Lead in Drinking Water:
What you need to know
While federal regulations aimed at minimizing lead in public water systems have been in place for over 25 years, the issue of lead in drinking water has been brought to the forefront in recent years. In 2016, New York became one of the first states to mandate testing for lead in drinking water in public school buildings. LaBella assisted some of the first districts to be affected by the new rules.
What's the Problem?
Here are some of the key issues schools need to know in communicating with their constituents:
The US EPA and CDC indicate there is no safe level of lead to consume.
Young children (under age 6), are among those most affected by lead poisoning.
Lead poisoning is a chronic issue – lead can be stored for up to 10 years in our bodies – so even after the contamination source is removed, it can still affect our health.
In residences, the highest risk of lead exposure in water comes from service lines, pipes that run from the water main to the building. However, schools typically use more water than service lines made of lead were sized to provide. Therefore, school service lines are more likely to be made from other materials, and lead contamination more often comes from other sources, such as fixtures and interior plumbing.
What's the Latest?
All public schools in New York State, including all districts and BOCES, were required to complete a first round of testing by the end of 2016. Results of this testing must be reported by December 31, 2019 through the statewide electronic health reporting system. Any remediation performed as a result of this testing must also be reported and the public notified. Furthermore, outlets associated with new construction or renovation must be tested prior to being made available for use.
The next round of lead testing must be completed between January 1 and December 31, 2020. All water outlets used for drinking and cooking must be tested. Testing is required on all outlets regardless of when they were installed.
The next round of lead testing must be completed between January 1st and December 31st, 2020.
What Regulations Apply?
Regulatory testing protocols are laid out in 10 NYCRR Subpart 67-4 Lead Testing in School Drinking Water.
If a sample result exceeds 15 parts per billion, further action is required per regulations.
Some schools may also be subject to the Lead and Copper Rule under the federal Safe Drinking Water Act, and will need to comply with additional US Environmental Protection Agency testing requirements.
How is Water Sampled?
All outlets that supply water used for drinking or cooking, like drinking fountains and kitchen sinks, will need to be tested. The protocol will be the same that was used during the initial round of testing in 2016 – that is, “first draw” samples from each outlet will be collected into a wide-mouth 250 mL bottle for lab testing.
The premise of the sampling protocol is to replicate the likely worst case under NORMAL conditions. Water must sit stagnant between 8 and 18 hours before sampling. This typically means the building has to be vacant prior to and during sampling. Therefore, planning and scheduling is key.
While sampling itself is straightforward, errors in following the protocol can lead to invalid data and the need to repeat the process. We strongly advise getting an expert on board to review the proposed testing program early to avoid costly mistakes and quickly address any elevated results.
It is important to note that care should be taken when comparing results between residential and school tests. The sampling procedures may be different and represent different purposes.
What Happens if Elevated Concentrations of Lead are Found?
In short, it depends. We have found that the majority of issues in schools are associated with older fixtures, such as faucets and drinking fountains. Up until 2014, brass fixtures were allowed to contain up to 8% lead by weight. That standard has since changed to less than 0.25%.
Your environmental engineer can help identify potential sources of lead contamination and recommend options for remediation. Remedial options depend on the source of contamination and may include replacement of fixtures or piping, point-of-use filtration systems, or anti-corrosion systems.
Most schools have found that replacing fixtures with products compliant with the new lead rules is most effective. However, there are no guarantees, and follow-up testing is always required. In some cases, problematic outlets may have to be permanently isolated, and other sources of drinking water provided.