Toxic Brew: DGS & Child Safety

Perhaps the oddest moment of the 5+ hour city council hearing on October 3, dedicated to sussing out why we have actionable lead levels on DC public playgrounds and recreational spaces with synthetic surfaces, was when the director of the agency responsible for those public places and all DCPS facilities (DGS) noted that lead is a “naturally occurring substance.”

(Yeah: see it here.)

Coming after hours of public witnesses testifying as to how poor communication and standard setting by DGS have resulted in obfuscation of even basic principles regarding testing, preventing, and remediating a substance unsafe at any level (see this video of Ward 4 ANC commissioner Erin Palmer for a good summary), declaring that lead is “naturally occurring” is pretty rich–especially as lead is present in urban environments mainly through the actions of people, not Mother Nature.

But that statement revealed a lot–about DGS.

That is, many of DC’s outdoor, public play spaces that DGS oversees have artificial turf and rubbery, poured-in-place surfaces that have many attractive qualities–as well as unattractive ones. While such synthetic surfaces are relatively durable, low maintenance, and shock-absorbing, the materials used therein can also contain carcinogens, hormone disrupters, and other substances that one doesn’t want children touching, much less ingesting–including lead.

And that’s not even getting into the fact that such synthetic surfaces can (and do) fail hardness tests as well as have dangerously high temperatures.

To better elucidate the safety of such commonplace materials in DC’s public spaces, two studies in DC have been recently funded: to ensure a master list of all synthetic materials on public recreational spaces as well as to evaluate the safety of the materials themselves.

This is great news going forward. But what that 10/3 hearing made very clear is not only how much we as a city have yet to do, but how much we as a city have failed to do regarding our synthetic surfaces.

For instance, DGS has a website to show the latest hardness tests, as well as a page with the latest lead tests.

That all sounds good until you realize the enormity of what the public doesn’t know, including

–All schedules of lead, temperature, and hardness testing;
–What that testing constitutes at each surface and all testing protocols;
–Who maintains each individual outdoor play space in DC (DGS may contract with others for this–and does not work on nor tests charter schools’ outdoor play spaces, even though some are located in DC-owned former DCPS schools);
–What constitutes maintenance for each individual synthetic surface;
–The schedule of that maintenance;
–Communication protocols for testing and maintenance of synthetic surfaces, including test results;
–How, when, and where are replacements determined to be needed and then done;
–Who makes those decisions and on what basis;
–Remediation schedules;
–Determination of remediation efficacy;
–Protocols for field and playground closures because of failing tests for hardness, lead, or temperature; and
–Making all this information available in a publicly accessible way that is not disaggregated (i.e., not in separate, unrelated websites).

And that’s not even getting into the weeds of how we got here in the first place. Simply put: who made the decisions to put in poured-in-place and artificial turf around the city and why (i.e., some DC public fields have grass); current contractors and their bidding processes for the synthetic surface installation, testing, and remediation; and how those companies are connected to the DC politicians who have supported putting in poured-in-place and artificial turf surfaces.

The upshot is a city agency charged with safeguarding the facilities that our children use at a seeming remove from public concerns about that safeguarding.

For instance, at the 10/3 hearing, DGS personnel made clear that the agency attributed elevated lead levels on a variety of synthetic outdoor school and recreation surfaces to environmental lead–despite evidence that the synthetic materials themselves likely contain lead (including, incredibly, their pigments).

Moreover, there did not appear to be obvious answers for how remediations are being handled (one elementary, Thomson, had its synthetic surface covered, while others have had them removed entirely) nor how effective the remediations are and whether the remediation effort itself is safe (i.e., where are the materials being disposed and how is the rinse water, used to rinse off surface lead, being handled).

Perhaps the most shocking aspect of all of this is that DGS was in a similar position just 3 years ago with lead in school water.

While there are now more clearly articulated processes for making test results public and relatively strict allowable levels, both DGS and the deputy mayor for education (DME) have not made protocols on school water testing clear.

For instance, a revised water-testing protocol was open for public comment 30 days this summer–but never really advertised.

Then, on August 7, members of the public submitted questions and comments on it–but got no response. On September 23, in response to questions about that nonresponsiveness, Alex Cross in the DME’s office noted in an email that the testing protocol document would be “finalized shortly.”

Nearly a month later, there is still nothing in place, at least publicly, for a water-testing protocol nor have any answers to questions from the public been released.

All of which (ironically) substantiates public fears that DGS never wanted to have anyone in the public aware of or present at its school water testing, which would act as a check on any contractor or DGS personnel simply flushing water lines prior to testing–which would artificially lower levels of detectable lead while doing nothing to actually address the problem.

That lack of clarity regarding procedures for dealing with lead on playgrounds and in school water appears to extend to DGS’s treatment of lead elsewhere in our schools.

For instance, at Maury elementary’s 1886 building, original plaster was apparently untouched during its recent renovation by DGS and simply covered over with dry wall (see a picture here, from a February public meeting document put out by DCPS and DGS).

Such sealing can, in fact, be a good strategy for containing lead-based paint.

But parents noted that there are few, if any, records available to show what abatement of lead paint was ever done at the school by DGS. The fact that this picture doesn’t show any effort to contain chipping paint and dust is thusly worrisome. Not to mention that if ducts were not sealed during that work and there was lead paint on the plaster, it is possible that lead dust entered the school’s ventilation system.

Possibly because of public concerns regarding this history of DGS work in schools, the 10/3 hearing also featured council members and public witnesses discussing other basic safety concerns in our schools, including the fact that fire alarms at Beers elementary that didn’t sound in June when the school had a fire were actually functional, but had been turned off. (Sigh.)

During the hearing, DGS also noted that despite 124 recent fire code violations in DCPS schools, all have been mitigated.

One certainly hopes that’s the case–because this FOIA production of outstanding work orders for my kids’ elementary and middle schools at the start of this school year shows many concerning things in DGS’s purview there, including fire management systems in need of service or inspection.

What makes this FOIA production all the more incredible (well, besides the fact that it’s actually incomplete–am still waiting for the rest, including the open work order for Stuart-Hobson’s main library door, which has been nonfunctional for at least 5 years) is the fact that these work orders are for three separate buildings that together have received around $100 MILLION in renovations in less than a decade, all overseen by–wait for it!–DGS.

In other words, from my little corner of DC, it doesn’t seem like we’re getting a lot of value for that municipal fortune paid out to DGS and its private contractors.

Possibly worse, as a parent whose child lived through the Stuart-Hobson renovation with dust literally everywhere for years running (and attendant health issues among staff and students), I can attest to how DGS has not effectively watched out for kids in schools being modernized.

That is, despite DGS pulling back from doing work in schools while children are present in those schools (a la Stuart-Hobson), kids nonetheless are still being exposed to construction debris and dust (Eliot-Hine, anyone?). Worse, the loss of Ferebee-Hope in Ward 8–leaving no swing space anywhere in either ward 7 or 8–means that the many unrenovated schools east of the Anacostia River will inevitably have children up close to construction zones if and when those schools are ever touched by modernizations.

What makes all of this concerning (well, beyond kids being IN active construction zones) is that there are apparently no standards anywhere regarding the safety of children in construction zones. This is not due to neglect–it’s because, well, children are not normally part of construction zones! (Normally, of course.)

As a large city agency, DGS clearly has many masters, including a mayor and numerous contractors, all of whom may have political as well as monetary reasons to put a good face on something that may not, in fact, deserve it.

But there is one master that DGS seems to lack almost entirely: the public.

And our kids pay a very steep price.

2 thoughts on “Toxic Brew: DGS & Child Safety

  1. Thank you for a this overview and analysis of the unnecessarily harmful exposures at school and play faced by children in DC and the weak response by DGS that may add insult to injury with inappropriate lead abatement (and it’s abatement not just “remediation” that is needed: full and CAREFUL removal of all lead contaminated materials- carefully so to there is no spread of lead further). As you note CDC and American Academy of Pediatric


  2. One point of clarification. Has DC released the full report on lead levels with ALL the numbers – not just those over 400ppm? That is an inappropriately high lead standard to apply to playgrounds (90 ppm is paint standard and 100 ppm children’s product standard). As you note the U.S. Centers for Disease Control (CDC) and American Academy of Pediatrics (AAP) have stated in no uncertain terms – there is NO SAFE LEVEL of lead to expose children to. AAP also states that all regulatory levels only give an “illusion of safety”: the only actual safe level is NOT DETECTABLE. So at the very least school officials and parents need to know which are over 90ppm . Lead exposure is cumulative and in the body forever- in addition to affecting the brain lead is stored in and released from the bones during pregnancy and old age, to poison fetal and aging brain. The poison that crosses the lifespan and generations.


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