opportunity to look at the environment as an integrated system upon which a coordinated effort can be made to improve its present status and prevent additional degradation.

This agency will eliminate much of the present bureaucratic entanglement and will thus be better able to assist the local and state agencies to fulfill their own responsibilities. It will also be better able to make Congress aware of present inadequacies existing in our federal environmental programs. Until now, it is apparent that many departments of government have been concerned with a single pollutant or a single environmental medium. This fragmentation of effort has resulted in confusion, overlap and inefficient management making it impossible to view the total effect of any pollutant on the environmental system. The consolidation of the present agencies vitally concerned with the environment, will eliminate many of the aforementioned problems and will at the same time assure that we do not create new problems in the process of controlling existing ones. THE ROLE OF WATER HYGIENE IN THE NEW ENVIRONMENTAL PROTECTION AGENCY

This new type of approach is particularly relevant to one of the HEW Bureau's scheduled for transfer to EPA-The Bureau of Water Hygiene, which should have the identity, legislative base, and financial resources necessary to provide Federal leadership in assuring the safety and adequacy of drinking water. This activity is vital to each of us, in order to assure good health for the people of this Nation.

The drinking water problems of this Nation, as well as the functions and responsibilities of the Bureau of Water Hygiene, constitute one of the few unrecognized environmental problem areas, and thus the BWH presently constitutes a major program void which has developed from a previously disorganized approach to the environment.

DOES A WATER HYGIENE PROBLEM EXIST TODAY

Overconfidence or apathy seems to pervade the public's attitude with respect to drinking water. Common daily experience plus a current myth about the future, falsely implies that the quality, safety and adequacy of our municipal water supply systems are above reproach. Perhaps the myth can be stated as follows: Everyone knows we have launched a massive water pollution control effort and that waterborne disease outbreaks are a thing of the past.

This statement is simply not true and the dangers of this misinformation are illustrated by the epidemic at Riverside, California in 1965 which affected 18,000 people, the 30% gastroenteritis attack rate in Angola, New York in 1968 due to a failure in the disinfection system, and the 60% infectious hepatitis attack rate which afflicted the Holy Cross football team in 1969 as a result of the ineffective cross connection control procedures.

The recent discovery of critical amounts of mercury in our water supplies as a result of industrial waste disposal is even more conclusive evidence of the existence of very current water hygiene problems.

The Federal Water Quality Administration has assumed the primary epidemiological role of digging up facts on the extent of the contamination. But FWQA has little capability for assessing human health effects of mercury, and even its data collection system based on quickie telegraphed reports, may not be adequate. Likewise, the Food and Drug Administration has limited jurisdiction, coming into the picture only when the mercury is taken up in the food chain, which it apparently has.

The National Communicable Disease Center (now known as Center for Disease Control) probably is best equipped to provide an over-all assessment of the health effects, but it came into the present picture late.

From the standpoint of environmental health, the point of all of this is that here we have a potentially lethal contaminant which has been allowed to build up to possibly dangerous levels in water, perhaps affecting many elements in the ecological balance, without coming to attention of Federal authorities (it is, after all, a national problem) and then dealt with in a piecemeal fashion by several agencies which rarely communicate their findings to each other.

It was this sort of fragmentation which presumably led to formation of the proposed Environmental Protection Administration. But will EPA be organized in such a way that a mercury contamination problem such as this, can be dealt with swiftly and effectively? And who will be providing the health data to EPA?

The answer to both these questions I believe, must be found in the establishment of a greatly strengthened Bureau of Water Hygiene working within the Environmental Protection Agency.

PAST SUCCESS IS THE KEY TO CURRENT FAILURE

In a somewhat different sphere, scientific work on chlorine and the discovery that it can disinfect drinking water is a major cause of the pollution of our waterways. I do not refer to the role that chlorine itself may play as a "pollutant," although, astonishing to say, this has been the subject of very little research. Rather, the confidence that chlorination would make any water supply "safe" no matter how badly polluted to start, is the keystone of our sewage disposal system, namely, "dump in the nearest river".

Speaking before the Diamond Jubilee Meeting of AWWA in 1956, Abel Wolman characterized the accomplishments of our forefathers over the preceeding century, from the standpoint of the sanitary quality of the Nation's public water supply system, as "one of the most dramatic improvements in public health that the world has ever known." As a result of past progress such words as typhoid, dysentery and cholera have become anachronisms. For instance, diseases which plagued the cities of the East Coast in the mid-1880's have all but disappeared, such as typhoid fever, which has declined from 75-100 deaths annually per 100,000 persons to less than 0.1 on a National basis.

By the 1930's, the state-of-the-art in municipal drinking water treatment advanced to a point where water borne disease was all but eliminated. As part of our way of life, people expect to travel anywhere in the United States and drink water from public supplies without fear of getting sick. In other times and in other countries, the accomplishment of that feat would be considered an idealistic dream. Yet, the water works industry of the United States under unifying controls of federal and state health regulations made the dream come true during the first half of this century. All three elements, a knowledgeable and dedicated industry, a strong federal control effort, and intelligent determined regulation at the state level, were required to accomplish the feat.

There is ample evidence that after achieving safe water for the entire nation, federal and state efforts began to lag. Control in many areas has relaxed. Criteria standards, and design practices are still pointed toward prevention of communicable disease as they were in the 1920's. Not as they are now in 1970.

During the 1950's and 1960's, Federal, state and local program emphasis shifted from stressing the treatment and protection of our drinking water systems to curbing the discharge or organic pollutant at the source. The resultant decrease in interest or concern has lead to a backsliding of state and local community water supply programs which were evaluated against the U.S. Public Health Service Drinking Water Standards. In the face of lagging efforts at the federal level and in some states, imperfections in the nation's water supply are beginning to show up. A soon to be released study report by the BWH notes that all too many Americans are drinking potentially dangerous water containing bacterial indicators of water borne disease. Therefore, the near term activities that will preoccupy the Federal water Hygiene Program must be an enumeration of deficiencies found in municipal and state water supplies.

OUR WATER HYGIENE PROGRAM MUST BE UPDATED

C. C. Johnson, Administrator of Consumer Protection and Environmental Health Service, speaking in Sept. 1969, before the Chesapeake Section of AWWA on "Preliminary Findings of the Special Community Water Supply Survey", said, "The question we face is this: Are we going to wait until the public health statistics reveal a drinking water crisis or are we going to begin now to upgrade our water treatment and distribution systems to cope with the problems of our own time and place? In the case of water hygiene, as in all of the many environmental problems that face our Nation and the world today, if we must wait for epidemiological studies of human illness to convince us of the hazards, it may well be too late".

The philosophy of letting the nation's control over public water supplies deteriorate until adverse health effects are noted is condemned. In fact, it is generally conceded that the involuntary use of our citizens for bioassay is immoral. Yet, isn't that precisely what is being done, when as a necessary condition for a budget increase, public health safeguards are allowed to fall lower and lower to the point where adverse health effects can be observed?

I think for a long while in this country we sort of mesmerized ourselves into thinking that the only water problems we had were water pollution control problems. As a result of that, very little attention was given to what we call the water hygiene aspects of the water problem

The backsliding in local, county, state and Federal water hygiene programs can be traced to a lack of Federal leadership associated with the popular misconception, that water pollution control efforts are a panacea which will not only restore and enhance the quality of our lakes, streams, and coasts to the benefit of fish and aquatic life and recreational pursuits but also guarantee delivery of healthful quantities of safe drinking water to the consumer's tap. This is not true insofar as drinking water is concerned.

Water pollution control efforts can assist the delivery of safe water to the consumer's tap but the community drinking water supply must be treated in any event. Pure water can be collected, treated and delivered to individual homes only under the close scrutiny of competent local, state and Federal programs.

These programs must begin to receive the needed resources to conduct necessary planning and research both to catch-up on past voids and looking to the future, to provide training and technical assistance to assure full application of existing technology and to conduct active, constructive surveillance and enforcement programs.

FEDERAL RESPONSIBILITIES

The Federal water pollution control effort of the Department of the Interior now exceeds $800 million per year and is scheduled to rise to well over $1 billion next year, while the Federal water hygiene efforts of the Bureau of Water Hygiene situated in the Department of Health, Education and Welfare is currently being subject to a budget cut from $2.7 million to $2.4 million. I am in complete agreement with the major attack being waged through the Federal Water Quality Administration against water pollution. It must not be minimized in any way if it is to succeed. In contrast, however, I am appalled by minimal support being given to the Bureau of Water Hygiene.

It is crucial that we have support at the Federal level to overlap state boundaries and variations in state capabilities in the field of water supply. There is no reason why there should be any better water supplies in one state than another, and the development of adequate criteria based on meaningful research is essential to our setting reasonable and understandable standards and then keeping these standards abreast of our changing environment.

The federal government has a responsibility and a role which it cannot avoid, and the water supply industry in the United States certainly encourages and depends upon the federal departments for fulfilling their responsibility.

CURRENT COMMUNITY WATER SUPPLY STUDIES

The Community Water Supply Study was launched to determine the quality and dependability of water being delivered to a cross section of the population including many small towns up through the largest cities. A total of 969 public water supply systems located in 9 areas of the country have been investigated. The study includes 5% of the systems and 12% of the urban population on a National basis when compared with statistics from the last comprehensive facilities inventory conducted in 1962. In addition to large metropolitan systems like New York City, Cincinnati, and New Orleans, the study includes 760 systems serving populations of less than 5,000 persons.

Using the 1962 PHS Drinking Water Standards as a guide, each water supply system was investigated on these bases. First, drinking water quality was determined by sampling the finished and distributed water and returning these to the laboratories of the Bureau of Water Hygene for bacteriological, chemical and trace metal analyses. Second, the status of the water supply system facilities was determined by a field survey of the system and the gathering of information on a) source of supply; b) treatment, if any; c) distribution system pressures, and d) operations. Finally, the status of the surveillance program over the water supply system was evaluated by obtaining bacteriological water quality data for the previous 12 months of record from state and county health department files.

While we all hold the Drinking Water Standards in high esteem, an unexpectedly high number of communities exceed either the recommended or mandatory constituent levels and a surprisingly larger number of communities show deficiencies in operations and surveillance. For instance-in excess of 80% of 969 systems investigated, primarily communities of less than 100,000 people, failed to meet one or more of the provisions of the U.S. PHS Drinking Water Standards because of water quality deficiencies or system risks; one out of every four samples (based on 3,563 samples) exceeded one or more of the recommended limits in the Drinking Water Standards; 9% of the samples evidenced bacterial contamination at the

consumers tap; 11% of the samples drawn from systems using surface waters as a source of supply exceeded the recommended organic chemical limit of 200 parts per billion; 53% of the systems evidenced physical deficiencies including poorly protected groundwater sources, inadequate disinfection capacity, inadequate clarification capability, and/or inadequate system pressure; 79% of the systems were not inspected by State or county authorities in 1968, the last full calendar year prior to the study, and 50% of the chief operators of the supplies did not remember when, if ever, a state or local health department has surveyed the supply; 77% of the plant operators had inadequate microbiological training and 46% were deficient in chemistry relating to plant operation; cross connection prevention ordinances, plumbing inspection programs on new construction, and re-inspection programs were lacking in a vast majority of the systems studied; the study showed that as to training 61% of the personnel responsible for the operation of water treatment facilities have not had formal training even at the short course level; 77% were deficient in microbiological training; 72% were deficient in chemical training.

The smaller water systems often operated by part-time personnel, generally have the poorest records of operator training and experience.

PRESENT TASKS OF THE BUREAU OF WATER HYGIENE

The Bureau of Water Hygiene works to assure the safety and adequacy of the water that man ingests or otherwise contacts in his day-to-day activities by conducting a comprehensive program of research, development, technical assistance and training.

In the current fiscal year, the Bureau has; (1) Completed a cross section study of community water supplies involving 969 systems serving approximately 18 million people, which documents for the first time the deficiencies in the Nation's water supplies; (2) completed joint Federal-State field surveys on 43 of approximately 700 water systems serving interstate carriers; and (3) launched a technical task force to review and update the U.S. Public Health Service Drinking Water Standards.

The research accomplishments include: (1) Development of a new and fast method for the identification of fecal contamination; (2) development of new quick, accurate, and cheaper methods of examining waters for cadmium, zinc, copper, and lead; and (3) demonstration of subclinical methemoglobinemia in children utilizing a specific ionelectrode and direct analysis of blood samples. While the accomplishments of the BWH are admirable under severe budget restrictions, it can not be said that we truly have a Natioual water hygiene program today. But this proposed reorganization provides the opportunity to both highlight and rectify past mistakes and to begin planning and implementing the necessary action program.

The problems of the future require: 1. research; 2. planning; 3. technical assistance; and 4. surveillance, if our society is to continue to be blessed with the benefit of adequate quantities of safe drinking water.

THE ADEQUACY OF WATER HYGIENE RESEARCH

We must not lose sight of research and development needs which exist today' Each of us faces a host of new questions on a day-to-day basis. One day the questions concern arsenic, the next day, nitrates. And how about mercury? Is there a general accepted detecting method? And, once the measurement is made, what criteria is used to judge health effects?

It is evident that a broad program of research and development is vitally needed to investigate and elucidate potential hazards, thereby insuring the strength of the Nation's water supplies and to provide for a higher degree of efficiency and effectiveness in the management of water supply systems. For example, a recent Bureau of Water Hygiene Report summarized some of the potential hazards as follows: "Water for direct and indirect human ingestion contains varying amounts of organic and inorganic material and in some cases may harbor bacteria and viruses. In order to safeguard the health of the American public by having the mechanism to detect, analyze, and remove any hazard in water, many studies MUST be conducted. Compounds to which people are exposed number in the thousands and include herbicides, insecticides, corrosion inhibitors, water softeners, coagulants, coagulant aids, fecal material, industrial waste material and breakdown products, household waste material and breakdown products."

Using the carbon-chloroform-extraction technique, it is known that many of these organic and inorganic compounds are in drinking water. What we need to

know is: (1) Specifically, which chemicals are in water?; (2) What is the concentration of each chemical in the water?; (3) What are the efficiencies of recovery (for analysis) of the compounds?; (4) Are the chemicals at the environmental concentration a hazard, either acute or chronic, to the health of the users?; and (5) If a hazard exists, what procedures can be used to effectively cope with the problem? It is equally apparent that virology criteria must be added to future editions of the Drinking Water Standards stressing the need to develop new methods of sampling, isolating, concentrating and enumerating enteric viruses. And, aside from detection procedures, health effects, and constituent levels there is the need to develop and demonstrate new municipal and individual water treatment procedures.

MANPOWER AND TRAINING REQUIREMENTS

Providing a continuing safe and adequate water supply depends on a research and development program in water analysis, an ability to evaluate health effects of the water constituents, and a full understanding of treatment methodology. It progresses through the design and construction of suitable treatment and distribution facilities and ends with the proper operation of the facility under the guidance of a ground surveillance and technical assistance program. With this in mind, several areas of manpower need emerge: (1) Engineers and technicians are needed to design and supervise the construction and operation of water treatment and distribution facilities; (2) Managers and operators are needed to supervise the operation and maintenance of water supply and distribution facilities; and (3) Research engineers and scientists are needed to conduct a water quality surveillance and technical assistance program at both the state and Federal level and to conduct the research and development program related to municipal water supplies.

It is estimated that in the next 20 years, over 20,400 new plant operators will be required. At the present time, the inadequate salary structure of most small public water systems has meant that the average operator in the small utility has less than a high school education. A Federal program to enforce mandatory certification of water plant operators based on the completion of a minimum level of general education (high school graduation) and specialized training is long overdue. Water treatment technology is sufficiently advanced, and the public health responsibility is so important, that the minimum specialized training need for a plant operator and/or manager in responsible charge of a water plant or system is the completion of a 2 year technical institute program in water hygiene technology. To attract competent people to enter this important field, a major change in the salary structure for operators and managers of the smaller, public water systems is essential. Such a salary structure is, of course, dependent on the availability of adequately trained personnel.

Thus, there is a significant and overwhelming need to develop a pool of trained operators at the post-high school or technical institute level. In the area of water pollution control, this need has been recognized to the extent that the Water Quality Act of 1970 recently passed by Congress authorized the expenditure of $62 million for the training of men at the undergraduate level in the design, operation, and maintenance of water quality (pollution) control facilities. If we can justify such a program in pollution, how much more important is such a program in the area of water hygiene? This expenditure of funds for operator training is designed to provide more adequate training of people to operate plants for the production of water which can be returned to our streams. Unfortunately, the legislation and the authorization ignored the fact that there is an equal need for training of operators for the operation of water facilities where the water is designed to be used for human consumption.

Even if we were willing to accept deficiencies in average chemical water quality, and we are not so inclined, who has the resources to provide on-the-job training, technical assistance, or short-courses on disinfection even if we could discount the numerous other prevalent community water system deficiencies? Certainly, the results show that the State and county health departments, as now financed, are hard pressed to inspect the community systems in an effort to detect and correct gross deficiencies let alone provide broad technical assistance and training.

It should be apparent to the entire professional community, local, state, university, and Federal, that we can either wait for a major tragedy to occur and say "we told you so" or we can begin to face up to our program deficiencies and identify water hygiene program needs in a responsible professional manner.