UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     GUIDANCE FROM HOTLINE COMPENDIUM
                                                                             WSGH42
                                                                  Date Issued: July 1992
SUBJECT:   Adverse Health Effects of Lead and Copper from Avenues Other
             Than Ingestion

SOURCE:    Jeff Cohen
EPA promulgated standards for lead and copper in drinking water on June 7, 1991 (56 FR
26460).  The studies that were performed to set the standards examined lead contamination from
ingestion only.  However, consumers come in contact with lead contaminated water through
many other avenues besides drinking.  For example, bathing in water that is contaminated with
lead potentially could allow lead to be absorbed through the  skin or droplets of water could be
inhaled while showering.

In the document Risk Assessment Management and Communication of Drinking Water
Contamination (EPA/625/4-89/0254),  EPA does not mention absorption or inhalation as an
avenue for contamination from inorganic contaminants.  On page 48 the report states that,  "The
skin is  a relatively impermeable to toxicants:  this barrier is over 100 cells thick.  However,
some toxicants, such as carbon tetrachloride, can be absorbed through the skin in sufficient
quantities to cause liver injury.  Absorption through the skin is possible through the hair
follicles, through the cells of the sweat glands and sebaceous glands, and through cuts or
abrasions..."  Therefore,  in a few rare instances, EPA has considered avenues of contamination
other than ingestion, but these contaminants are organics like carbon tetrachloride rather than
inorganics like lead.

Does EPA consider contact with lead contaminated water through inhalation or absorption
through the skin to be a health concern?
       Response:

       EPA does not consider exposure to lead contaminated water from absorption through the
       skin or inhalation to be a health threat.  Water contains inorganic forms of lead, which
       are not capable of being absorbed through the skin.  Lead in water is unlikely to pose a
       risk via inhalation, unless contaminated water is used.  Studies have shown no
       significant evidence that these means of exposure to lead contaminated water will result
       in increased levels of lead in blood, and therefore, no adverse health effects are
       anticipated.

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