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Answer the following questions to determine if sampling
for lead is necessary at your school.
- Does the school supply its own water? (e.g., from a well)
a. Yes. Go to 2.
b. No. Skip
to 7.
- Your school is a non-transient, non-community water system that must
comply with the Lead and Copper Rule under the Safe Drinking Water Act.
Your system collects water quality data as part of its compliance
activities. Look at the most recent lead tests. Were they:
a. Less than or equal to 0.015 mg/L (15 parts per billion)?
Go to 3.
b. Greater than 0.015 mg/L (15 parts per billion)?
Skip to 6.
- Your school’s lead results are lower than the action level set by
the Lead and Copper Rule for the water system as a whole. To confirm
your water is not overly corrosive, look at the most recent tests for
copper, too. Were they:
a. Less than or equal to 1.3 mg/L (1,300 part per billion)?
Go to 4.
b. Greater than 1.3 mg/L (1,300 parts per billion)?
Go to
5.
- Recent tests indicate neither lead nor copper is a problem for the
water system as a whole. Generally, this means the water in the system
is not particularly corrosive. As long as on-going sampling requirements
are met, your water system is in compliance with the Lead and Copper
Rule. Because lead is of particular concern for young children – and
can be a building-specific problem – eliminate the possibility that
individual water taps in your building(s) could have elevated lead
levels.
To rule out localized hot spots, consider limited lead-testing that
focuses on high traffic faucets and fountains used for drinking or
cooking. This type of testing uses a different sample protocol than the
Lead and Copper Rule. Since the water system as a whole is in compliance
with the rule, mark these additional samples with a sampling purpose of
"investigative" so they do not interfere with required testing. Check
with the laboratory doing the analysis to ensure they are documented
correctly.
You have completed the self-assessment. Sampling is recommended. Go
to the Initial sampling protocol for high traffic outlets.
- Copper results greater than 1.3 mg/L indicate the water in your
system is corrosive enough to cause copper or lead to leach from the
plumbing.
The Lead and Copper Rule (LCR) requires
water systems to manage the corrosive nature of the water in their
systems. Your water system must develop a Corrosion Control Plan (CCP).
While the system is working on its CCP, the water is still corrosive and
there may be outlets in your school with elevated lead or copper levels.
Because lead is of particular concern for young children, consider
limited lead testing to rule out the risk of localized hot spots. EPA
recommends a lead level of no more than 0.020 mg/L at individual water
taps.
Limited lead-testing focuses on high traffic faucets and fountains
that may be used for drinking or cooking. Since this type of testing
uses a different sample protocol than the LCR, mark these samples with a
sampling purpose of "investigative." Check with the laboratory doing the
analysis to ensure they are documented correctly, and discuss them with
your water system operator so the results will not interfere with the
system’s corrosion control activities.
You have completed the self-assessment. Sampling
is recommended. Go to the Initial sampling protocol for high
traffic outlets.
Lead concentrations over 0.015 mg/L indicate a potential lead
exposure problem. Generally, this means the water in your system and
buildings is corrosive enough to cause lead to leach from the plumbing
into the water supply. The Lead and Copper Rule (LCR) requires water
systems to manage the corrosive nature of the water in their systems.
Your water system must develop a Corrosion Control Plan (CCP). While the
system is working on its CCP, the water is still corrosive and there may
be outlets in your school with elevated lead or copper levels.
Because lead is of particular concern for young children, conduct
additional sampling for lead at all water outlets that could be used for
drinking or cooking. Since this sampling is not required by the LCR,
mark the samples with a sampling purpose of "investigative." Check with
the laboratory doing the analysis to ensure the samples are documented
correctly, and discuss them with your water system operator so the
results will not interfere with the system’s corrosion control
activities.
You have completed the self-assessment. Sampling
is recommended. Go to the Initial sampling protocol for all drinking
water outlets.
Though there is no requirement to test individual school fountains
and faucets for lead, the federal government passed the 1988 Lead
Contamination Control Act (LCCA) to help schools identify and reduce
lead in drinking water.
The LCCA and the U.S. Environmental
Protection Agency recommend schools test their water for lead. If
testing is done, the LCCA requires schools to make the results available
to the public. The act also identifies plumbing fixtures, coolers and
fountains that contain lead; bans the further use of these fixtures and
recommends their replacement. (See Resources
below).
Has your school ever tested its tap water for lead?
a. Yes. Get a copy of the test results and
go to 8.
b. No. Skip to 16.
How many samples were taken?
a. Few locations were sampled. Go to 16.
b. All or most locations were sampled (including sinks).
Go to 9.
Were samples taken where people typically drink the water?
(Water bubblers, coolers, kitchen faucets, nurse's office sink, etc.)
a. Yes. Go to 10.
b. No.
Skip to 19.
Was sampling done in accordance with guidance from EPA or the Office
of Drinking Water?
a. Yes. Go to 11.
b. No.
Skip to 19.
Were any results greater than 20 parts per billion (0.020 mg/L)?
a. Yes. Go to 13.
b. No. Go to 12.
The data suggests little or no immediate risk of lead exposure from
your building plumbing. However, if the data is not recent, consider
re-sampling because conditions in buildings can change over time.
It
may be useful to consider limited lead testing that focuses on
high traffic faucets and fountains that may be used for drinking or
cooking.
You have completed the self-assessment. Sampling is recommended. Go
to the Initial sampling protocol for high traffic outlets.
Were the samples collected in the last 12 months?
a. Yes. Go to 14.
b. No. Go to 15.
The data indicate you have faucets and fountains that exceed
EPA’s recommended lead level for individual taps. Follow-up samples from
each water outlet that exceeds the EPA level are recommended. EPA
and the Office of Drinking Water (ODW) have developed guidance for
schools on initial and follow-up sampling. (See Resources
below.)
You have completed the self-assessment. Sampling is recommended. Go
to the Initial sampling protocol for all drinking water outlets.
The data indicate you have faucets and fountains that exceed EPA’s
recommended lead level for individual taps. EPA recommends retesting all
taps with initial results greater than 0.020 mg/L. However, since your
samples are more than a year old, consider re-sampling the taps in
excess of the limit as well as other sites before proceeding with
follow-up sampling.
Conditions in the building(s), the quality of the water, and the use
of these sites will change over time. Re-sampling will give you updated
information to use in determining the need for follow-up
monitoring. Since your old samples indicated elevated lead levels,
consider sampling for lead at all the outlets that could be used for
drinking or cooking. Repeat this self-assessment after you have
re-sampled and have the new results.
You have completed the self-assessment. Sampling is recommended. Go
to the Initial sampling protocol for all drinking water outlets.
EPA recommends schools and day care facilities test their drinking
water for lead. You have only limited direct water quality information,
but there are indirect sources of information you can use to determine
the need for lead testing at your school.To get recent water quality information, ask your water system for a
copy of its Consumer Confidence Report and recent sampling
data. The water system can also describe its status under the Lead and
Copper Rule, how it is managing corrosion, and the quality of the water
as it enters your building. It will be important to compare this with
any sample results you collect in your building(s).
Consider the following questions related to your school building(s)
and the water system:
|
School building(s) |
Water system |
| Do any faucets or
fountains get green, orange or brown stains? |
Is the service connector a
lead pipe? |
| Have there been complaints
about taste, odor, or color? |
Does the water have a low
pH? |
| Is there a metallic taste
to the water? |
Did my water system exceed
the action level for lead or copper? |
| Is there lead solder in
the building (common before 1991)? |
Does my water system have
a corrosion control plan? |
| Are any appliances or
mechanical devices grounded to the water supply pipes? |
Do recent sample results
show:
· Cadmium greater than 0.005 mg/L
· Iron greater than 0.3 mg/L
· Manganese greater than 0.05 mg/L
· Zinc greater than 5 mg/L
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a. If you answer yes to any of these questions,
Go to 17.
b. If you answer no to all of these questions,
Go to 18.
-
There is evidence the water in your building may be corrosive. The
combination of water system characteristics and building plumbing
conditions may create lead and other water quality hot spots.
Because lead is of particular concern for young children, you should
sample for lead at all the outlets that could be used for drinking or
cooking.
You have completed the self-assessment. Sampling is recommended. Go
to the Initial sampling protocol for all drinking water outlets.
- Though there are few obvious indications the water is corrosive,
you have very little direct information about the water quality in your
building to use in determining the need for testing. Because lead is
of particular concern for young children – and can be a
building-specific problem – eliminate the possibility that individual
water taps in your building(s) could have elevated lead levels.
To rule out localized lead hot spots, consider limited lead-testing
that focuses on high traffic faucets and fountains that may be used for
drinking or cooking.
You have completed the self-assessment. Sampling is recommended. Go
to the Initial sampling protocol for high traffic outlets.
- Your sampling results may not accurately reflect the risk of
lead from drinking water. Additional samples are recommended from
faucets and fountains used for drinking and cooking, especially if your
students include young children. Prioritize your initial sampling by
focusing on high traffic water taps. By examining those results first,
you can assess the potential for lead hot spots in your school. (See
Resources below.)
You have completed the self-assessment. Sampling is recommended. Go
to the Initial sampling protocol for high traffic outlets.
Resources
3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical
Guidance (816-B-05-008) -- U.S. Environmental Protection Agency, December 2005. EPA
developed the 3Ts (Training, Testing and Telling) to help schools
implement simple strategies for managing the health risks of lead in
schools and drinking water. It is on
EPA's Web
Site.
Testing for lead in school drinking water systems
(PDF 811KB, DOH PUB #331-261)
-- A step-by-step brochure to help you collect initial and follow-up
samples based on EPA's guidance is on the Office of Drinking Water Web
site.
EPA's Web site
has one-stop source of information on drinking water
quality in schools and childcare facilities. It includes technical
guidance and tools, information on laws and rules, and the health
effects of lead exposure.
back to number 7.
back to number 14.
back to number 19.
For more information, call Derrick Dennis, Lead and Copper Program
Manager, at (360) 236-3122 or e-mail
Derrick Dennis.
April 2006
DOH PUB. #331-284
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