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Investigative Sampling for Lead in Drinking Water

man holding sampling bottle next to school drinking water bottle filling stations
Environment, Great Lakes, and Energy

Investigative Sampling for Lead in Drinking Water

Schools and child care facilities either get their source of water from a community water supplier or they produce their own water on site. Schools and child care facilities that have their own water source must follow the Michigan Safe Drinking Water Act, 1976 PA 399, as amended (Act 399), Lead and Copper Rule requirements for lead and copper sampling.

Schools and child care facilities that get water from a community water supplier should voluntarily take steps to test and reduce the risk of lead in drinking water using guidance from the United States Food and Drug Administration (FDA) and EGLE.

There is no known safe level of lead exposure for children. EGLE recommends that action is taken to reduce the risk of lead in water at all fixtures with test results greater than 5 parts per billion (ppb) and encourages schools and childcare facilities to reduce lead levels to the lowest possible amounts.

The potential for lead to be released into water increases the longer the water remains in contact with leaded plumbing materials and, as a result, facilities with intermittent water use patterns, such as schools, are more likely to have elevated lead levels in drinking water.

The occurrence and rate of lead release into drinking water depends on:

  • How corrosive the water is (corrosivity is a function of water quality and can be measured through pH, alkalinity, conductivity, etc.)
  • The type of plumbing materials in the building (leaded solder, lead pipes, brass valves, etc.)
  • The age of plumbing materials (pipes pre-1989 and fixtures pre-2014)
  • How long water sits in pipes and fixtures (weekends, vacation breaks, and low usage taps)
  • If solid pieces of pipe scale containing lead (particulate lead) are knocked loose or disturbed, very high lead results can occur
two lead sampling bottles

Investigative Sampling for Lead

A plan for investigative sampling for lead should be made with the goal of sampling all fixtures where water is used for drinking or food preparation.

Schools and child care facilities that get water from community water supplies and nontransient noncommunity facilities can conduct investigative sampling for lead in drinking water.

The risk of lead in drinking water may still exist even if the building does not have a lead service line or lead solder because lead is still allowed in small amounts (up to 0.25 percent) in brass valves, “lead-free” fixtures, and other plumbing components.

Lead may be found in the plumbing system building-wide, or just at a single fixture – you will not know unless every fixture is tested. Lead release can be variable. An initial test at a fixture may show no lead but if the conditions are right (i.e. excessive stagnation or particulate release), another sample taken at the same fixture later may show elevated results. Do not include fixtures that are not used for consumptive purposes (e.g., hand wash, janitor, lab faucets, etc.) in the sampling plan; however, clear signage should be used at these locations to notify people that it is not for drinking.

bottles of samples in trunk of car

How frequently your facility can and should test for lead in drinking water is dependent on a variety of factors (e.g., plumbing, water quality, lead results, budget, and competing priorities). Schools and childcare facilities should make drinking water testing a part of their regular building operations. Annual monitoring is suggested as it provides information on changes in the lead levels and the effectiveness of remediation or treatment efforts.

Lead sampling priorities:

  • Buildings with the highest risk population (ages six and under)
  • Fixtures used by children under the age of six or pregnant women
  • Schools or childcare facilities built before 1989
  • Fixtures that are older and/or have never been tested
  • Fixtures frequently used by students and staff
8 happy school children

Guidance for Lead Reduction in Schools and Child Care Facilities

Michigan uses the United States Environmental Protection Agency (EPA) 3Ts  For Reducing Lead in Drinking Water in Schools and Child Care Facilities manual as a model for creating a program, testing for lead, communicating the results, and taking remediation actions where needed.

Additional EGLE guidance documents and information are also available for download.

Visit the EPA's 3Ts for Reducing Lead in Drinking Water for detailed information and to download:

In general, there are ten steps to take for lead reduction in school and child care drinking water outlined the 10 Steps to School & Child Care Water Testing.

EGLE recommends that all fixtures used for consumption are sampled and tested for lead, however, a school or childcare facility conducting investigative lead sampling may decide to prioritize the sampling effort if resources are limited. If this is the case, prioritization should be made at buildings with the highest risk for lead release and those with the youngest children.

Follow up samples should be taken after all remediation efforts are completed to ensure low lead results before a fixture is put back into service.

water drop with sign that reads, "Do Not Drink from this Sink" and "Water Testing in Progress"
two lead sampling bottles
water fountain and bottle filler with fixture identification code
cardboard box cooler with drinking water samples inside
examples of EGLE drinking water lab results
person reviewing a fixture plan
example of lab test results for drinking water
outside of a school
two lead sampling bottles

Testing Follow Up

There are things that must be done to make sure actions taken to reduce lead and improve water quality have been and continue to be successful:

  • Collect follow up samples after all remediation efforts to ensure no to low lead results before a fixture is put back into service
  • Update documents and records
  • Provide parent and staff outreach
  • Provide proper maintenance on filtration devices
  • Conduct routine sampling on a regular basis to ensure water quality