Free Monthly Webinar Series:Challenges and Treatment Solutions for Small Drinking Water SystemsHosted by EPA’s Office of Research and Development (ORD) and Office of Water (OW)Schedule & Recordings: epa.gov/water-research/small-systems-monthly-webinar-series

TODAY’S TOPIC:

Lead in Schools andSelecting Lead FreePlumbing Products

November 28, 2017, 2:00-3:00 pm ET (Optional Q&A session from 3:00-3:30)

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DisclaimerThe information in this first presentation has been reviewed and approved for public dissemination in

accordance with U.S. Environmental Protection Agency (EPA). The views expressed in this presentation are

those of the author(s) and do not necessarily represent the views or policies of the Agency.

Any mention of trade names or commercial products does not constitute EPA endorsement or

recommendation for use. 3

Presentation 1: EPA’s Office of Water

Presented by Victoria Banks | Contact: banks.victoria@epa.gov Victoria is a physical scientist in the Drinking Water Protection Division of EPA’s Office of Ground Water and Drinking Water. She’s been with EPA since January of 2015, and works on projects related to the implementation of the Radionuclides Rule, the Lead and Copper Rule and drinking water in schools. Prior to joining the EPA, she was an O.R.I.S.E. participant at the National Center for Environmental Health at the Centers for Disease Control and Prevention. Victoria holds an Environmental Health degree from East Carolina University.

Children are particularly vulnerable to lead exposures and spend a significant portion of their day in schools. This underscores the importance of establishing proactive, voluntary testing and remediation programs in schools. The 3Ts for Reducing Lead in Drinking Water in Schools was developed using a training, testing and telling approach to assist schools in implementing such a program. This webinar will provide background on lead in drinking water and discuss recommended steps for ensuring effective school sampling, remediation and communication measures.

Testing Drinking Water in Schools and Reducing Lead Levels

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Overview of Presentation

• Information about lead – Health Effects of Lead– Sources of Lead– Lead in Drinking Water

• EPA’s Lead and Copper Rule

• Lead in Drinking Water in Schools

• 3Ts for Reducing Lead in Drinking Water in Schools

• Existing Resources

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Information about Lead• Lead is a toxic metal that affects multiple body

systems, particularly the nervous system.

• Lead enters the body primarily through inhalation and ingestion.

• Once lead enters the body, it is distributed to the brain, liver, kidney and bones. It is stored in the teeth and bones, where it accumulates over time.

• The human body cannot tell the difference between lead and calcium (a mineral that strengthens bones).

• Pregnant women and their developing fetus, infants, and young children are most vulnerable to the effects of lead.

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Health Effects of Lead: For Children

• Reduced IQ and Attention Span

• Learning Disabilities

• Poor Classroom Performance

• Hyperactivity

• Behavioral Problems

• Impaired Growth

• Hearing Loss

September 2016 U.S. Environmental Protection Agency

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Sources of Lead in the Environment

Lead-based paint In the air In the soil

Lead Industry In consumer products and food

In water

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• Children in schools and child care centers may be exposed through water they drink or food that has been prepared with contaminated water.

• Did You Know: Formula fed infants can receive up to 60 percent of their exposure to lead from lead in drinking water.

• Lead in drinking water has no taste, scent or color.

• Boiling water will not get rid of lead.

Lead in Drinking Water

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Lead in Drinking Water: Source Water• Lead can enter drinking water by being present in the source water.• Lead can enter source water from contaminated runoff or water pollution.

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Lead in Drinking Water: PlumbingLead can enter drinking water through an interaction between the water and plumbing materials containing lead, such as through corrosion.

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Factors That Can Influence Corrosion• “Soft” water • Acidic (low pH) water• Water velocity • Temperature • Alkalinity• Chlorine levels • Grounding of electrical wiring to

water pipes• Age and condition of plumbing • Amount of time water is in contact

with plumbing

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How Lead in Drinking Water is Regulated• Lead Ban (1986):

– requires only “lead-free” materials be used in new plumbing and in plumbing repairs.

• Lead Contamination Control Act (1988): – The LCCA is aimed at the identification and reduction of lead in drinking water at schools and

child care facilities. It banned lead-lined water coolers and required guidance. Implementation and enforcement of the testing portion of the LCCA has been at each state’s discretion..

• Lead and Copper Rule (1991): – A regulation by EPA to minimize the corrosivity and amount of lead and copper in water

supplied by public water systems.

• Reduction of Lead in Drinking Water Act (2011): – further reduces the amount of lead in plumbing and identifies lead-free

certification marks on plumbing product.s(https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100GRDZ.txt).

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Lead in School Drinking Water: Public Water Supply

September 2016

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Lead in School Drinking Water: Interior Plumbing

September 2016 U.S. Environmental Protection Agency

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3T’s for Reducing Lead in Drinking Water in Schools

September 2016

TRAINING

TESTING

TELLING

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Steps to Developing and Implementing a 3Ts Program

September 2016

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TRAININGWhat You Should Know about Lead in Drinking Water • Health Effects of Lead• Sources of Lead • How Lead Gets into Drinking Water • How Lead in Drinking Water is Regulated

Planning Your Program and Establishing Partnerships• Assigning Roles• School Records• Establishing Partnerships

– Your Public Water Supplier – Your Local Health Office– Your State Drinking Water Program – Certified Laboratories – Local Community Organizations

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Planning A Program

Some Roles to Consider• Testing• Follow-up• Contact person• Budget coordinator• Communication

Assigning Roles

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• Review records

• Complete Plumbing Profile Questionnaire

• If records are sparse, contact earlier personnel

Planning A ProgramSchool Records

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Establishing PartnershipsPublic Water Suppliers

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Establishing PartnershipsLocal Health Office

Helpful for establishing contacts through programs the local health office may already have in place.

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Establishing PartnershipsState Drinking Water Programs

MA

RICT

WA

OR

CA

ID

MT

WY

ND

SD

MN

IA

WI

MI

IL INOHNV

AZ NM

TX

OK

UT

NE

KSCO

KY

TN

PA

NY

MO

AR

AK LA

ALMS GA

FL

SC

NC

VAWV

VT

NH

ME

NJ

DEMD

DC

HI

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Establishing Partnerships

• Get list of labs from state drinking water office

• Use only state or EPA certified labs

• Costs vary, consult multiple labs

Certified Laboratories

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Establishing Partnerships

The region’s PEHSU may be able to provide risk communication support to school districts; for more information please visit: http://www.aoec.org/PEHSU.org

Local Community Organizations

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Some Examples:• Volunteer groups• Senior citizen groups• Parent & Teacher Associations• Local environmental groups

TESTING

• Assessment & Strategy• Conducting Sampling• Remediation

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Assessment & Strategy• Review available records

• Develop a plumbing profile

• Conduct a Pre-Sampling Inspection of your building(s)– Understand how water enters and flows in your building(s)

– Identify your building(s) plumbing products

– Check for recalled water coolers (EPA810/F-90-21)

– Identify and prioritize sampling sites. Map and code each outlet.

– Record observations (i.e., leaks, corrosion, particles on screens, locations of where electrical wires are grounded to water pipes, etc.)

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Developing a Sampling Plan

EPA recommends the following sites as priority sample sites:

– Drinking fountains (both bubbler and water cooler style) – Kitchen sinks – Classroom combination sinks and drinking fountains – Home economics room sinks – Teachers’ lounge sinks– Nurse’s office sinks – Sinks in special education classrooms – Any other sink known to be or visibly used for

consumption (e.g., coffeemaker or cups are nearby)

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Overview of Sampling Protocol• The 3Ts recommends a 2-Step sampling

process to identify whether lead is an issue at the school and to pinpoint potential lead sources (i.e. the fixture of interior plumbing).

• The Testing section includes information on how to take samples, how to interpret the results, and how to choose appropriate remediation measures.

• The guidance also discusses other parameters (i.e. copper and bacteria), and how to take additional interior plumbing samples.

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Public Water System Testing vs. Testing at Schools

Lead and Copper Rule (LCR) 3Ts for Reducing Lead in Drinking Water in Schools

Required for: all community and non-transient non community water systems

Voluntary Program: to assist schools with training, testing, and telling

Sample Volume: 1 L Sample Volume: 250 mLAction Level: 15 µg/l Action Level: 20 µg/lFollow Up Actions: If more than 10% of the samples exceeds the action level, water systems are required to undertake actions including optimizing corrosion control treatment.

Follow Up Actions: If the initial sample at any one outlet is above the action level, follow-up flush testing is recommended at thatoutlet to determine the source of the lead, and then determine remediation.

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Conducting Sampling• Ensure outlets are inactive for at least eight hours prior to

testing, but not more than 18 hours.

• The 2-Step Sampling Process:

– Step 1: Collect 250 mL samples from water outlets to determine lead occurrence

– Step 2: Collect follow-up flush samples from outlets identified as problem locations from Step 1

– Compare sample results to determine sources of lead contamination and appropriate corrective measures

• Send samples to a certified laboratory.

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Immediate Responses

If results identify outlets with high lead levels,

– turn off outlets with high lead results and prioritize remediation;

– publically post test results;

– notify staff, parents, and students of high lead levels and identify activities you are pursuing to correct any lead levels found.

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Remediation

Routine Control Measures

Interim Control Measures

Permanent Remedies

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Remediation: Routine Control Measures

• Clean debris from screens (aerators) frequently

• Thoroughly flush holding tanks to remove sediment

• Use only cold water for food and beverage preparation

• Maintain drinking water filters

• Post “Do Not Use Water” signs

• Know your plumbing products

• Keep up to date with plumbing standards (Consult NSF: www.nsf.org)

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Remediation: Short-Term Actions

• “Flush” the piping system in your building

• Provide bottled water (The FDA ensures the quality and safety of bottled water)

• Shut off problem outlets

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Remediation: Permanent Remedies• Remove or replace water outlets

• Install point-of-use filters that control lead at the tap– Consult NSF (www.nsf.org).

• Check grounding wires

• Lead pipe replacement

• Reconfigure plumbing

• Automatic flushing

• Use lead free materials– See EPA’s guide to identifying lead free:

https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100GRDZ.txt

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Follow-Up Testing

Once remediation measures are taken, the school should conduct post-remediation sampling to ensure that levels have been reduced and that remediation activities have been successful.

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Recordkeeping is important before, during, and following any testing that is conducted. Ensure your school does the following:

– Documents methodologies, procedures, and best practices that were used to plan for testing.

– Maintains information about the laboratories and/or professionals and their procedures.

– Memorializes any plans instituted in the process (e.g., flushing plans, maintenance plans or schedules, etc.).

Recordkeeping

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TELLINGCommunicating & Public Notification

September 2016

• Communication Strategy

• Paper & Electronic Notifications

• In-Person Education

• Recordkeeping

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Communication Strategy• The purpose of a communication strategy is to provide the

means for delivering ongoing, up-to-date information regarding your sampling efforts.

• Communications should take the following into consideration:

– Method of communicating

– Audience

– Timing

– Content

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Paper & Electronic Notifications

• Examples of paper communications to the public:– Press Releases– Letters/Fliers– Mailbox or Paycheck Stuffers– Staff Newsletters

• Examples of electronic communications to the public:– Email and websites– Social media

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In-Person EducationExamples of in-person public education:

– Presentations– Open Houses– Posters and information tables

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Recordkeeping

Maintain an ongoing record of public outreach and communication activities.

– Enables complete transparency.

– Provides documentation that steps were taken to inform the public on lead issues.

– Aids in keeping the state in the loop as to the steps a school has taken to notify the public.

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EPA ResourcesDrinking Water in Schools and Childcare Facilities

https://www.epa.gov/dwreginfo/lead-drinking-water-schools-and-childcare-facilities44

EPA ResourcesBest Practices for Schools

Best Practices for Schools Being Serviced by a Municipal Water System https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100HGM8.txt

Best Practices for Schools That Own There Own Well https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100GOT8.txt

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Additional Resources• Drinking Water in Schools and Child Care Facilities

https://www.epa.gov/dwreginfo/lead-drinking-water-schools-and-childcare-facilities

• 3Ts for Reducing Lead in Drinking Water in Schoolshttps://www.epa.gov/dwreginfo/3ts-reducing-lead-drinking-water-schools-and-child-care-facilities

• EPA’s School Homepagewww.epa.gov/schools

• Basic Information about Lead in Drinking Waterhttps://www.epa.gov/ground-water-and-drinking-water/basic-information-about-lead-drinking-water

• Lead and Copper Rule Pagehttps://www.epa.gov/dwreginfo/lead-and-copper-rule

• Schools and Early Childhood Education Facilitieshttps://www.wkkf.org/resource-directory/resource/2016/02/managing-lead-in-drinking-water-at-schools-and-early-childhood-education-facilities

• Contact Information for Certification Programs and Certified Laboratories https://www.epa.gov/dwlabcert/contact-information-certification-programs-and-certified-laboratories-drinking-water

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Presentation 2: EPA’s Office of Research and

Development

Although there is no mandatory federal requirement for lead free product testing or third-party certification under the Safe Drinking Water Act (SDWA) as of November 2017, consumers can increase their level of confidence by purchasing products that have been certified as meeting the SDWA lead free requirement. Because there is not a single, uniform mark for identifying certification to lead content, it can be difficult to determine if a product is lead free. This presentation highlights a tool designed to help consumers identify lead free plumbing and water system products that have undergone third-party certification testing.

Identifying Plumbing Products that are Certified as Lead Free

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Presented by Michelle Latham | Contact: latham.michelle@epa.gov Michelle is a biologist with EPA ORD’s Safe and Sustainable Water Resources Research Program, where she manages the program’s research outputs and has served as the technical communications and outreach lead since 2014. From 2008-2014, Michelle served as the technical communications lead for the Water Supply and Water Resources Division of ORD’s National Risk Management Research Laboratory. A large portion of her efforts at EPA have focused on drinking water, particularly small systems. Michelle co-leads this small systems webinar series, is on the planning and implementation committee for the annual EPA small systems workshop, and leads a small systems communications workgroup with states.

She also serves as a stakeholder advisory board member for the University of Cincinnati’s Community Outreach and Engagement Core. Michelle has a B.L.A., a B.S. in Biology, and a M.Ed. from Xavier University, an A.A.S. from Shoreline, and a C.G. in medical laboratory technology from the Naval School of Health Sciences.

Although the SWDA does not currently include a federal requirement for certification of products, there may be state or local laws or certain entities that do.

Lead Free Requirement Revision to Section 1417 of SDWA

January 4, 2014: Requirement went into effectChanges the definition of “lead-free” in the SDWA by reducing allowed lead content of not more than 8%, to a weighted average of not more than 0.25% when used with respect to the wetted surfaces of pipes, pipe fittings, plumbing fittings, and fixtures.

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Driver for Tool Development

• States, utilities, consultants, etc. found it difficult to offer guidance on how to easily identify lead free products.

• Small systems wanted to be able to advise consumers on what replacement devices to buy.

• Small system may have been stocked with an inventory of undesirable product.

• Retailers may be unaware of the lead content of products on shelves, therefore not able to answer consumer questions.

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Issues with Identification of Lead Free Products

• There is not a universally used lead free mark

• Some manufacturers have their own marks/logos

• Eight ANSI accredited third-party certification bodies, each with their own certification mark

• Fraudulent use of certification marks

Although it is not required by the SDWA, consumers can increase their level of confidence by purchasing products that have been certified to the new lead free requirement. 50

Certification Bodies & their Marks

• Eight ANSI accredited third-party certification bodies provide product certification to the SDWA lead free requirement.

• The certification bodies’ have different approved certification marks and required identifier text.

• Marks with indicator text indicate that a pipe, pipe fitting, plumbing fitting, or plumbing fixture meets the lead free requirement of Section 1417 of the SDWA.

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Lead Free Test Standards

NSF 372Indicates certification to new lead free requirement.

NSF 61Establishing leach test performance requirements for inline and endpoint devices. Updates to NSF 61 may include NSF 372 test method. Unknown how this will effect certification labeling.

NSF 61-Annex GAnnex G is was retired from NSF 61 in late 2013. Although it was retired, products bearing NSF 61-G certification marks will continue to indicate compliance with both NSF 61 and NSF 372.

AB 1953 (2006) or AB 1953 (2006) California HB AB1953, Section 116875 or CA HSC §116875, indicates certification to new lead free requirement

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http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100LVYK.txt

Tool Available on EPA’s Website

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Although the tool was designed with system operators as the target audience, it can easily be used by others:

Tool Design and Use

• Building and plumbing contractors• Schools and daycares• Military bases and other federal buildings• Retailers needing to review and stock inventory• Homeowners replacing faucets

…Just about anyone

How can it be used:— Downloaded to a smartphone or tablet— Printed as a whole document or individual pages

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Identifier text next to mark

NSF 372 with certification mark on packaging

Examples of certification marks indicating compliance with the lead free requirement

Certificationmark

Identifier text under mark

Certificationmark

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NSF 61-G with certification marks on products

Identifier text in a box under mark

Identifier text under mark

Examples of certification marks indicating compliance with the lead free requirement

Engraved certification mark

Certification mark

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NSF 61-G with certification mark on packaging

Identifier text to right of certification mark

Examples of certification marks indicating compliance with the lead free requirement

Certification mark

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NSF 61 with CA Code AB1953 identifier text under certification mark

Examples of certification marks indicating compliance with the lead free requirement

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No certification mark or identifier text on tag or packaging

This does not necessarily mean that the product does not meet the SDWA lead free requirement. Contacting the manufacturer is the best way to confirm the lead content.

Examples of products with no certification marks for the lead-free requirement

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• Similar tool is being developed for household water filters (point of use devices).

• Will be used to identify filters that have been certified to remove lead.

• Will include NSF/ANSI 53 and NSF/ANSI 42.

New Tool under Development

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Questions?

ContactsEdward Viveiros, viveiros.edward@epa.govVictoria Banks, banks.victoria@epa.govMichelle Latham, latham.michelle@epa.gov

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