EVALUATION OF CONSUMER NOTIFICATION UNDER THE SAFE DRINKING WATER ACT

WATER RESOURCES BULLETINVOL. 25, NO.4 AMERICAN WATER RESOURCES ASSOCIATION AUGUST 1989

EVALUATION OF CONSUMER NOTIFICATIONUNDER THE SAFE DRINKING WATER ACT'

Linda A. Wardlaw and William H. Bruvold2

ABSTRACT: The Safe Drinking Water Act of 1974 as amended in1986 requires that consumers be notified when maximum contami-nant levels are exceeded in their community water supply and whenpresci-ibed testing and treatment procedures are not met. A review ofcommunication theory indicates that for the message to be effective(1) it must be received by the intended audience, (2) it must be at-tended to by that audience, (3) it must be understood, and (4) it mustbe accepted and acted upon. A review and analysis of existing re-search evaluating notification programs administered under the SafeDrinking Water Act indicates (1) that receipt rates have been highlyvariable, (2) that attention to the message has usually not been di-rectly assessed, (3) that levels of understanding, while variable, haveusually been minimal, and (4) that acceptance, though not often di-rectly measured, seemed higher than expected. These results, whilecritical of past notification programs, indicate that understanding andacceptance can be increased if receipt and attention rates are in-creased. The paper concludes with a series of recommendations forimproving receipt and attention rates, for increasing understanding,and, most importantly, for increasing acceptance and community ac-tion for upgrading local water treatment and quality.(KEY TERMS: Safe Drinking Water Act; public notification; commu-nication theory; evaluation.)

CONSUMER NOTIFICATION AND THE SAFEDRINKING WATER ACT

The Safe Drinking Water Act (SDWA) of 1974 wasdesigned to coordinate and regulate the efforts of local,state, and federal agencies in the promotion and pro-tection of safe drinking water nationwide. The SDWAwas amended and extended in 1986 and the intent ofthese actions has been explained by Gray and Koorse(1988). The Environmental Protection Agency (EPA),under amended SDWA guidelines, retains responsibil-ity for the development and enforcement of primarydrinking water regulations for all water systems pub-licly or privately owned The amended Act strengthensprovisions for public notification of water system defi-

ciencies (EPA, 1987), provisions that are the focus ofthis paper.

Table 1 summarizes the violations requiring publicnotification under the Safe Drinking Water ActAmendments of 1986 (EPA, 1987; Abbot, 1988;Hoflbuhr, 1988). As indicated in Table 1, violations aredivided into two tiers. Tier 1 violations are seen asmore serious, requiring immediate, extensive, andsustained public notification efforts. Tier 2 violationsare seen as less serious, requiring less immediate andextensive, but nevertheless sustained, public notifica-tion efforts. The most prominent Tier 1 violation occurswhen a maximum contaminant level (MCL) is exceededin the finished water distributed for human con sump-tion. The second Tier 1 violation requiring public notifi-cation occurs when a prescribed treatment technique,usually imposed in lieu of an MCL requirement, is notmet. The third Tier 1 violation involves noncompliancewith the schedule limiting the time a purveyor has tocorrect a variance or exemption to SDWA regulations.

Tier 2 violations pose less serious threats to humanhealth, making the cost and unnecessary consumerconcern of full scale public notification harder to justif'.The major Tier 2 violation occurs when a purveyor doesnot comply with the monitoring requirementsstipulated by the SDWA. The second involves failure tocomply with a testing procedure prescribed by aNational Public Drinking Water Regulation (NPDWR).The third Tier 2 violation occurs when the purveyor isoperating under a variance or exemption to SDWA re-quirements. The classification of Tier 1 and 2 violationswas developed by the EPA (1987) after the agency hadobtained and considered public comments urging thatnotification efforts match the seriousness of the viola-tion. Considerable criticism of the original regulationscentered on the perception that there was no clear dis-tinction between major and minor deficiencies in thereporting requirements (EPA, 1987).

1Paper No. 89030 of the Water Resources Bulletin. Discussions are open until April 1, 1990.2Reapectively, Project Manager, AIDS Division, University of California, San Francisco, California 94143; Professor, School of Public Health,

University of California, Berkeley, California 94720.

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Wardlaw and Bruvold

TABLE 1. Classification of Violations for Public Notification(EPA, 1987).

Tier 1 Violations Tier 2 Violations

1. Failure to comply with a 1. Failure to comply withmaximum contaminant monitoring requirements.level (MCL).

2. Failure to comply with a 2. Failure to comply with aprescribed treatment testing procedure prescribedtechnique. by a national public drinking

- water requirement(NPWDR).

3. Failure to comply with a 3. Operating under a variancevariance or exemption or exemption.schedule.

The SDWA Amendments (EPA, 1987) classify publicwater systems as community and non-community sys-tems. Community water systems provide piped serviceto at least 15 service connections or 25 people regularlythroughout the year. Non-community water systems,such as campgrounds, provide such service only on anintermittent or seasonal basis. This classification, alongwith the type of violation (Tier 1 or Tier 2), is used tostipulate the kind of public notification that must beundertaken. The many details constituting the newregulations, which became effective in April 1989, arefully presented in the reference cited (EPA, 1987) andonly their basic structure is summarized here.

For Tier 1 violations that pose an acute risk to hu-man health, community water systems are required toprovide a notice to the electronic media within 72hours. This must be followed by a notice printed in a lo-cal newspaper within 14 days. A written notice must bemailed to consumers within 45 days, and the mailednotice must be repeated every quarter until the viola-tion is corrected. The mailed notice may be waived bythe State if it determines that the violation has beencorrected within the 45-day period. The notificationprocess for Tier 1 violations that pose no acute threat tohuman health differs only in that notice to the elec-tronic media is not required.

Tier 2 violations in community water systems re-quire notification in a local newspaper within threemonths of the violation or granting of the variance orexemption. The newspaper notice must be followed bymailed notices sent every quarter for as long as the vio-lation exists.

Under the provisions of the amendments, non-com-munity water systems may deal with any of these vio-lations in the same manner as community systems.However, because resources are often more limited inthe non-community systems, alternative methods arestipulated for meeting the notification requirements.Non-community systems can post a written notice in aconspicuous place or hand deliver the notice to con-

sumers. The posted notice must remain in place untilthe violation is corrected. Hand delivery of such noticesmust be repeated quarterly until the violation is cor-rected.

All required written public notices must provide aclear and readily understandable explanation of theviolation; any adverse health effects; the population atrisk; the necessity for seeking alternative water sup-plies, if any; other preventive measures the consumershould take until the violation is corrected; and thesteps that the public water system is taking to correctthe violation (EPA, 1987). The public notification re-quirement is designed to be first of all a warning sys-tem to protect public health, but it also is intended toserve as a tool for educating the public about the prob-lems underlying their utility's current deficiency. It isreasonable to assume that, if people are educated aboutthe problems facing public water systems, they may bewilling to support greater expenditures at all levels forresolving such problems (USGAO, 1982).

The recent amendments to the SDWA (EPA, 1987)indicate that public notification will continue to be amajor activity required of all public water systems inthe United States for the foreseeable future. Thus it isimportant to summarize and integrate past researchevaluating public notification activities to determine ifthese activities have, in fact, informed the consumersabout harmful constituents in their water supply and todetermine if these activities have, in fact, generatedpublic support for correcting these problems. Results ofsuch an evaluation will be useful to future notificationefforts by indicating how difficulties and shortcomingsexperienced by past notification efforts can be dealtwith and overcome.

CRITICAL COMMUNICATION FACTORS

Risk communication is often thought to be the taskof reducing the discrepancy between the formal, objec-tive assessment of risk and the subjective, emotionalresponse to it. It is not difficult in principle to endorsethe right of the public to know about environmentalrisks, but it is extremely difficult to ensure that it re-ceives more than symbolic attention.

The duty to disclose risk cannot be discharged if themessage fails to reach those who need to hear it.Therefore any measures that can increase the thor-oughness of disclosure should be considered of primaryimportance. If written communication is the methodemployed, appropriate attention to distribution will becritical. Accurate mailing lists or prominent postingsites will increase the odds that the intended audiencewill get the message.

WATER RESOURCES BULLETIN 838

Evaluation of Consumer Notification under the Safe Drinking Water Act

If the message is designed so poorly that it attractslittle or no attention, then the communication attemptwill have failed at this stage. Mass mailings may beparticularly subject to such problems. The message mayget lost in the shuffle of everyday "junk mail." The like-lihood that the message will be read may depend inpart upon such factors as print size and style and thequality or color of the paper (Smith and Bass, 1979;White, 1982). Such physical characteristics may be es-pecially critical if the official message must competewith more compelling media images.

The clarity and precision of the message will deter-mine in part the level of understanding that recipientswill have of the content. If the message is too complex,too lengthy, or alternatively, too sketchy, the public willnot be able to understand it. If they cannot, the com-munication will have failed even though it succeeded inreaching the audience.

In the end, whether the message is accepted by thepublic and acted upon is very difficult to control, but itis perhaps the most critical component of a successfuldisclosure effort. As noted above, a major purpose ofpublic notification under the SDWA is to increase pub-lic support for financing the improvements in publicwater supply facilities necessary to remedy the prob-lems requiring notification.

In summary, successful communication (1) must bereceived by the intended audience, (2) must be attendedto by that audience, (3) must be understood, and (4)must be accepted, and if necessary, acted upon.Community-wide disclosure programs are still rela-tively new. There is optimism about them in some cir-cles, consternation in others, and some confusion for allwho must see that they are carried out in an ethicaland legal manner. It will be helpful to examine the safedrinking water community-wide disclosure program insome depth to see how it has been implemented and togauge its major strengths and weaknesses in communi-cating environmental risk.

EVALUATION RESEARCH

Conventional and two computer-based literaturesearches located fifteen published reports that dealtspecifically with the public notification provision of theSDWA. Nine of the fifteen (Douglas, 1976; Gaston,1977; Segree, 1979; Gray and Koorse, 1988; Abbott,1988; HofThuhr, 1988; Shaw and Herb, 1988; Tenny,1988; Wendel, 1988), while providing valuable com-mentary on the philosophy and operation of the publicnotification provisions of SDWA, reported no empiricaldata that could be employed to evaluate the publicnotification process. Six empirical studies reported

evaluations of the consumer notification provisions ofthe SDWA, and these are noted in chronological order.

Bruvold and Gaston (1980) conducted surveys ineight Southern California communities. Fifty respon-dents were selected from each community by methodsdesigned to give every adult member of the communityan equal chance to participate in the survey.

Stegman and Schneider (1982a), in the first phase oftheir study, mailed questionnaires to 190 water sys-tems in 14 states that had recently notified consumersof bacterial or turbidity quality violations. A total of 101questionnaires were mailed to systems serving small(250-999) populations, 75 were mailed to systems serv-ing intermediate (1,000-9,999) populations, and 14 weremailed to systems serving large � 10,000) populations.

In a second study Stegman and Schneider (1982b)conducted phone interviews with 50 respondents ineach of 28 communities selected from the 190 chosen forthe initial survey to represent the six combinations ofsize and contaminant type. Billing lists were used toselect the 50 respondents from each utility service area.

Lemley, Fessenden-Raden, Bisogni and Holway(1985) report a two-stage study done in a community inupstate New York faced with a chronic nitrate problem.The first survey questionnaires were mailed to 655customers selected from the utility's billing list with144 (22 percent) returned. Several months later, follow-up interviews were conducted in 69 (48 percent) of thehouseholds that had returned the questionnaires.

Bruvold, Wardlaw and Gaston (1985) performed asecond study in California in 15 communities that hadrecently received notification of violation of an MCL.Five problems involved nitrates, five bacteria, and fiveturbidity. The sixty respondents interviewed in eachcity had been selected in a manner designed to giveeach adult resident in the community an equal chanceof inclusion in the survey.

In a related follow-up study, Wardlaw (1986) per-formed a detailed analysis of notification methods andwritten communications employed in the more recentCalifornia study in order to clarify how these factorsinfluenced understanding of the message.

Reaching the Audience

Bruvold and Gaston (1980) report that 47 percent ofrespondents were certain that they had received thenotice sent by the water utility. Another 9 percent wereuncertain if they had received it. Forty-four percent ofall respondents were sure they did not receive the no-tice.

Stegman and Schneider (1982b) reported that 41percent of respondents were aware of a consumer noti-fication in their community.


Wardlaw and Bruvold

Lemley et at. (1985) report that 99 percent of thosewho responded to the initial mailed questionnaire saidthat they knew about the notice. It should be noted thatthe researchers used the same list for mailing ques-tionnaires that the utility used for mailing out notices.

Bruvold et at. (1985) report that, overall, 68 percentcould recall receiving notice about the violation. Acrossthe 15 communities studied, these percentages rangedfrom a low of 43 percent to a high of 83 percent.Wardlaw (1986), in the follow-up study, found that bill-paying status was highly related to recall of the notice,with bill payers reporting higher rates of recall.

Attending to the Message

Only one of the studies (Lemley et at., 1985) directlyaddressed public attention to the notification message.The researchers asked respondents if they had in factread the notice mailed to them. Eighty-seven percent ofthose responding said they had read it. Respondentsparticipating in the follow-up survey were asked if theyhad read any of the newsletters mailed to utility cus-tomers. Sixty-one percent of those personally inter-viewed indicated that they had read all or part of atleast one newsletter.

Wardlaw (1986) performed further analysis of dataobtained from the earlier survey work of Bruvold et al.(1985) and found that there was a limited relationshipbetween awareness of the notification effort and overallsize of the notice in square inches.

Understanding theMessage

Bruvold and Gaston (1982) measured consumer un-derstanding of the notification messages by askingthose respondents who could recall the notice whathealth problems were associated with the contaminantand what personal action was required to avoid suchproblems. Only 7 percent (3 percent overall) of thoserecalling the message demonstrated clear understand-ing of it. But 46 percent (22 percent overall) of thosewho recalled the message demonstrated partial under-standing of message content.

The consumer survey conducted by Stegman andSchneider (1982b) asked respondents two questions re-lated to understanding of notification content. About 39percent knew that the notice was about a water prob-lem and some 33 percent understood that the problemwas a violation of a specific water quality standard.

Lemley et at. (1985) asked respondents specificquestions about the content of the nitrate contamina-tion notice mailed to them. Most importantly, 55 per-cent of respondents knew that nitrates were a specialhealth risk for young infants. Additionally 33 percent

accurately reported the existing nitrate level in thecommunity water supply and 25 percent knew what thefederal standard was for maximum contaminant levelsof nitrate in public water supplies. These results mustbe interpreted against a 99 percent notification aware-ness level in the respondent group.

Bruvold et at. (1985) report results separately for the613 respondents who recalled the notice and the 287who did not recall the notice. For the former group, 46percent had specific knowledge about the contaminantand its effects while 9 percent of the latter group hadsuch knowledge. Twenty-five percent of the formergroup had some general knowledge of the contaminantand its effects while only 4 percent of the latter grouphad such knowledge.

In a further analysis of the second California study,Wardlaw (1986) found that the amount of informationcontained in the written message was significantly re-lated to knowledge about contaminants and about pos-sible solutions. Written messages judged to be fully in-formative were associated with higher levels of under-standing than were messages judged to be minimallyinformative. Regarding the long-range solution to theproblem requiring notification, 65 percent of those re-ceiving the informative message understood the solu-tion required and 41 percent of those receiving a mini-mal message understood the solution required.

Accepting the Message

It is very difficult to directly measure "acceptance" ofthe message. It could be argued that, in the end, onlyaction leading to a change in the status of the waterquality problem itself can be considered to be meaning-ful acceptance of the message. However the notificationmessage can be fully understood, but no change will oc-cur because the course of action proposed by the mes-sage is not acceptable to the public.

It is also true that public endorsement of the princi-ple of the notification process does not ensure that so-lutions proposed by such notifications will even occur.Nevertheless, the degree of acceptance of the notifica-tion program reflects the climate in which water utili-ties must operate to solve water quality problems.Further, indirect markers of acceptance, such as ex-pressed willingness to pay more to correct underlyingproblems, also reflect the degree to which the notifica-tion message has been accepted and agreed upon.Acceptance of the message in the six empirical surveyswas indirectly measured by either the stated degree ofsupport for the notification program or by willingness tobear increased costs for resolving water quality prob-lems.

Bruvold and Gaston (1982) assessed the degree ofstated support for public notification programs. They



found that 71 percent of all respondents thought suchnotices were of definite value, 14 percent said that theywere of possible value, and 5 percent strongly doubtedthe value of the notification program.

Stegman and Schneider (1982a) asked utility opera-tors to estimate how much their customers would bewilling to pay to correct the problems that requiredpublic notification. Thirty-eight percent believed thattheir customers were unwilling to spend additionalmoney for any reason, 38 percent concluded that theircustomers would be willing to pay some additionalamount to correct existing problems and 24 percentthought that their customers might pay even largeramounts to cover the cost of facility and system mod-ernization.

In the questionnaire survey directed at customers,Stegman and Schneider (1982b) found that 20 percentof those responding were willing to pay more to improvewater quality. The response also revealed that the mainreason why 80 percent of those responding wereunwilling to pay more was because they were satisfiedwith the current quality level of the water delivered tothem.

Lemley, et al. (1985) directed extensive attention toconsumer willingness to pay more in order for waterquality to meet established standards. A total of 35percent of those responding said they would pay"whatever amount is necessary" or a "substantial in-crease over the present rate." A total of 53 percent ofthose responding said they would be willing to pay at

least a slight increase to meet standards. Only 12 per-cent were unwilling to pay any additional costs.

Bruvoid et al. (1985) asked two questions related toacceptance of the notification program. A large majorityof respondents (82 percent) believed that consumersshould always be notified, 14 percent said that con-sumers should be notified only if health is threatened,and 4 percent said that the notification program shouldbe discontinued.

Wardlaw (1986) reports survey results regardinghousehold actions taken in response to the notification.Twenty percent of the respondents reported taking aspecific action, for example bottled water purchase, and80 percent reported no action was taken. It should benoted that in most cases, no specific action was recom-mended by the notice.

EVALUATION SUMMARY

Table 2 summarizes results from currently availableresearch evaluating the public notification provisions ofthe SDWA. These results deal directly with the per-centages of respondents receiving, attending to, under-standing, and accepting the message. Further, the re-suits presented in Table 2 can also be scrutinized forpossible relationships between these four outcomes andfor assessing the overall worth of the public notificationprogram.

TABLE 2. Tabular Summary of Results from Five Published Evaluations of Consumer Notification.

StudyRespondentsand Sites

Reaching theAudience

Attending tothe Message

Understandingthe Message Accepting the Message

1. Bruvold & Gaston 400 Respondents Yes 47% --- --- Full 3% Definite Value 71%(1982) 8 Towns Unsure 9%

No 44%.-- ---.-- ---

Partial 22%None 75%

Possible Value 14%No Value 5%

2. Stegman & 176 Respondents .-- .-- --- --- --- Pay More 62%Schneider (l982a) 176 Utilities --- ..- -.- --- --- --- Not Pay More 38%

3. Stegman & 1400 Respondents Yes 41% --- --- General 33% Pay More 20%Schneider (1982b) 28 Towns No 59% --. --- None 67% Not Pay More 80%

4. Lemley, Fessenden- 144 Respondents Yes 99% Yes 87% Correct 55% Pay Considbly More 35%Raden, Bisogni, and 69 Respondents No 1% No 13% Incorrect 45% Pay Somewhat More 53%Holway (1985) 1 Town Pay No More 12%

5. Bruvold, Wardlaw 900 Respondents Yes 68% --- --- Full 34% Defmite Value 82%and Gaston (1985) 15 Towns No 32% -.- --- Partial 19%

None 47%Possible Value 14%No Value 4%

6. Wardlaw (1986) 900 Respondents15 Towns

Bill PayersYea 72%No 28%Not Bill PayersYes 33%No 67%

Large FormatYes 69%No 31%Small FormatYes 67%No 33%

InformativeYes 65%No 35%MinimalYes 41%No 59%

Household Action 20%No Household Action 80%


Wardlaw and Bruvold

Percentages of respondents reached by the messagevaries from a low of 41 percent (Stegman andSchneider, 1982b) to a high of 99 percent (Lemley et al.,1985). These results are very mixed and indicate, whenthey fall below 80 percent, that the notification effortswere not as successful as could be reasonably expected.The study results reviewed in Table 2 provide little in-formation on attending to the message. However, dataon understanding the message show that all notifica-tion programs evaluated left much to be desired.Theoretically, acceptance is contingent upon prior un-derstanding, and if understanding does not occur, anecessary condition for acceptance is missing. Thestudy results reviewed in Table 2 provide only indirectinformation on acceptance but, as noted, the major ob-jective of the consumer notification program, accep-tance of the message, cannot be attained if not precededby understanding. Viewed from this perspective it mustbe concluded that the evidence from the consumer sur-veys (Bruvold and Gaston, 1982; Stegman andSchneider, 1982; Lemley et al., 1985; Bruvold et al.,1985; Wardlaw, 1986) indicate that notification pro-grams have fallen short of reasonable expectations forobtaining program objectives.

Nevertheless, further scrutiny of Table 2 gives somebasis for optimism. Bruvold and Gaston (1982) foundthat 47 percent of respondents remembered receipt ofthe message but only 3 percent fully understood it.However, Bruvold et al. (1985) found in the secondCalifornia study that 68 percent remembered receivingthe message and 34 percent fully understood it. Thus,for the two California studies, a higher rate of reachingthe audience appears to result in a higher rate of un-derstanding the message. The same conclusion obtainswhen comparing the results of Stegman and Schneider(1982b) and Lemley et al. (1985). In the former study 41percent of respondents acknowledged receipt and 33percent understood the message. For the later studythese percentages were 99 percent for receipt and 55percent for understanding.

There is also evidence that higher rates of under-standing the message result in greater acceptance ofthe message. Stegman and Schneider (1982b) foundthat a 33 percent rate for understanding was associatedwith a 20 percent rate for acceptance, as defined bywillingness to pay more to upgrade treatment and wa-ter quality. Lemley et al. (1985) found that a 55 percentrate for understanding led to a 35 percent or greaterrate for acceptance. Therefore, the presently availableevidence suggests that consumer notification programscan successfully meet objectives regarding acceptance ofthe message if levels of receipt, attention and under-standing can be raised. Since public notification willcontinue under the amended SDWA, and since evidenceoffered by Bruvold and Gaston (1982) and by Bruvold etal. (1985) indicates that consumers strongly favor con-


sumer notification, it is worthwhile to consider the im-plications of the research for raising receipt, attention,understanding, and, most importantly, acceptance lev-els, in consumer notification programs in the future.

DISCUSSION AND RECOMMENDATIONS

Reaching The Audience

Many water utilities comply with the notification re-quirements by sending notice of water quality viola-tions with the water bill, or even stamped on the backof it. This is less expensive than separate mailings tothe community and it is within acceptable standards fornotification. However, the billing list is not a completelisting of customers affected by the water quality prob-lem. Many respondents in the second California survey(Bruvold et al., 1985) indicated that they did not receivethe notice, in their opinion, because they did not paytheir own water bill. Most were renters whose landlordsmay have failed to pass on the information to them.This problem would be even more troublesome in com-munities with higher percentages of renters. The factthat such communities might be among the poorestcould raise ethical as well as practical concerns.Families with young children might be disproportion-ately represented among those households overlooked ifbill payers were the primary recipients of violation no-tices. Nitrate contamination is but one example wherethis oversight could prove to be costly.

Respondents in the Bruvold et al. (1985) survey wereasked how to increase the chances for receipt of the no-tice. They frequently mentioned mail addressed to eachdwelling unit rather than to bill payers only. Some sug-gested that the utility should telephone consumers di-rectly when there is a water quality problem, but thatwould not be feasible for any but the smallest of utili-ties. Some respondents felt that there should be greateruse of television announcements to reach more of thepublic.

The emphasis on notification by phone or by televi-sion no doubt reflects public desire for rapid notifica-tion. Although the mail is slower, it is required by theamended SDWA regulations. It can be used effectivelyif proper attention is devoted to developing a thoroughmailing list. Such a list must be available on short no-tice. Therefore it should be drawn up before there is aproblem, and it should be reviewed frequently for accu-racy. SDWA guidelines for thorough, prompt delivery ofviolation notices can be more readily achieved if theutility is prepared in this manner.


Attending to the Message

The key to effective communication is salience andsimplicity. It is important for those who write the re-quired notices to understand that they will be compet-ing with many other issues for public attention.Therefore the odds that such a notice will be an effec-tive form of communication will depend to some extenton its visual appeal. It must appear worthy of attentionto compete with the myriad pieces of information com-ing into the average household in the course of a day.Further, it should be concise enough not to overwhelmall good intentions (Wardlaw, 1986; Abbot, 1988).

Cohen et al. (1985) have suggested that health riskmessages should use a variety of communication meth-ods that vary the timing and the format in order to at-tract attention to the message. The most recent warn-ing labels for cigarette advertising and packaging re-quire that warning messages be altered and rotated ona regular basis to ensure greater visibility of suchwarnings. Perhaps utility operators would be well ad-vised to consider such a strategy when confronted withchronic water quality problems. They might rotate sev-eral notices which vary the wording or at least the styleof presentation. The novelty might increase the chancesthat people would take the time to read the notice.Moreover, revising the notices would be an opportunityfor the utility to present the most recent information tothe community. Updating the notices was among thesuggestions offered by the public to improve the notifi-cation effort (Bruvold et al., 1985).

Understanding the Message

Obviously an attractive message that is not clearlywritten or easily understood will fail to inform the pub-lic. Study results demonstrate that differences in thequality of content can make a significant difference inhow well the public understands the message deliveredby the notices (Wardlaw, 1986). Of the 15 notificationsexamined in depth by Wardlaw (1986), only three werejudged to be informative for overall content. Most no-tices were especially inadequate in explaining the solu-tion for the current water quality problem. In addition,the notice should be as free from technical terminologyas possible so that individuals not familiar with thewater industry will know what it is saying. This doesnot mean that complex problems must be reduced tosimple ones for presentation. Rather the complexitymust be clearly and concisely stated. SDWA notices aresupposed to be informative, but not unduly alarming.Technical jargon can be alarming if it is not translatedfor the average person (Hoffbuhr, 1988).

It might be profitable for utilities to considersubjecting their written notices to formal content anal-ysis. Conveying information clearly, simply and com-pletely is not a matter of chance, but rather the productof the skillful application of tested and proven tech-niques for mass communication. It may be asking toomuch of already overworked utility operators and regu-lators to take on the additional skills required to be"communications experts." The high cost of such con-sultation may discourage some utilities (particularlythe smaller ones), but the long-term savings in goodwill and public cooperation may be worth the invest-ment.

Accepting the Message

A disgruntled water utility customer might concludethat the company was interested in raising rates andwas only sending such notices to scare customers intoagreeing to them. It is possible that the suggestion torotate notices on a regular basis might also increasepublic trust of the utility. If the notices were perceivedas a genuine attempt at communication with the publicrather than a bureaucratic requirement, it might gen-erate more public confidence in those responsible forthe quality and safety of drinking water (Wendell,1988). The multi-faceted responses to a water qualityproblem may not be evident from the pro forma noticessent out month after month. The utilities may be seek-ing additional sources of funding to correct chronicproblems. They may be negotiating with major pol-luters in an effort to eliminate hazards to the watersupply. But little of this will be apparent to the publicunless the utility makes a serious effort to communi-cate such behind-the-scenes information (Wardlaw,1986; Tenny, 1988; Shaw and Herb, 1988).

Specific Recommendations

The Right to Know as a principle has a certain ele-gance and simplicity about it, but there is nothing sim-ple about the kind of effort it takes to translate thisprinciple into practice. Nevertheless it should be possi-ble to ensure greater access to the information requiredto protect public health and ultimately to correct thesource of water quality problems, by adhering to thefollowing recommendations:

1) Distribute written messages to the entire popu-lation served;


Wardlaw and Bruvold

2) Recognize the importance of the appearance ofthe notice and vary its content when repetitionsare necessary;

3) Describe the problem in simple, non-technicallanguage;

4) Describe the nature of the contaminant of con-cern and its related health effects;

5) Describe the nature of the long-term solutionneeded in order to develop necessary public sup-port for funding; and

6) Use the notification process as an opportunity toeducate consumers about broader issues affect-ing the quality of drinking water.

The amended notification requirements represent anexcellent opportunity for the water utilities to strive formeaningful public disclosures that meet not only theletter of the law, but its true spirit as well. Both thepublic and the water industry should profit from suchan effort.

LiTERATURE CITED

Abbot, W.H., 1988. Management Aspects of Public Notification Re-quirements. Journal American Water Works Association, vol. 80,no. 10, pp. 39-41.

Bruvold, W.H. and J.M. Gaston, 1980. Public Notification: Pain orPanacea? Journal American Water Works Association, vol. 72, no.3, pp. 124-127.

Bruvold, W.H., L.A. Wardlaw, and J.M. Gaston, 1985. An Evaluationof Public Notification Requirements in California. JournalAmerican Water Works Association, vol 77, no. 3, pp.40-43.

Cohen, A., M.J. Colligan, and P. Berger, 1985. Psychology in HealthRisk Messages for Workers. Journal of Occupational Medicine, vol27, pp. 543-551.

Douglas, T.J., 1976. Safe Drinking Water Act of 1974: History andCritique. Environmental Affairs, vol. 5, no. 2, pp. 501-543.

Environmental Protection Agency, 1987. Drinking Water Regulations,Public Notification, Final Rule, Federal Register, Vol. 52, no. 208,pp. 4153441550.

Gaston, J.M., 1977. Consumer Notification: Public Awareness or theSmoking Pistol? Journal American Water Works Association, vol69, no. 11, pp. 574-576.

Gray, K.F. and Koorse, S.J., 1988. Enforcement; USEPA Turns Upthe Heat. Journal American Water Works Association, vol. 80, no.1, pp. 4749.

HofThuhr, J.W., 1988. Can Public Notification Work for You? JournalAmerican Water Works Association, vol. 80, no. 10, pp. 37-38.

Lemley, A.T., J. Fessenden-Raden, C.A. Bisogni, and J.M. Holway,1985. Nitrate Contamination: Public Awareness. JournalAmericanWater Works Association, vol. 77, no. 2, pp. 34-39.

Safe Drinking Water Act, 1974. USGPO, Washington, D.C. PL93-523,93rd Congress.

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Documents

EVALUATION OF CONSUMER NOTIFICATION UNDER THE SAFE DRINKING WATER ACT