New LCR Revisions Push Systems Into Uncharted Waters: School & Childcare Facility Testing

Among all the Lead and Copper Rule Revisions (LCRR) regarding testing, reporting, and reacting to lead levels in drinking water is an entirely new requirement for water testing at K-12 schools and licensed childcare centers in a utility’s service area. Here are some thought-provoking considerations for involved schools and the utilities, government officials, and engineering firms who serve them.

The national publicity generated by the Flint, MI, water crisis in 2014, which focused attention on the risks lead poses for infants, toddlers, and school-age children, eventually caused various cities and school systems to test their own water outlets. Some of the results were startling and triggered closer looks at aging schools in inner-city communities.

Upon the implementation of the LCRR, all community water systems (CWS) will be required to begin testing water outlets in a minimum of 20 percent of the school and childcare facilities within their service area each year. The change in regulations and reporting requirements — not to mention being responsive to local publicity and anxious parents — will represent a major challenge for schools and utilities alike.

The Scope Of The Issue

Until the introduction of the LCRR in October of 2019, the track record for lead-in-drinking-water sampling among U.S. schools (Figure 1) was disconcerting in both the number of schools that avoided testing and the quality of results from those schools that were tested. The aim of the new LCRR requirements is to correct those situations.

Graphic courtesy of 120Water

Figure 1. Historically, lead testing in schools has been a patchwork process. The new requirements of the LCRR now make school and childcare facility testing a priority for all CWS nationwide.

In areas that have mandated school testing programs, some commonalities have emerged:

• Certain Fixtures Show Higher Concerns. Among 13 types of fixtures studied in a project that examined school results in Massachusetts and Indiana, classroom faucets (the most dominant fixture), drinking water fountains (second most dominant fixture), and faucets in home economics classrooms were the most important predictors of elevated lead concentrations. A statewide program in Indiana also found that 60 percent of schools tested had at least one fixture exceeding the 15 µg/L action level.

While the LCRR does not require sampling of every fixture in the schools being tested, school boards might want to do so on their own to ensure that all students and employees are equally protected against potential lead exposure in their drinking water. Since individual school tap testing results do not count toward the 90^th percentile calculation, utilities can encourage schools to be more thorough without impacting their own overall water utility compliance.

• Facility Age Is Not A Reliable Indicator. It is important not to focus exclusively on school construction dates as a factor in selecting which facilities to test. Building age alone is not an important predictor of potential lead problems. As part of the proposed LCR revisions, utilities would be testing all facilities built before 2014 — at a rate of 20 percent per year, for a five-year period.

• Broad Coverage Is A Priority. Lead problems are found in all types of school buildings. Elementary schools and preschool childcare facilities are considered high-profile targets because of the known effects of lead on early childhood development, but utilities would need to test all K-12 and childcare facilities under the new LCRR requirements.

The ABCs Of Managing Lead In Schools

As a water utility or engineering firm serving school districts or childcare facilities, it is important to be prepared for both the testing and the follow-up procedures required to deal with elevated lead levels. This includes being prepared with a program for managing all data related to U.S. EPA compliance and follow-up for the new LCRR, not just testing for the presence of lead in water lines, fixtures, or water fountains.

• Physical Testing. School testing creates an entirely new level of involvement for water utilities, beyond increased LCRR testing, lead service line (LSL) inventories, and LSL replacement efforts among consumer and business accounts. Taking advantage of end-to-end solutions for water-testing kits and tracking/reporting software makes it easier for utility personnel to focus on water quality and for schools to focus on protecting their students.

• Data Management. Using cloud-based data-tracking and management programs developed specifically for school districts makes it easier for school administrators to keep track of testing, remediation, and current status for their own management purposes and to share that data with their water-supply utility.

• Leveraging Existing Data. In states that already have programs parallel to LCRR requirements for detecting and remediating lead in drinking water at schools and childcare centers, data submitted to the state primacy agency can typically be used for utility compliance reporting, too. Checking with the state, school district, or facility for the existence of such data can save utilities the cost and effort of new testing going forward.

• Education. While the proposed LCCR only mandates that 20 percent of schools and childcare facilities be tested per year, it is not necessary for other schools to wait three or four more years to learn more about lead levels in their drinking water. Water utilities can make school districts and childcare facilities not yet scheduled for LCRR-mandated testing aware of this EPA toolkit and of turnkey solutions available to assess, monitor, manage, and provide point-of-use filters for affected schools — by district, by facility, and even by fixture (Figure 2).

Graphic courtesy of 120Water

Figure 2. Cloud-based software designed specifically to help school districts track lead testing results across all schools and all fixtures in a district makes it easier for school leaders to identify and manage the remediation of problem areas.

Make It Easy To Put Remediation Into Action

This case study shows how one school district took advantage of a statewide program through the Indiana Finance Authority to pinpoint specific water fixtures exceeding the action level for lead. Using a complete solution that combined self-administered test kits, mail-in lab samples, and tracking software made it easy to ensure that both water quality and LCRR compliance standards could be met. While not all school buildings were affected and not all fixtures within an affected school building exhibited lead problems, results tracked through cloud-based software helped to target remediation efforts toward the non-compliant fixtures.