.: U.S. Senate Committee on Environment and Public Works

Subcommittee on Fisheries, Wildlife, and Water hearing Oversight of Drinking Water in the District of Columbia

Wednesday, April 7, 2004

Jody Lanard M.D.
Risk Communication Consultant Princeton, NJ

Senator Crapo and Members of the Subcommittee:

Thank you so much for asking me to testify about needed improvements in public communications regarding the detection of lead in Washington D.C. water.

I am Jody Lanard, a psychiatrist from Princeton, New Jersey, specializing for almost twenty years in the rapidly evolving field of risk communication. My own contributions are mostly in the crisis communication branch of the field. I work independently, with my husband Peter Sandman, a former academic who is one of the early founders of risk communication. My biography and c.v. follow the testimony.

Here is a list of the crisis communication strategies which underlie my critique of WASA's communications with the public. Expanded descriptions of these strategies, references to articles from which they were derived, and references to case studies using (or failing to use) these strategies are appended at the end of this statement.

1. Don't over-reassure.

2. Put reassuring information in subordinate clauses.

3. Err on the alarming side.

4. Acknowledge uncertainty.

5 . Share dilemmas.

6 . Acknowledge opinion diversity.

7 . Be willing to speculate.

8. Don't overdiagnose or overplan for panic.

9. Don't aim for zero fear.

10. Don't forget emotions other than fear.

11. Don't ridicule the public's emotions.

12. Legitimize people's fears.

13. Tolerate early over-reactions.

14. Establish your own humanity.

15. Tell people what to expect.

16. Offer people things to do.

17. Let people choose their own actions.

18. Ask more of people.

19. Acknowledge errors, deficiencies, and misbehaviors.

20. Apologize often for errors, deficiencies, and misbehaviors.

21. Be explicit about "anchoring frames."

22. Be explicit about changes in official opinion, prediction, or policy.

23. Don't lie, and don't tell half-truths.

24. Aim for total candor and transparency.

25. Be careful with risk comparisons.

(adapted from Sandman and Lanard's crisis communication articles)

I'm going to tell you about some good and bad risk communication practices, and give you my critique of the D.C. Water and Sewage Authority's public communications. But first, here's my bottom line: for the most part, WASA did fairly typical, rather ordinary, well-intentioned public relations-oriented communication -- as most agencies are inclined to do, despite the fact that it regularly backfires. My colleague Peter Sandman and I like to call this, only half-joking, a "knee-jerk under-reaction," as a way of turning the tables on officials who often feel the public responds to scary new situations with "knee-jerk over-reactions." Sometimes investigation reveals a genuine intentional cover-up, but much more often, the communication strategy is based on false beliefs:

-- about how the public learns new information,

-- about responsible early speculation,

-- about how much anxiety the public can bear,

-- about how reassuring to be in the face of uncertainty.

For instance, WASA's outrage-inducing delay in informing the public was rationalized by WASA officials in at least two conventional ways: the desire to have "complete" information before releasing it, and the desire to prevent public panic. WASA's communication practices are misguided approaches when used in uncertain, potentially scary situations. It is painful to watch agencies walk over the public relations cliff in a crisis communication situation, especially given what other agencies, such as the Centers for Disease Control, have worked so hard to learn and to distill into easily accessible nearly-free training programs.

The U.S. EPA was one of the first agencies to take the new field of risk communication seriously, publishing articles about it when it barely had a name, starting in the mid '80s. And the American Waterworks Association put out a risk communication training video in 1992, entitled "Public Involvement: a Better Response to People's Concerns About Water Quality," subtitled: "an interview with Peter Sandman on how water providers can translate risk communication concepts into mechanisms to build effective relationships with the public." So risk communication is not a new concept in environmental and water management. But each new generation of managers discovers it anew -- often as a result of botching a crisis.

What WASA did was, unfortunately, common every-day bad risk communication. I have had no access to internal agency documents or communications, so if there was deliberate self-serving intent to hide important information from the public, I do not know it. But officials' public comments so far suggest only that WASA was unskilled in the difficult, counter-intuitive strategies of crisis communication -- and despite the ramping up of crisis communication planning and training since September 11, this is extremely common.

Risk Communication

My analysis of WASA's communication rests partly on Sandman's re-definition of risk, drawing on the risk perception work of Slovic, Fischoff, and others, that states: Risk = Hazard + Outrage. This notion was first published in the EPA Journal in 1987. The rest of my analysis is informed by the crisis communication work I and others have done since September 11, 2001.

Health and safety workers usually define risk as "probability times magnitude" -- How bad is the worst case? How likely is it to happen? The public -- including the experts when they are at home -- mostly see "risk" in terms of what Sandman calls "outrage factors", and others more recently call "fear" or "dread" factors: Is this hazard being imposed on me voluntarily? Do I have control over it? Is it industrial, or is it natural? Can I trust the people who are managing the hazard? Have they been open and honest with me? Do they show concern for my worries? Does the hazard effect particularly vulnerable populations, like children? Does it disproportionately fall on oppressed and powerless groups? Is it particularly dreaded, like cancer or AIDS?

On most risks, most of the time, people are apathetic or in denial. That was the starting position of most of the Washington D.C. population about lead, in October 2002 when WASA first widely released information about elevated lead levels in some homes' water. Normally, you can't easily scare people about such hazards as obesity, high blood pressure, not wearing seatbelts, not wearing condoms -- or lead poisoning. So when people suddenly get upset about a risk they have long been ignoring, there are usually new "outrage factors" (or "fear factors") driving the reaction.

The main problems with WASA's communication about lead in the water were: initially, trying to attack apathy with information alone, and without scaring anyone; and later, neglecting public outrage -- especially its outrage at them, the official sponsor of the outrage.

1. Trying to attack apathy with information alone.

Trying to attack apathy -- let me define this as a profound lack of outrage -- with information alone -- especially information that doesn't signal a change in a familiar situation -- is a big reason for communication failure when people are not upset about a potentially serious risk. This is what WASA failed to factor in, in its October 2002 Lead Awareness Week brochure. WASA cites this brochure to demonstrate that it did not try to hide the lead problem from the public -- and technically they didn't hide it. And they did send notices to the actual homes which tested high for lead in the water. But they did not signal that it was a potential problem for the public at large.

WASA's brochure was entitled, "The District of Columbia Water and Sewer Authority and the District of Columbia Department of Health acknowledge National Lead Awareness Week and its impacts on your health. Living Lead-Free in D.C." The explicit purpose of the brochure, based on its title, was to acknowledge National Lead Awareness Week.

This brochure has excellent educational content. But it only weakly signals to the public that there are new reasons to take this information seriously. The title makes it sound like the PR department decided to use "National Lead Awareness Week" as a news peg for sending out information about what to do about lead -- major lead sources like paint and dust; less significant sources like lead in the water. Pretty picture of water on the cover. A smiling pregnant woman holding a glass of water on page 2. Low down on page three comes this sentence: "However, in the annual monitoring period ending June 30, 2002, the lead results indicate that although most homes have very low levels of lead in their drinking water, some homes in the community have lead levels above the EPA action level of 15 parts per billion."

By the time a reader gets to this sentence, the context of the brochure suggests that "some homes" are very few, and "above the EPA action level" is only a little above. The cheerful, informative tone of the preceding pages, in context with the celebratory title of the brochure, does not signal, "DO something! This is a surprising change in our findings! Take this seriously!"

The next mention of the actual water problem is at the bottom of page 7: "Despite our best efforts mentioned earlier to control water corrosivity and remove lead from the water supply, lead levels in some homes or buildings can be high." CAN be high? Didn't they know? How many homes or buildings so far? HOW high? You cannot tell from the brochure. But on January 31, the Washington Post reported that "some homes" meant 4075 homes, and "how high?" -- 2287 homes were above 50 parts per billion, way over the EPA action level. A much scarier way for the public to find this out. Yes, public anxiety would have increased at any point that they heard about this, and public anger too; but WASA lost the opportunity to help the public cope with its anxiety, and WASA generated much more anger, by letting the story break unexpectedly. Feeling blindsided gets translated into a belief that the hazard is much more serious: this is a very robust finding in risk communication research.

I can understand WASA's reluctance to lay out this information explicitly early on. On March 2, The Washington Times wrote that WASA General Manager Jerry Johnson "wanted more comprehensive analysis of the test data before unnecessarily alarming the public." Well, they still don't know the full extent of the problem. They still do not know if many people, especially, children, have been affected. They wouldn't even get much of a hint until March 30, when the CDC published a small amount of mostly reassuring data. It's hard to tell people bad news, and then add, "Not only that, but we don't know how bad, and we don't know what it means, or what to do!"

But an official at WASA trained in crisis communication could have shared the anguish of this uncertainty with the public: "I'm so sorry to tell you that we're finding a lot of unexpected high lead levels in water coming out of the taps in lots of homes. We don't know yet why this is happening. We don't know yet whether any people, especially children, have increased blood lead levels because of this. We don't even know all the recommendations we want to make to you, because we feel you deserve to know this information quickly, so we'll just give you some preliminary precautionary recommendations. We'll be learning things over the next weeks that we'll wish we had known months ago. We may make mistakes, or retract things we've already said, or change our minds as new information and guidance come in. But we're committed to sharing this with you early. We know you'll be worried; we share that worry; and we will bear this together and get through it."

This would have expressed confidence in the public -- a compliment the public might well have returned, along with its appropriate anger at you, and its anxiety. You can't skip the part where they are angry at you, you can only manage it better. But telling the public you don't think they can handle bad news -- "we didn't want to panic people" -- is insulting, patronizing, and it generates mistrust.

The third mention of an actual problem is on page 10. "WASA's recent Lead and Copper Program hosted 53 volunteers who have single-family residences that are served by either lead services, internal lead plumbing or copper pipes with lead solder installed after 1982. During WASA's last sampling program in the summer of 2001 and June 2002, some of these homes tested above 15 ppb. In the District of Columbia, there are approximately 130,000 water service lines and 20,000 of these are lead services."

As an imaginary recipient of this brochure, I react to this thinking: "Well, if they knew this in the summer of 2001 and in June of 2002, and they are only telling me now in the context of acknowledging National Lead Awareness Issue, and they are not mentioning how elevated the levels were, this must be not be very important new information."

You cannot tell if officials are even a little worried about a developing situation. I'd love to know data about how many people responded to this brochure by testing their water, or testing their houses for lead, or screening their children. It was a very good brochure in terms of what to do if you are worried about lead, which many people should be. It just didn't give readers a new reason to do it, if they were not worried about lead to start with.

In my Mandarin Chinese classes at Princeton University, we learned a little word that you put at the end of a sentence to signal, "New situation! Not business as usual!" The word is "le." There is no "le" in the brochure. Terrific information. Lots of action people can and should take. But no alarm bells, just business as usual.

2. Neglecting public outrage -- especially outrage at "you", the official sponsor of the outrage.

Neglecting or disparaging the public's outrage is one of the main problems in poor risk communication when people are already angry or upset.

By February 5, WASA and other officials were sounding defensive -- the beginning of their own knee-jerk reaction to the public's outcry over the story. Spokesman Johnnie Hemphill insisted, "We certainly didn't do anything to hide this information....we have done everything we were supposed to, from beginning to end...It's clearly a challenge for WASA and homeowners, but it isn't a crisis."

Not recognizing and acknowledging that this was indeed a crisis -- a crisis of public confidence and fear -- was insulting to the public. Not as bad as "There's no need to panic," but still disrespectful. Hemphill was leaning on the technical side of hazard versus outrage -- the actual effort to assess and mitigate the lead hazard. If the October brochure suggested that WASA did not know how to send a signal to apathetic people that a new problem had arisen, WASA statements after January 31 revealed that they didn't know how to listen or talk to angry people either.

Since I have watched many good officials do this wrong and then learn, I am probably more sympathetic to how hard it is, how counter-intuitive it is, to engage in compassionate, responsive, human crisis communication when people are attacking you! You feel like a good person, engaged in thankless tasks with inadequate resources; you feel like you've been trying to get people to take lead seriously forever and suddenly they are accusing you of not taking it seriously! And you get defensive. (I just illustrated a risk communication strategy called "telling people stories about themselves," very useful when trying to get through to angry worried people.) Hemphill's reactions are as natural as the public's reactions. I hope I can help some of the people who are angry at WASA to understand this, just as I hope I can help WASA see that they genuinely did a lot of communication things wrong, and made public outrage and fear much worse than it could have been, and that there are learnable strategies for doing it better.

On February 13, in a letter to its customers, WASA General Manager Jerry Johnson sounded like he was minimizing the extent of the potential problem: "There are about 130,000 water service pipes in the District....The vast majority of those are not lead service pipes. Our initial efforts are concentrating on the relatively small percentage of our customers served by lead service lines....23,000 homes..." That's about 18% of the homes. I'm sure that doesn't sound relatively small to WASA when they try to figure out a budget for mitigating all those lead service lines, and it doesn't sound relatively small to the public when they live in a neighborhood served by lots of these lines. So Johnson sounds defensive, like he's minimizing the problem. In a world where we don't want a single child to be damaged by lead, it sounds callous and uncaring to refer to 23,000 homes as "a relatively small percentage." I will bet that Jerry Johnson is not actually callous and uncaring, but in his defensive posture, he sounded that way.

In the same letter, Jerry Johnson says that the houses served by lead service lines "may have increased levels of lead in their tap water." He certainly must mean that all of those houses are at risk -- which is the right message. But he still isn't saying how many houses he already knows have elevated lead in the water. And in the next paragraph he discusses how in spring and summer of 2002, "samples indicated that some households experienced increased lead levels above the [EPA] 'action level' ." The indefinite words -- "may have," "some households," "increased lead levels" -- all sound evasive, and are likely to evoke both alarm about the extent of the exposure, and anger about an attempt to minimize it. Can you imagine the U.S. Postal Service saying, "Out of the billions and billions of letters mailed every day, we have found 'some letters' which contain anthrax spores'"? Or the U.S. CDC saying, "We have found 'some patients' with SARS"? The crisis -- not the hazard crisis, but the outrage crisis, the crisis in confidence -- was in full swing by February 13, and WASA was still doing mostly public relations, trying to reassure.

We have come up with a concept called the Risk Communication Seesaw. If you -- the official -- sit on the over-reassuring, minimizing side of the seesaw, I -- the public or your critics -- will heavily sit on the alarming side. If you sit more toward the fulcrum, and share some of my fears, and validate my anger, and openly acknowledge the worrisome news while also giving me information that is hopeful or reassuring, I will put it in perspective better, I will feel less patronized, I will bear my worries better, and paradoxically I will blame you less -- after I get through telling you how angry I am! You can't skip that step with the public.

Now I heard that WASA held a lot of public hearings where they let people yell at them. This is excellent crisis management. But most of the quotes I've read of officials responding at those meetings sound defensive, bureaucratic, and technocratic. The public gave you outrage and you gave them back hazard. I'm not saying to respond only to the outrage -- you have to address the hazard, but you are in no danger of forgetting to do that. But bend over backwards to acnowledge and validate people's feelings, show some of your own anguish, express your wishes that you had responded differently, express your regrets, express your hopes about managing the problem, ask people even more for their ideas and for their help, tell them stories about what other members of the public have told you (and I do not mean complimentary stories) -- these are all ways officials can let the public feel they have been heard and even understood. Learn how to apologize -- "I'm so sorry we didn't break this story months ago, so people would have been spared months of drinking so much leaded water. I'm so sorry we tried to deal with this ourselves instead of involving the public early, so people could take their own precautions sooner."

Using good risk communication, Johnson could have written to his customers: "I have been appalled for months that about 4000 houses - out of about 6000 tested -- had elevated lead in their water. That's about 66%! We can only guess that about the same percentage of the rest of the houses served by lead service lines may have elevated levels too. Even though most of districts homes are not served by lead lines, there are 23,000 homes I am worried about until we find out if they have elevated lead too. I wish I could tell you not to worry while I work on this problem. But it's your drinking water, and of course you have a right to be worried."

Two other examples of neglecting outrage:

On February 19, WASA posted an alert on its website entitled, "Lead Service Line Flushing Clarification," outlining a change in previous guidelines for how long to let taps run before drinking the water. The recommendation increased in an alarming direction -- from "one or two minutes" to "10 minutes to protect against high levels of lead in drinking water." Why the first recommendation was now seen to be inadequate is not clear; issues on this recommendation between WASA and EPA are not clear; but they are not my focus when reading this "clarification."

The word "clarification" is odd: the previous recommendation was clear, and the new recommendation is equally clear. The new recommendation isn't a clarification, it is a change. A revision. The old recommendation may or may not have been an error. The new recommendation may be based on evolving knowledge, or a re-thinking of old knowledge. But a clarification it isn't. Tell us what it is!

This alert notice let people know that the precautions they thought were adequate for quite a while had not been adequate, and therefore they had been exposing themselves to more hazard than they thought. This is upsetting! WASA's alert, while clearly for the purpose of telling people the new recommendation, could have added a couple lines of regret that the new recommendation hadn't been made sooner, and an acknowledgment that it is frustrating and upsetting for people to find that their precautions had been inadequate.

Dr. Vicki Freimuth, who was director of communications for the CDC during the anthrax attacks and the SARS outbreak, describes how during anthrax, evolving knowledge was perceived as mistakes -- and that this was largely because of failure to acknowledge uncertainty all along. Several important risk communication strategies to reduce public alarm in response to changing information are:

-- use anticipatory guidance: warn people that information and recommendations are likely to change as we learn more, or have more time to analyze what we already know, or consult with more experts; warn people (regretfully!) that some of what we know will turn out wrong.

-- acknowledge uncertainty all along.

-- show your own humanity: express the wish that you knew more, and that you didn't have to put the public through anxiety-provoking changes. While some of these techniques can raise anxiety at first, they also let you share the public's worry, and help them bear it, rather than trying to squelch the public's worries and leaving them alone with their fears.

MY last example of WASA ignoring public outrage and fear comes from a statement by Glenn S. Gerstell, Board Chairman of WASA, on about February 27. In this statement, Gerstell says he is "pleased" that nearly 99% of school water samples are below the EPA action level, and he is "pleased" that WASA has caught up with its backlog of voicemails. "Pleased" is a PR kind of word. I'd vote for "relieved." This is a minor quibble, but I use it to illustrate that PR and crisis communication are different. Gerstell also wrote that he and other top officials "have conducted numerous media interviews to communicate facts and findings as we get them." Separate from my comment that the "facts" very often did not include numbers of houses affected, or degree of lead elevation, I want to point out that this view of communication -- communicating facts to the public -- is probably less than half of good crisis communication. Listening to the public, acknowledging human feelings -- your own and the public's -- is a very large part of what makes crisis communication work when people are angry and afraid.

3. Some examples of spectacular risk communication from other crises.

WASA General Manager Jerry Johnson has been quoted as saying he believes in using "facts to overcome fears" to educate the public. I hope I can convince him to use even the scary-sounding facts, and to go beyond the facts and help people bear their fears. It is part of the job, as Mayor Guiliani demonstrated so magnificently on September 11, and as superb risk communicators in public health do.

Here are some examples of very good risk communication, which illustrate validating public emotion, acknowledging uncertainty, using anticipatory guidance, showing your own humanity, and not prematurely over-reassuring people.

In June 2003, North Carolina had its only confirmed SARS patient. State Epidemiologist Jeff Engel responded with a series of news conferences. At one of them, a reporter asked if all the news coverage had the potential to cause more hysteria and fear. Dr. Engel replied: "We need to involve our community in all aspects of public health. Certainly a disease like SARS, so new, so frightening, should instill fear. Fear is an appropriate response ‹ for me as a public health physician, for everyone in the community. We need to transfer that fear into positive energy, and keep the facts out in front of hysteria.... I think [the media's] response is appropriate. This is a new disease, it spreads person to person, it can kill, it has a high case-fatality rate. That is newsworthy!"

Two months later, Dr. Engel made essentially the same empathic statement about Eastern Equine Encephalitis (EEE). Here he is in the August 24, 2003 Fayetteville Observer:

Dr. Jeff Engel, a state epidemiologist with Health and Human Services, said the state has documented "only 12 or 13 human infections since 1964." The most in one year was three in 1989....

Though human infections are rare, Engel emphasized precautions.

"Fear is appropriate. I mean, my God, here you have a mosquito that can kill," Engel said. "What we are trying to do through you guys, the media, is use that fear in a positive way. We are trying to get information out there."

The local Wal-Mart sold out of insect repellant after the EEE news conference. Dr. Engel generated preparedness, not panic.

On March 14, 2003, two days after the World Health Organisation issued a rare global alert, WHO spokesman Dick Thompson said: "With relatively few SARS deaths, one might think we are overreacting but when you don't know the cause, when it strikes hospital staff, and moves at jet speed... until we can get a grip on it, I don't see how it will slow down... It's highly contagious. It's bad."

And one of the best risk communicators I know, CDC Director Dr. Julie Gerberding, often acknowledges uncertainty, and balances reassuring information with caution, by putting the reassurance in a subordinate clause. This shows what we mean by balancing on the fulcrum of the risk communication seesaw.

Early in the SARS outbreaks Dr. Gerberding was asked if SARS could be bioterrorism. She answered, "While we have lots of reasons to think that the SARS outbreaks are not due to terrorism, we're keeping an open mind and being vigilant." Other officials said only the first half: "There is no evidence of a terrorist attack." Dr. Gerberding's version is paradoxically more reassuring; we know she is still looking, just in case.

Later in the SARS outbreak, Dr. Gerberding reassured us and cautioned us at the same time, saying, "Although we haven't seen community transmission of SARS, we're not out of the woods yet."

Sometimes, when people hear my examples, or my re-writes of what I think officials should have said, they ask me, "Well, aren't some people just naturally inclined to do crisis communication well? Is it really something you can learn and practice?" I usually answer by telling them my favorite Julie Gerberding story:

One day during SARS, there had been a really weird newspaper article quoting an astrobiologist from Wales that SARS and other viruses might come from outer space, on meteor dust. (It had to be a very quiet day on the SARS front when newspapers had space for this strange notion.) At a CDC telebriefing, CNN's Miriam Falco said, "Dr. G., I just have to ask you about this outer space thing. What do you think?" Dr. G. answered, with a wicked twinkle in her eyes, "Although we have no evidence that SARS is from outer space, we're keeping an open mind." The reporters in the room roared with laughter -- in recognition of her signature way of acknowledging uncertainty and not over-reassuring.

Crisis communication is hard, but learn-able. As a field, it is a moving target; we are learning and trying out new strategies all the time, and seeing what works -- and what doesn't work. I'm not sure if WASA officials can learn it, but I am hopeful they can. Some of what I recommend may backfire on you too -- and I will feel terrible when that happens. Some of it may turn out wrong. I wish I knew everything there was to know about crisis communication, and I wish it was easier to learn.

So even though WASA officials think they are doing good communication, I hope they will be keeping an open mind as they consider other ways. And even though many in the public think that WASA did egregious communication (the closest I come to agreeing with that is the delay in informing the general public), I think WASA mostly did ordinary conventional "bad" risk communication. And this applies to me too: Even though I think WASA's communication mistakes are pretty run-of-the-mill, I will be keeping an open mind as I learn more about how they actually managed the lead crisis.

Thank you

Jody Lanard, M.D. - Bio and Curriculum Vitae

Jody Lanard M.D., a psychiatrist, is a risk communication consultant and writer who increasingly specializes in public health crisis communication since 9/11. She has worked with the Federal Emergency Management Agency's Northern Virginia Community Resilience Project, and has spoken at homeland security, science communication, bioterrorism, and environmental public health tracking conferences in the U.S. and Europe. Since the 2003 SARS outbreaks began, Dr. Lanard has been advising the World Health Organization on communicating with the public during disease outbreaks. Dr. Lanard has worked on a wide range of risk communication issues with her husband and colleague, Peter Sandman, for almost twenty years.

Email: jody@psandman.com

Website: The Peter Sandman Risk Communication
Website http://www.psandman.com

Address: 59 Ridgeview Road, Princeton, NJ 08540 USA

Phone: 1-609-683-1158

Date and Place of Birth: May 7, 1951,
Philadelphia, USA

Professional Experience:

1975-1976: Research Assistant, Neurobiology and Behavior, Langmuir Lab, Cornell University

1984-1999: Behavioral pediatrics and psychiatry practice

1990-1997: Staff psychiatrist, Boston University Student Health Services

1985-2004: Risk communication and crisis communication work with Peter Sandman and others (research, consulting, training, writing).

Education and training:

1975: B.A., Hampshire College

1980: M.D., University of Pennsylvania

1980-2: Pediatric residency, Sinai Hospital, Baltimore

1982-3: Chief resident in pediatrics, St. Agnes Hospital, Baltimore

1983-4: Adolescent psychiatry fellowship, Boston University

1985-9: Psychiatry residency, Cambridge Hospital/Harvard Medical School

1989-90: Dupont-Warren Fellow in Psychiatric Research, Harvard Medical School