Public record / dated comparison

What the blind call could and could not know

A November 6, 2015 briefing stays intact beside later findings. This is a communication analysis, not an all-clear, medical advice, or an operational order. Approval to publish remains unknown.

Two records, two dates

Knowable November 6, 2015 / F1 and F2

The original public call

This packet does not justify a citywide assurance that the water is safe.

Three dated results at one residence, not three independent households and not a citywide prevalence estimate. The October 21 EPA report addresses three residences overall. F1, October 21, 2015, printed page 11, Appendix B.

Lead results at one residence, F1 printed page 11
Sample dateLeadSource
February 18, 2015104 µg/LF1, printed page 11
March 3, 2015397 µg/LF1, printed page 11
April 2, 2015707 µg/L*F1, printed page 11

* The source row has an asterisk; this packet does not explain it. Minimum 104 µg/L; maximum 707 µg/L; spread 603 µg/L. These are not a representative sample.

Observed and recommended: The November 4 transmittal reports a switch back and filters provided, while additional corrosion control treatment "will be implemented." It recommends notice when work may disturb lead service lines. The report asks for representative sequential sampling across common plumbing materials. F1, November 4 memorandum, PDF page 1; report printed pages 6-7.

Institutional plan: The October 16 task force release promises technical assistance on reconnection and optimized corrosion control, not proof of achieved systemwide safety. F2, October 16, 2015, technical assistance excerpt.

Public action requested: Recommend advance notice near planned service-line work and request privacy-safe, representative sequential sampling and publication of methods and aggregate results. Ask community partners to review translation and accessibility before authorized publication; refer urgent exposure or treatment questions to responsible authorities. Citywide distribution and intervention effects remain unknown. F1, printed pages 6-7.

Established January 21 and October 20, 2016 / F3 and F4

Order finding, then oversight assessment

EPA order, January 21: EPA determined city and state responses inadequate and continuing, and found city-provided water posed an "imminent and substantial endangerment." EPA said it would promptly begin sampling tap-water lead; paragraph 54 requires information without public disclosure of personally identifiable information. F3, January 21, 2016, introduction paragraph 1; determination paragraph 33; order paragraph 54.

The order's finding that the city lacked corrosion control treatment at its plant was attributed to an April 24, 2015 notification. This later order finding is not evidence that the blind reviewer possessed the order in November. F3, January 21, 2016, findings paragraph 10.

OIG retrospective, October 20: The OIG assessed that Region 5 had authority and sufficient information for an emergency order as early as June 2015; it reported the region regarded state action as a jurisdictional bar. Its printed page 5 describes information available by June on corrosion control and at least four homes above the action level. That assessment is not an adjudication of anyone's personal motive. F4, October 20, 2016, At a Glance PDF page 3; printed page 5.

76 days elapsed from the public November 6 cutoff to the January 21 order. The small blind packet could not predict the order's exact legal findings or date, when subsequent sampling would begin, or the later OIG assessment. F3, January 21, 2016; F4, October 20, 2016.

What the earlier plan could help: Advance notice would communicate a documented disturbance risk; representative sampling would seek evidence missing from the blind packet. Neither later source demonstrates a counterfactual health outcome if that plan had been implemented. F1, printed pages 6-7; F3, January 21, 2016, introduction paragraph 1.

Dated record, not a quantitative scale

Equal spacing below is for legibility, not elapsed-time magnitude. The list remains available without scripts.

Nine dated events from February 2015 through October 2016Three F1 samples, F2 task force release, F1 report and transmittal and public cutoff, F3 emergency order, F4 retrospective assessment. Equal spacing does not represent elapsed time.Feb 18, 2015 / F1 sampleMar 3, 2015 / F1 sampleApr 2, 2015 / F1 sampleOct 16, 2015 / F2 releaseOct 21, 2015 / F1 reportNov 4, 2015 / F1 transmittalNov 6, 2015 / public cutoffJan 21, 2016 / F3 orderOct 20, 2016 / F4 OIG
  1. : 104 µg/L at one residence. F1, printed page 11.
  2. : 397 µg/L at the same residence. F1, printed page 11.
  3. : 707 µg/L* at the same residence. F1, printed page 11.
  4. : task force release. F2, release excerpt.
  5. : final report dated. F1, report heading.
  6. : report transmittal. F1, memorandum PDF page 1.
  7. : public cutoff and preserved blind call. F1, public posting recorded in SOURCES.csv.
  8. : EPA emergency order. F3, paragraphs 1 and 33.
  9. : OIG management alert. F4, At a Glance PDF page 3.

Compare what an institution said

Switch between the prospective 2015 commitment and the 2016 order finding. Different sources and dates, not contradictory measurements of the same sample.

October 16, 2015: prospective assistance

“The Task Force will provide technical assistance to the MDEQ and the City of Flint to reconnect the Flint system to a new source of drinking water (to be supplied by the Great Lakes Water Authority) and to optimize corrosion control for the Flint system, starting in October 2015.”

F2, October 16 release, technical assistance excerpt. A plan does not establish systemwide safety.

January 21, 2016: emergency determination

“Based on the foregoing, EPA finds that water provided by the City to residents poses an imminent and substantial endangerment to the health of those persons.”

F3, January 21 order, determination paragraph 33. This finding postdates the blind call.

Source key and dated excerpts

  1. F1, October 21, 2015: EPA Region 5 final report and November 4 transmittal; publicly available November 6 per SOURCES.csv. Printed page 11, Appendix B: “February 18, 2015: 104 µg/L”; “March 3, 2015: 397 µg/L”; “April 2, 2015: 707 µg/L*”. Printed pages 6-7 recommend notice and representative sequential sampling.
  2. F2, October 16, 2015: EPA Region 5 task force release; excerpt quoted in the comparison above.
  3. F3, January 21, 2016: EPA Section 1431 emergency order; introduction paragraph 1, findings paragraph 10, determination paragraph 33 and order paragraph 54. The determination is quoted above.
  4. F4, October 20, 2016: EPA OIG management alert; At a Glance, PDF page 3: “EPA Region 5 had the authority and sufficient information to issue a SDWA Section 1431 emergency order to protect Flint residents from lead-contaminated water as early as June 2015.” Printed page 5 discusses the information available by June. Retrospective oversight, not a November source.