Health-Based Drinking Water Violations 101

For example, let us look at health-based drinking water violations. Health-based violations are fairly common, with national data showing 1 in 10 Americans drinking water from a system that experienced health-based violations during the three-year period of 2018 to 2020 . Violations range from bacterial contamination to chemical safety breaches, and can, depending on the persistence and scope of the violations, be an indicator of a potentially failing system because they directly correlate with public health risks that undermine safe drinking water delivery. However, data on health violations is dependent on various factors, including enforcement rates, regulatory frameworks, reporting consistency, and real-world water system issues. To understand more, let us examine the growth of health-based violations in Texas from 1978 - 2024.

In this graph, the data says there is no doubt we are seeing more violations. But what does that mean? Are we actually witnessing a decline in water quality delivered to customers? The reality on the ground may be more nuanced.

Changes in Health-Based Drinking Water Violations: 1990 - 1994

For example, the Total Coliform Rule (TCR) implemented in 1990, created a new framework for water quality monitoring that changed how violations were tracked and reported. What initially appeared as an increase in water quality problems may be largely due to more rigorous testing requirements and improved detection methods, rather than a sudden decline in water quality. The subsequent drop in TCR violations indicates that systems were responsive to the increased monitoring requirements, resulting in improved water quality from a TCR perspective.

Changes in Health-Based Drinking Water Violations: 2001 - 2010

When we look at health-based violations in Texas in the past 40 years, we see a stark increase starting in the early 2000s. Quite a few new national primary drinking water regulations came into effect at the turn of the century. Similar to the impact of the new TCR noted in the figure above, these new requirements may be behind the increased violations highlighted in the figure to the left.

Changes in Health-Based Violations 2015 - 2020

As the drinking water world learned more about the impact of coliform bacteria, the Revised Total Coliform Rule went into effect in 2016, resulting in a response from water systems and a corresponding reduction in Total Coliform violations in years following implementation of the Rule.

This analysis underscores both the power and limitations of examining complex questions through a purely quantitative lens. As veteran technical assistance providers reminded us during our investigation, boil water notices are NOT inherently an indicator of system failure. These notices often represent proactive public safety measures rather than systemic breakdown.

Similarly, water quality violations, like those involving PFAS or fluoride, may hint at underlying issues, but their true significance depends on additional factors like the level and persistence of the violation, and how the system responds. For example, a violation for exceeding the MCL or Maximum Contaminant Level of a rule might be a one-off event; however frequent exceedances, across multiple rules, can indicate a concerning systemic issue.