There are no federal regulations that require testing of drinking water in schools and childcare facilities, except for those that are public water systems and therefore are subject to comply with the National Primary Drinking Water Regulations (NPDWR). States and local jurisdictions may establish their own voluntary or mandatory programs for testing drinking water in schools and child care facilities.
No, states are not federally required to implement a 3Ts program.
Although there is no federal requirement for states or tribes to implement a 3Ts program, many states have provided schools with technical guidance regarding sampling plans, analysis, and support in communicating monitoring results. Some states have also published their own guidance and have enacted laws and/or regulations on the testing and notification of lead sampling in these facilities.
EPA does not typically recommend flushing for the sole purpose of sampling but rather as a routine practice to ensure the water is not becoming stagnant, not moving, in buildings. Flushing before sampling may cause results showing lower than representative lead levels in the water.
The 3Ts provides further clarification on when flushing is appropriate during sampling events, for example when conducting 30 second follow-up flush sampling or sequential sampling to identify potential lead concerns related to building interior plumbing.
See the 3Ts toolkit and the Flushing Best Practices Factsheet for more information, including flushing dos and don’ts.
See the Establishing Routine Practices factsheet of the newly revised 3Ts toolkit to learn ways to improve water quality throughout the year and after long breaks.
A smaller sample (e.g., 250-mL) is used for identifying the sources of lead at an outlet because it is representative of a smaller section of plumbing. For example, a 250-mL sample from a faucet would not include larger portions of the plumbing behind the wall that the faucet is mounted on. Under the Lead and Copper Rule (LCR), public water systems are required to collect a 1-liter sample, which is representative of larger portions of plumbing in the home.
Samples for 3Ts should be collected at locations used for drinking water. This may include water from a fountain, a kitchen sink, or a bathroom sink. EPA recommends prioritizing sampling for lead at potable water sites over non-potable sites (e.g., mop bucket sinks, utility sinks, outdoor hoses, or eye wash stations). If there is potential that these non-potable sites may be used (e.g., the outdoor hoses are used to fill water jugs for sports activities), use clear signage to notify people that the faucet should not be used for drinking or cooking, or include the fixture in your sampling plan.
It is important that water samples be collected properly. Some certified laboratories provide both collection and sample analysis services. If the laboratory is not collecting the sample, be sure to either identify an individual who is adequately trained to collect lead samples or read the sampling instructions on how to collect the sample provided by the laboratory carefully to help avoid sampling errors. Make sure to check the sampling instructions to confirm they are following the 3Ts sampling protocol, as there are different sampling protocols for different contaminants. Many laboratories work regularly with the water systems and are used to sending out kits with instructions for sampling procedures under the Lead and Copper Rule (e.g., 1L sample bottles). Some state drinking water programs or public water systems may provide both services, although there is no federal requirement that they do so.
Collect all water samples before the facility opens and before any water is used. Remember not to use the facilities’ restrooms or sinks that morning prior to sampling.
Unless specifically directed to do so, do not collect samples in the morning after vacations, weekends or holidays because the water will have remained stagnant (not moving) for too long and will not represent the water used for drinking during most of the days of the week.
How frequently your facility can and should test for lead in drinking water depends on a variety of factors (e.g., plumbing, water quality, lead results, budget, and competing priorities). 3Ts does not recommend a set frequency for sampling schools and child care facilities, but does note that annual monitoring provides information regarding changes in the lead levels and the effectiveness of remediation or treatment efforts as well as timely notice of lead levels that need to be addressed.
Regardless of the frequency set by your facility, EPA recommends that the sampling frequency be documented, and that schools and child care facilities make testing drinking water a part of their regular building operations.