Water Testing Requirements for Schools

With national stories about elevated levels of lead in the water supply of Flint, Michigan, which began several years ago, and subsequent news reports regarding possible lead contamination in Texas school districts, district staff have asked TASB, “What are we required to do? How do we know our water is safe?”

Water Testing Requirements

Under the Lead and Copper Rule, a federal regulation, both community water systems (large public water systems that supply water to a consistent population year-round) and non-transient non-community water systems (smaller water systems such as those in public schools that supply water to the same population for at least six months a year) are required to test their drinking water for lead.

At this time, there is no state or federal regulation that requires a school district to sample drinking water unless a school in the district is a public water system. However, with the public becoming more aware of the possibility of lead in drinking water, and with the funding for testing and remediation that is available, additional bills will likely be introduced in the upcoming state legislative sessions.

It is up to an individual school district’s discretion to test district drinking water.

School districts can find information about their community’s drinking water by requesting a Consumer Confidence Report from their water suppliers.

Recent updates to the Lead and Copper Rule mean community public water systems may be required to:

• Provide information about testing for lead and reducing exposure to lead.
• Provide information about health risks of lead.
• Offer to sample for lead at elementary school and childcare facilities constructed prior to Jan. 1, 2014. Secondary schools can be sampled by request.
• Identify service line materials and make the inventory publicly accessible.

Public water systems must comply by Oct. 16, 2024.

Your District’s Responsibility To Test Drinking Water

Water system regulation focuses on identifying systemwide problems and testing only one outlet at each testing location. If one of your schools is a testing location, it is likely that your water supplier is not testing all your outlets. Your water system’s compliance with the Lead and Copper Rule does not indicate a school’s water is lead-free. Lead can leach into water from the service connector, interior plumbing pipes, solder, flux, water fountains, bubblers, and fixtures. Lead sediments can be trapped in aerator screens and build up over time.

If a building was built prior to 1988, lead pipes and lead solder may exist in the facility’s plumbing. The older the building’s interior plumbing and fixtures, the more likely lead contamination exists.

Ultimately, the only way to be certain that lead is not contaminating a water supply is to have it tested by a state-accredited laboratory.

The Dangers of Lead

Lead is a toxic metal once widely used in plumbing components. Exposure to lead can also come from lead-based paint, soil, consumer products, food, and contaminated clothing from workers. Of these, lead-based paint is the most common source of exposure. Children can be exposed through paint chips or dust from renovations.

The U.S. Environmental Protection Agency (EPA) estimates that up to 20% of lead exposure may come from drinking water.

Exposure to lead is especially harmful to children and expectant mothers.

According to the World Health Organization (WHO), there is no known safe level of lead exposure. Lead exposure impacts motor functions, cognitive ability, and organ function. Children and women of childbearing age are at the greatest risk of lead exposure. These populations make up a significant proportion of our school building occupants.

Even lower levels of lead exposure that cause no obvious symptoms can lead to a number of issues. In particular, the WHO indicates that lead can affect children’s brain development, resulting in:

• Reduced intelligence quotient (IQ)
• Reduced attention span
• Increased antisocial behavior
• Reduced educational attainment

Lead exposure also causes:

• Anemia
• Hypertension
• Renal impairment
• Immunotoxicity
• Toxicity to reproductive organs

Even though products containing lead have been phased out of the market through the years, there may still be lead-based paint or lead plumbing components in your schools.

Lead can enter drinking water in numerous ways. Common causes of lead in drinking water include:

• Exposure of pipes and fixtures to corrosion
• Lead present in the existing water supply
• Plumbing materials that contain lead

Pipes and fixtures exposed to corrosive water were the suspected cause of the problems in Flint.

See “Exhibit 1. Potential Sources of Lead in Schools” on page 16 of the EPA’s 3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities for a simplified version of how water is transported from the public water supplier to the consumer.  

The 3Ts of Drinking Water

TASB Facility Services and the Texas Commission for Environmental Quality (TCEQ) recommend that when collecting drinking water samples, one should follow the 3Ts for reducing lead in drinking water set forth by the EPA:

• Training
• Testing
• Taking Action

Training

Training involves teaching district officials about lead’s health effects and causes and the potential for contamination of lead in drinking water. The first step is to assign responsibility to one person or a team who will make sure testing and additional actions are taken as appropriate.

The designated person should assist with identifying potential areas where elevated levels may occur and establish a testing plan. Finding information about the plumbing in a structure can assist with pinpointing potential problem areas.

Testing

Lead contamination may not occur uniformly throughout a building. A testing plan ensures that all areas are assessed. While a license is not required for taking samples of drinking water, a certified laboratory should be used for sample analysis, and a standardized protocol should be followed to lend confidence to the results.

The TCEQ recommends that sampling drinking water for lead should be conducted after at least eight hours but not more than 18 hours of inactivity. Sampling should not be conducted after weekends, after water has been used, or during extended periods of inactivity such as summer, winter, or spring breaks.

Drinking water samples should be taken from every outlet potentially used for water consumption. This includes but is not limited to:

• Drinking fountains or bubblers
• Sinks in lounges, kitchens, and classrooms or restrooms with young children

Lead service connections were sometimes used to connect the school to the water supply. Check with your public water supplier to see if they have any information on lead service lines to your buildings.

Taking Action

There is no known safe level of lead for children. Districts should prioritize remediation efforts based on lead sample results to lower the levels of lead in drinking water to the lowest possible amount.

Following the EPA’s 3T guidance, follow-up actions can be immediate, short term, or permanent solutions. Some possible options for remediation, depending on the source of lead, include:

• Placing fixtures out of service
• Installing water filters
• Flushing regularly
• Replacing fixtures or pipes
• Purchasing potable water

Before conducting sampling, districts will need to have a plan in place to address potential issues with lead in drinking water. Moving quickly to address issues is important to building trust with your communities.

Communication

Sharing information with district staff, parents, and the community is an important component of any lead monitoring program.

Districts should notify students, parents, teachers, and employee organizations of the sample results. Copies of the sampling results should be available in school administrative offices for review by staff, students, and the public.

With an issue as sensitive as lead in drinking water, districts are encouraged to foster trust by making sample results and information readily available to the public. Information may be shared through news releases, letters, fliers, mailbox and paycheck stuffers, staff newsletters, presentations, emails, and website postings.

The content of district communication is important. If detailed information is not included, the public perception of how the district is handling the lead in drinking water program may be negative.

Communications about lead in drinking water typically include the following:

• Details about the drinking water lead control program
• Sampling results
• Plan for correcting identified problems
• Health effects and risks of lead in drinking water (other potential sources of lead and likelihood of exposure through other routes should also be covered)
• General information on lead in drinking water
• How to obtain medical information and how to get blood lead levels tested
• How the public can become aware of exposure risks in their homes and elsewhere

How To Get Help

The TCEQ has a voluntary Lead Testing in School and Child Care Program to assist with sampling drinking water for lead.

This voluntary program offers free training and guidance on how to identify sources of lead in drinking water and how to reduce exposure to lead where children are cared for. The TCEQ offers sampling materials and laboratory testing and can provide help communicating plans and results with the school’s community.

This program can help the district complete the lead testing program. Participants will receive:

• Education about the health effects and sources of lead
• Guidance on how to communicate with their community about the program
• Guidance on selecting testing sites
• Training on how to collect samples and send them to a laboratory for testing
• Recommendations on how to reduce exposure to lead

The TCEQ can help you identify and reduce exposure to lead in drinking water. Reach out today.

Additional information on the 3Ts can be found on the EPA’s website.

School maintenance is an ongoing process — from the day a school opens, until the time that the building is torn down. TASB Facility Services can help you with any questions and provide guidance on record keeping, environmental testing, and facility planning, so you can make sure you meet the proper standards set by state and federal agencies.