Editor’s note: While the presence of lead in drinking water is not a new phenomenon, there is a renewed focus on this problem. In 2015, it was disclosed that the drinking water in Flint, Michigan was contaminated with lead, while in New Jersey the discovery of high lead levels in some Newark public schools, as well as in schools in other districts, served as a wake-up call on the dangers of an aging infrastructure. On July 13, the New Jersey Department of Educated enacted new regulations requiring schools to test all water outlets for lead. Here, an expert from the New Jersey Department of Environmental Protection (NJDEP) answers questions about lead in drinking water and the regulations.
Where is lead usually found, anyway?
Lead is a common metal found in the environment. The main sources of lead exposure in people are lead-based paint and lead-contaminated dust or soil. In addition, lead can be found in certain types of pottery, pewter, brass fixtures, food, and cosmetics. Lead can also be found in drinking water. Other sources include exposure in the work place and exposure from certain hobbies.
Lead seldom occurs naturally in water supplies like rivers and lakes. Lead enters drinking water primarily as a result of the corrosion, or wearing away, of materials containing lead in the water distribution system and/or in household plumbing. These materials include lead-based solder used to join copper pipe, lead in brass and chrome-brass faucets as well as in fittings and valves, and in some cases, in pipes made of lead that connect houses and buildings to water mains or service lines.
When water stands for several hours or more in lead pipes or in plumbing fixtures that contain lead, the lead may dissolve into drinking water. As a result, the first water drawn from the tap in the morning, or later in the afternoon if the water has not been used all day, may contain elevated levels of lead.
Why are we hearing about this now? What laws or regulations are in effect to reduce lead exposure from drinking water?
Lead in drinking water has been in the news recently due to events that occurred in Flint, Michigan. However, lead in drinking water is not a new topic. In 1986, the federal government required the use of “lead-free” materials in new plumbing and in repairs.
In 1988, the U.S. Congress passed the Lead Contamination Control Act (LCCA), which aimed to identify and reduce lead in drinking water at schools and child care facilities by banning certain water coolers and establishing testing protocols for schools. However, until the recent adoption of new rules by the New Jersey State Board of Education, there was no regulation requiring schools in New Jersey to sample for lead in drinking water.
In 1991, the United States Environmental Protection Agency published the Lead and Copper Rule which requires public water systems to monitor for lead at customers’ taps. The Lead and Copper Rule is a regulation aimed at minimizing the corrosivity of the source water to minimize the leaching of lead and copper from customers’ plumbing.
How dangerous is lead in drinking water?
Lead can cause serious health problems if too much enters the body, including long-term developmental problems in children. For additional information on the health effects of lead in childhood please refer to the New Jersey Department of Health’s website.
Why might a school have lead in its water?
Lead is unusual among drinking water contaminants in that it seldom occurs naturally in water. Lead enters drinking water primarily as a result of the corrosion, or wearing away, of materials containing lead in the fixtures, plumbing and service line. Even though a public water supplier may deliver water that meets all federal and state public health standards for lead, there may be lead in the drinking water because of the plumbing in the facility.
Brass faucets, fittings, and valves that were made prior to Jan. 4, 2014 including those advertised as “lead-free,” may contribute lead to drinking water. Federal law currently requires end-use brass fixtures, such as faucets, to be at least 99.75 percent lead-free to be labeled as such. However, prior to Jan. 4, 2014, a fixture could have as much as 8 percent lead content and still be labeled “lead free.” Consumers should be aware of this when choosing fixtures and take appropriate precautions.
Don’t water companies and municipalities have responsibility for this?
Under the federal Lead and Copper Rule, public water systems are responsible for sampling for lead periodically at representative sites throughout their system. If more than 10 percent of the results find lead present in the water above 15 parts per billion, the water system is required to pursue appropriate treatment to reduce lead levels below the Action Level of 15 ppb and to conduct public education. The vast majority of the state’s public water systems do not have elevated levels of lead in their water. Since January 2015, only 8 of 587 community water systems exceeded the permissible levels of lead. Of almost 300 schools and childcare facilities served by their own well (known as nontransient noncommunity water systems), only 13 exceeded the lead action level during this same time period. All of these water systems are required by regulations to take steps to remediate the problem and conduct ongoing public education.
What are New Jersey’s requirements for lead testing of the water at schools? Must all water be tested or just drinking water?
As of July 13, 2016, public school districts, charter schools, renaissance schools, jointure commissions, educational services commissions, approved private schools for students with disabilities acting under contract to provide educational services on behalf of New Jersey public school districts, as well as certain state-funded early childcare facilities and receiving schools have one year to test all drinking water outlets, which are water outlets where water can be consumed or used for food preparation. This includes drinking water fountains, water coolers, ice machines, kitchens faucets, cafeteria taps, food preparation sinks, teacher lounge sinks, nurse’s office sinks, and sinks with a bubbler. Water outlets that do not provide drinking water (such as custodian’s sinks or showers) do not have to be tested.
General provisions on the regulation can be found here.
Who does the testing and how much does testing typically cost a school district?
The school district has the option of collecting the samples itself or of hiring a New Jersey-certified laboratory or other third party to collect the samples in accordance with the school district’s Lead Sampling Plan and Quality Assurance Project Plan. A New Jersey-certified laboratory must analyze the samples. The cost of sampling will vary between laboratories, and will depend on the number of schools, the number of sampled drinking water outlets, and who conducts the sampling.
A list of New Jersey Certified Drinking Water Laboratories may be found here.
Technical Guidance may be found on the DEP webpage.
How is water tested for lead?
Schools should test all drinking water outlets, which are water outlets where water can be consumed or used for food preparation. Samples collected must be analyzed by a New Jersey-certified laboratory using an EPA-approved method. The EPA recommends that a two-step sampling process be followed for identifying lead contamination. Lead in a water sample taken from an outlet can originate from the outlet fixture (e.g. the faucet, bubbler etc.), the plumbing upstream of the outlet fixture (e.g. pipe, joints, valves, fittings etc.), or it can already be in the water that is entering the facility. The two-step sampling process – which involves sampling both “first draw” water, and then water from an outlet where the water has run for at least 30 seconds – helps identify the actual source(s) of lead.
What is the standard for lead in a drinking water outlet and how are the test results interpreted?
The certified laboratory will provide a copy of the lead results to the school district in an Excel spreadsheet format. A copy of the Excel spreadsheet is available on DEP’s website and should be included in a school district’s Quality Assurance Program Plan. All results must be reported in micrograms per liter (µg/l), which is more commonly referred to as parts per billion (ppb). The school district will be responsible for determining if any of the results are greater than the lead action level established by EPA, which is currently 15 ppb.
If a school is found to have high lead levels in water, what steps must a school district take? Any suggestions for best practices in communicating with the public on lead in school drinking water?
Within 24 hours after the board of education has reviewed and verified the laboratory results, the district board must make the results publicly available at the school facility and on the district’s website, regardless of whether the results are elevated. For any result that exceeds the lead Action Level of 15 parts per billion, written notification must be promptly provided to the New Jersey Department of Education as well as the parents/guardians of all students attending that facility. The notification shall include health effects related to elevated levels of lead and a description of the measures taken to immediately end use of each water outlet that exceeds the action level, along with measures taken to remediate the outlet and/or ensure alternate drinking water availability.
NJDEP’s Division of Water Supply & Geoscience provides template letters for schools to use for communicating with the school community.
What steps must a school district take to eliminate the exposure of students, faculty, and staff to water that is found to have high lead levels? The school district is required to take measures to immediately end the use of each drinking water outlet (turn it off or restrict access) where water quality exceeds the permissible lead action level. This should include providing alternate drinking water to all students, faculty, and staff members if necessary. If sinks used for hand washing are found to have elevated lead levels, signs should be prominently posted warning against drinking that water. Lead is not absorbed through the skin by hand washing or showering.
Additional remediation is not required by the regulations; however, schools are recommended to refer to EPA’s 3Ts Guidance for additional information on remedial options.
If there are high lead levels in a school’s water, should individual students be tested?
Parents and guardians should contact their local health department or health care provider if they are concerned about lead exposure to discuss whether their child’s blood should be tested.
Is state or federal funding available to help with the costs of testing of drinking water and remediation?
Yes. The New Jersey Department of Education will be offering a reimbursement application on its website offering reimbursement to school districts. For questions, contact the New Jersey Office of the State Board of Education at (609) 984-6024.
How often must schools re-test for lead in the water?
Within six years following the initial testing and every six years thereafter, each district must test all drinking water outlets in accordance with its Lead Sampling Plan and Quality Assurance Program Plan. Sampling shall be prioritized so that buildings and facilities that previously had outlets with results above the Action Level of 15 parts per billion or identified in the plumbing profile as high risk for lead are sampled first.
All boards of education must also sample for lead after the replacement of any drinking water outlet or any other alteration to plumbing or service lines that may impact lead levels at the outlet.
Is lead a problem in schools in other ways? Lead paint dust, for example?
For general information regarding where lead can be present in school and at home visit the EPA website.
Are there steps that schools should recommend to parents if tests show high lead levels in a school?
Schools are required to notify parents or guardians if levels of lead above the federal Action Level of 15 parts per billion are found through water testing. Included in that notice must be a description of measures taken to ensure that alternate drinking water has been made available to all students and staff members. Parents and guardians can contact their local health department or health care provider for further information about the health effects of lead.