication issues. Further outreach and clarification of next steps are expected this fall.