Is School Water Safe to Drink?
The reality is that lead in school drinking water continues to be a serious concern, with children in many schools potentially drinking water with dangerous levels of lead. Even when water entering a facility meets all federal and state public health standards for lead concentrations, older plumbing materials found in schools can contribute to elevated lead levels in the drinking water. The health effects of lead exposure are especially dangerous in children, with both the EPA and CDC agreeing that there is no known safe level of lead in children. Additionally, a large portion of school staff tend to be women, who risk transferring lead to their babies during pregnancy and nursing.
Another factor increasing the risk of lead in school drinking water is intermittent water use patterns (e.g., weekends and breaks when water sits unused), which increases the potential for lead to leach into water the longer the water remains in contact with leaded plumbing materials.
So, is school water safe to drink? The disturbing answer is that many schools likely have elevated levels of lead but are unaware because they have not tested for it. In 2017, the Government Accountability Office conducted a survey of public school districts in the U.S. The survey found that approximately half of the schools had not tested for lead, but of those that had, over a third found elevated levels of lead.
Lead in Drinking Water Limits – What is the Allowable Lead in Drinking Water?
Currently, the EPA has an enforceable lead standard of 15 parts per billion (ppb) for water systems, which was originally established by the Lead and Copper Rule (LCR). However, the EPA itself states that 15 ppb is not a health-based standard, but rather based on what is feasible for water systems to achieve. The federal standard is viewed by public health experts to be well above levels that are considered protective of health. In other words, the current level of allowable lead in drinking water is not safe. On top of that, this standard does not guarantee lead levels at the tap– even if water provided by the water system meets the standard, once the water enters the home or school, levels of lead in the water can increase significantly due to lead plumbing within the property.
There are several health-based recommendations for lead in drinking water limits from public health agencies that are substantially lower than the 15 ppb legally allowed. The FDA’s standard for lead in bottled water is 5 ppb, the American Academy of Pediatrics recommends a limit of 1 ppb for lead in drinking water, and the California OEHHA has a Public Health Goal (PHG) of 0.2 ppb. The EPA itself has a goal of 0 ppb (Maximum Contaminant Level Goal), as there is no level of lead that has been determined to be safe.
Current Regulations on Lead Testing in Schools
No federal law currently requires testing for lead in school drinking water despite EPA recommending testing be done. While some states have required lead testing in schools, testing programs have often been limited.
From 2017 to 2019, under AB746, California required community water systems that serve schoolsites to test for lead in K-12 schools. The program required the testing of only 5 fixtures, with the requirement of remediation if lead levels were over 15 parts per billion (ppb). (If you recall, this limit is the same as the federal standard, which is well above levels that are considered protective of health.) As limited as this testing was, it uncovered elevated levels of lead in many schools— 19% had at least one tested fixture above 5 ppb, and 5% of schools had at least one tested fixture above 15 ppb.
More recently, California’s AB2370 required licensed childcare centers built before 2010 to test their drinking water for lead by the end of 2022. Although both programs arose from California state regulations, there were key differences between the childcare and K-12 school lead testing programs. For instance, the childcare testing program’s lead action level was set at 5 ppb, which is a third of the previous school testing program’s action level of 15 ppb. Not only was the school program’s lead action level far less protective from a public health perspective, but its requirement to test only five fixtures in the whole school also fell short. In contrast, the childcare program required testing of all drinking water fixtures. With one fixture unable to represent all others, this requirement is considered a best practice by the EPA. Finally, the school program was a one-time test, whereas the testing in childcare centers is required to be done every 5 years; a sensible measure because lead levels may change over time and, therefore, should be monitored periodically.
Results of AB2370 testing in 6,866 childcare centers in California revealed elevated levels of lead in drinking water at numerous childcare centers in California, with exceedances of the 5 ppb Action Level found in at least one fixture at 1,690 locations (roughly one in four sites). Levels of lead were found at up to 11,300 parts per billion. Results of the childcare testing also highlighted the weaknesses in the K-12 school testing program—due to the more rigorous childcare testing requirements, elevated lead problems were sometimes flagged at childcare centers that were located within schools that likely had similar lead issues but “passed” the school testing program. Regardless of regulatory requirements, the only way to ensure that a lead problem is not present is to test all drinking water outlets and conduct remediation at a sensible action level, such as 5 ppb or lower.
Upcoming Regulations on Lead Testing in Schools
Regulations are slowly in the process of catching up to best practices. The federal EPA is currently revising its Lead and Copper Rule, which will propose to include, for the first time on a federal level, mandatory testing of lead in schools and childcare facilities. While this is a step in the right direction, these requirements are limited. Under the updated rule, water systems would be required to do a one-time test of only five drinking water outlets at every elementary school and only two outlets at every childcare center, testing 20% of all school and childcare sites each year over 5 years. There is also expected to be no requirement for remediation based on the results.
In California, a major legislative development is the recently introduced Assembly Bill 249, which would require testing for lead in schools and childcare centers and would close the major gaps in the state’s previous school testing program. For example, all fixtures that are used for consumption would have to be tested, remediation would be required at a lower action level of 5 ppb, and testing would be required every 5 years instead of just one time. It would also require notifying parents of students in schools where lead levels were found to be high. The initial testing would be conducted by local water utilities, and at least some funding for remediation would be paid for by the state.
Best Practices for Reducing Lead in School Drinking Water
With forthcoming regulations and increased attention on the issue, schools should be prepared to address water quality to ensure the safety of their students and staff. Lead remains a real hazard, and schools can expect Action Levels to continue to lower as the U.S. works towards the public health goal of getting to zero lead exposure. Already, there are school districts that are leading the way with more aggressive and proactive lead programs that incorporate regular testing for lead, action levels of 5 ppb or even 1 ppb, and in some cases installing permanent water filters at all drinking water outlets.
Schools should familiarize themselves with best practice recommendations on how to address lead in drinking water. The EPA recommends that schools and childcare facilities have a program in place for reducing lead in drinking water, which includes establishing routine practices to manage water quality, such as cleaning of fixture aerators and drinking fountain screens, flushing outlets after periods of no water use, routinely testing each drinking water outlet, taking corrective actions at a sensible Action Level (such as 5 ppb or lower), and considering permanent filtration. FACS can support schools by assisting with the development of their lead water program as well as sampling efforts, remediation recommendations, and communication. For help, call FACS at (888) 711-9998.