The Pennsylvania School Code was amended July 1, 2018 to require schools to test drinking water sources for lead, or, discuss and decide options at a public meeting[1]. Childhood lead poison prevention is a serious issue in the Commonwealth, and one that can be positively affected by providing safe drinking water in schools.
This guidance document summarizes recommendations for testing and management of lead in drinking water to both meet compliance with regulatory obligations and best management practices. The recommendations outlined in this document have been developed with national consensus standards, including those developed by the U.S. Environmental Protection Agency (EPA)[2] and the PA Advisory Committee on Lead Exposure.
PROGRAM DEVELOPMENT:
Developing a written program is an important first step in identifying and controlling potential lead in drinking water issues. This program should address:
- Roles & Responsibilities
- Reviewing program effectiveness
- Awareness training for building staff
- Establishment of sampling strategy
- Informing parents and staff of results
- Recordkeeping
- Preventative maintenance on the system
SAMPLING STRATEGY:
When developing a sampling strategy, the EPA recommends the following steps:
- Obtain and review building information
- Map potable water supply system components
- Identify sources of drinking water
- Visually inspect the system to identify indicators of concern
The above steps are further outlined in Figure 1.
Figure 1: Developing a Sampling Strategy
SAMPLING PROCESS:
WHEN TO TEST:
- The EPA recommends that samples are collected after a stagnation period of 8-18 hours, often referred to as a “first draw” sample.
- A second sample may be collected after a 30-second flush of the outlet. This sample is typically only collected/analyzed if the first draw sample is elevated.
MATERIALS:
- Collection bottle (250-mL supplied by the laboratory)
- Markers/pens, sample bottle labels
- Sample log and lab chain of custody form; floor plan
- Gloves (nitrile, latex, rubber, etc.)
- Cooler
HOW TO SAMPLE:
- Start at the location closest to the service connection and progress away
- Record location, time, outlet identifiers (sinks/fountain; location)
- Don gloves
- Carefully start flow and fill collection bottle, take precaution to not overfill
- NOTE: Do not remove aerators, screens or filters prior to sampling
- If taking a post flush sample, allow the water to flow at a constant rate for at least 30 seconds.
- Label bottle and place in cooler
- Complete the chain of custody
- Deliver samples to the lab within predetermined hold times
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IMPORTANT Only use a laboratory accredited by the PA Department of Environmental Protection. A list of accredited labs can be found at:
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INTERPRETING RESULTS and RESPONSE ACTIONS:
The PA School Code Amendment identifies a maximum contaminant level of 15 parts per billion (ppb). If any result exceeds this level, the school must report it to the Department of Education and immediately implement a plan to ensure that no further exposure occurs. Response actions may include:
- Restricting the use of sources with elevated lead levels.
- Providing an alternate source of drinking water.
- System maintenance, such as cleaning, aerator replacement, etc.
- Replacement of the source or sources.
- Replacement of leaded plumbing materials with certified lead-free materials.
- Implementing a flush schedule.
- Point-of-use treatment, such as filtration.
[1] Act 14 of 1949: The Pennsylvania School Code: Section 742: Lead Testing: Harrisburg, PA; Updated July 1, 2018.
[2] The U.S. Environmental Protection Agency, Office of Water: 3Ts for Reducing Lead in Drinking Water; EPA-815-F-18-014; October 2018.