Lead Sample Collection Field Guide for Schools and Child Care Facilities

Disclaimer

This guide is a product of the voluntary program of the U.S. Environmental Protection Agency

(EPA) 3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities - Training,

Testing, and Taking Action Approach.

EPA's 3Ts program is not a federal requirement under the National Primary Drinking Water

Regulations. Therefore, this guide is not intended for use by public water systems that are

subject to compliance under the Lead and Copper Rule Revisions or other National Primary

Drinking Water Regulations under the Safe Drinking Water Act (SDWA).

The 3Ts program approach is voluntary and provides tools and informational materials for

schools, child care facilities, states, territories, and Native American Tribes to implement lead

testing programs in drinking water, at their discretion.

This document does contain overviews of federal regulatory requirements concerning lead in

drinking water that apply to public water systems. EPA has made every effort to ensure the

accuracy of the discussion in this guidance. In the event of a conflict between the discussion in

this document and any statute or regulation, this document would not be controlling.

The general description in this document does not substitute for any law or regulation. Many

states (or tribes) and localities have different, more stringent requirements than EPA’s, some of

which may apply to schools and child care facilities even if they are not a public water system.

Therefore, schools and child care facilities should not rely solely on this guidance for that

compliance information.

This document does not impose legally binding requirements on EPA, states, or the regulated

community.

This document does not confer legal rights or impose legal obligations upon any member of the

public.

Office of Water (4606M)

EPA 816-F-22-009

July 2022

i

chk with Ying]

Purpose

The purpose of this Lead Sample Collection Field Guide is to provide clear

instructions to designated personnel on how to effectively and accurately

collect samples to test for lead in drinking water in schools and child care

facilities.

This Guide is a product of the voluntary program of the U.S.

Environmental Protection Agency (EPA)

3Ts for Reducing Lead in Drinking Water in Schools and Child

Care Facilities - Training, Testing, and Taking Action Approach (referred to as “3Ts program”

hereafter).

Before collecting samples, go to Module 3: Planning your 3Ts Program to

establish a plan for:

(1) Communicating (e.g., methods and frequency to communicate

results and actions to parents and staff);

(2) Training (e.g., who an

d how personnel will be trained);

(3) Testing (e.g., prio

ritize outlets for sampling and identify the type of

lead samples to collect); and

(4) Taking Acti

on (e.g., identify the type of short-term and/or long-term

measures to take if l

ead is detected).

Transparency and communication are key to developing a successful

program for reducing lead in drinking water in schools and child care

facilities. Use the 3Ts p

rogram resources

, including step-by-step instructions

and interactive tools, to cr

eate your plan.

Funding for Reducing Lead in

Schools and Child Cares

Schools and child care facilities

may be eligible for funds to

conduct lead testing and

remediation through the Water

Infrastructure Improvements for

the Nation (WIIN) Act grant

program. Contact your state

program listed here:

WIIN 2107:

Lead

Testing in

School and

Child

Care Program

Drinking Water

State

Grant Program

Contacts.

Connection to US EPA Drinking Water Regulation --

Lead and Copper Rule Revisions

The Lead and Copper Rule Revisions (LCRR) includes provisions for public water

utilities to conduct sampling in schools and child care facilities. However, as part of

President Biden’s E.O. 13990 regulatory review of the LCRR, the agency received

stakeholder input suggesting improvements to these and other provisions. EPA will

be considering these suggestions as part of a planned immediate rulemaking and

non -regulatory actions to equitably improve public health protection and improve

implementation of the rule to ensure that it prevents adverse health effects of lead

to the extent feasible. For more information, visit EPA’s Review of the National

Primary Drinking Water Regulation: Lead and Copper Rule Revisions.

ii

Why is this important?

There is no safe blood lead level in children. Children are most susceptible to the effects of lead

because their bodies are still developing; therefore, they tend to absorb more lead from any source,

including drinking water, than adults. Lead exposure in children can cause adverse health effects

both physical (e.g., impaired growth and hearing loss) and behavioral (e.g., reduced IQ and attention

span, hyperactivity, and learning disabilities).

The only way to know if there is lead in your drinking water is to test each fixture used for human

consumption (i.e., drinking, food preparation, brushing teeth, dishwashing, and hand washing). EPA

suggests that schools and child care facilities implement lead testing programs for reducing lead in

drinking water as part of their overall plans for maintaining healthy learning environments.

•

It is important to establish a program that includes routine testing and evaluations to limit

lead contamination, as well as routine practices to ensure that you are providing safe

drinking water to students and staff.

• It is important to identify lead fixtures and plumbing materials and be familiar with the

source of your drinking water. Some schools and child care facilities are served by nearby

public or private water systems, while others operate their own water systems and are

regulated under the Safe Drinking Water Act (SDWA). Even when water entering a facility

meets all federal and state public health standards for lead, older plumbing materials in

schools and child care facilities may contribute to elevated levels lead in their drinking

water. The potential for lead to leach into water increases the longer the water remains in

contact with leaded plumbing materials. As a result, facilities with intermittent water use

patterns, such as schools and child care facilities, are more likely to have elevated lead

concentrations in their drinking water.

• Lead can enter your drinking water through the corrosion of lead-containing plumbing

materials within your facility or through the water service line connected to your school or

child care facility.

• Building age and plumbing installations/repairs may increase the risk of elevated lead levels

in your drinking water if corrosion occurred in the plumbing materials. Factors to consider

may include:

o Buildings older than 1930: Likely to contain lead pipes that can contaminate water

quality.

o 1930 - 1986: Likely to contain lead solders used to join copper pipes together. Lead

pipes are possible.

o 1986 - 2014: “Lead-free” solders used on plumbing joints, brass fixtures or plumbing

components may have lead. Lead pipes are very unlikely.

o 2014 - Present: Even if “lead-free materials” were used in new construction and/or

plumbing repairs, lead leaching may occur. Lead pipes are very unlikely.

Is this Lead Sample Collection Field Guide for me?

This Guide is designed to support any school or child care personnel (e.g., maintenance staff, child

care support staff, on-site water system staff) who is asked to collect lead samples in drinking water

at their facility.

iii

• The information and resources included in this guide will help the designated personnel

understand the procedures and process to follow to collect lead samples and provides actions to

consider based on laboratory results. For more details on remediation, refer to

Module 6 in the

3Ts Toolkit or 3Ts Manual (published October 2018; EPA 815-B-18-007).

• The sampling collection procedures outlined in this guide also meet the minimum requirements

for schools and child care facilities that are recipients of funding from their state grant program

as part of the Water Infrastructure Improvements for the Nation (WIIN) Act. States may have

additional procedures or processes to follow.

• If you have questions about the WIIN grant program, you can find your state program at: EPA’s

WIIN 2107: Lead Testing in School and Child Care Program Drinking Water State Grant Program

Contacts.

• This guide assumes that each school and child care facility will run its testing program

independently. However, as you read through this guide, check with your state drinking

water/environmental program, certified laboratory, plumbing professional, or public water

system to see if they can help you with the sample collection.

How do I use this Lead Sample Collection Field Guide?

• Blue text indicates a hyperlink to a resource. Click the text to navigate to the link.

• Text in brackets [ ] contain a hyperlink to applicable sections (i.e., Prepare, Collect, Results)

within the guide. Click the text to navigate to that section.

• Section icons (below) are hyperlinked. Click the icon to navigate to a section of interest.

Prepare……… 1

Collect………7

Helpful

Results………12

Resources………16

iv

Prepare

Before collecting samples, facilities should develop a plan for (1) Communicating; (2) Training; (3)

Testing; and (4) Taking Action. Preparation is key for testing lead in drinking water. Use the “3Ts Plan

eBuilder” to create your plan at 3Ts program website.

Remember the importance of due diligence and the role you,

as the collector, are serving to help protect the children at your

facilities. It is important for personnel collecting the lead

samples to follow the steps as outlined in this Lead Sample

Collection Field Guide and use the sampling instructions

provided by your selected certified laboratory.

Use these steps to ensure proper preparation and effective

testing:

 Prioritize sample sites based on the plumbing profile

questionnaire (Module 4 in the 3Ts Toolkit

) and your

existing knowledge of the building.

 Decide which certified laboratory will analyze your

samples for lead and ask if they can help you collect

the samples. To find approved, certified labs, visit EPA

Certified Labs.

 Develop a coding and labeling system that clearly identifies each sample before collection.

 Collect all the materials listed in the [Prepare the Sample Site] subsection below, before

conducting sampling on-site.

How Can Water Systems H

elp?

Your public water system are critical p artners

in helping schools and child care f acilities test

for lead. They may be able to:

• Offer technical guidance.

• Help you develop sampling plans or

plumbing profiles.

• Assist with sample collection and

laboratory analysis.

• Support you in communicating lead

sample re sults to the community.

• Help interpret results and determine

potential lead sources.

For more information, see the 3Ts for Public

Water Utilities factsheet or visit EPA’s Final

Revisions to the Lead and Copper Rule to learn

more about the role of the system in sampling.

Lead Sa

mpling Considerations

• There is no safe blood lead level in children. Children are most susceptible to the effects of lead because their bodies

are still developing; therefore, they tend to absorb more lead from any source, including drinking water, than adults.

• A sample test is a snapshot of the lead level taken at the time it was collected. Prior low or non-detected lead

levels should not be used to assume that an outlet or facility is lead-free. Lead levels at an outlet or within a building

have been shown to vary over time.

• Regularly scheduled testing and routine maintenance are essential to reducing lead in drinking water. Consult with

your public water system for guidance.

• Results from one outlet should not be used to generalize the lead levels at other outlets in the facility. Lead

contamination can occur both in fixtures and in building plumbing, so a sample taken at any given outlet is not

representative of the entire facility.

• Buildings and fixtures built before 1986 are most likely to have lead solder and/or plumbing components that

contain lead. The 1986 Safe Drinking Water Act (SDWA) Amendments included a “lead ban” requirement stating that

only “lead-free” materials could be used in new plumbing and plumbing repairs. However, it is likely that lead pipes,

high-lead solder, and fluxes were used until 1990. The Reduction of Lead in Drinking Water Act of 2011 made the

definition of “lead free” more stringent by lowering the lead maximum lead content permitted. Up until 2014, even

those plumbing materials labeled as “lead-free” could contain up to 8% lead.

1

☐ Determine Which Fixtures to Sample

Many factors can contribute to selecting and prioritizing sampling locations. Some considerations:

• Oldest kn

own fixtures because these are more likely to contain lead (especially those installed

prior to the Lead Ban Act of 1986);

• Sampling sites should be those used for human consumption;

• Outlets that are used by children under the age of six or pregnant women (e.g., drinking

fountains, nurse’s office, early childhood education classroom, kitchen, teachers’ lounges);

• Areas with known service lines or lead pipes;

• Areas with corroded plumbing; and

• Frequency of use. The longer the water remains in contact with the lead plumbing material, the

potential increases for lead to leach into the water.

Testing each fixture used for human consumption

is important. During the first sampling round, if you

are not able to sample all fixtures in the building, the above factors can be used to prioritize the

sampling order. For example, first round samples may include drinking water fountains, water bottle

refill stations, sinks and kettles in kitchens, and nurse’s office sinks. If faucets are rarely used, consider

taking them out of service or designating them “not for human consumption,” if they cannot be

sampled. For more information on prioritizing sampling site locations, refer to

Module 4 in the 3Ts

Toolkit and answer the Plumbing Profile Questionnaire.

☐ Select a Certified Laboratory

Your school or child care facility should identify a

certified laboratory to analyze the water samples.

• Use a laboratory certified by the state or EPA for

testing lead in drinking water. Certified laboratories

have been validated by EPA or the state to use

appropriate analytical techniques that guarantee

accuracy and precision.

• Visit EPA’s Website or your state WIIN grant program

to find a list of certified drinking water labs and refer

to Module 4 in the 3Ts Manual for a list of

considerations when choosing a laboratory. Your

selected certified laboratory will be able to provide

sampling bottles, labels, relevant paperwork, and

specific instructions. Some may also offer to send

qualified individuals to collect the samples for you

(Be sure to check with the laboratory to determine if

there will be an extra cost for their sampling

services).

2

Questions to Ask Certified Laboratories

 What is the cost of the laboratory’s services and

what is included?

Costs will vary, depending upon the extent of the

services provided (e.g., if only analyses are conducted

or if sample collection is provided as well), and some

laboratories may have bulk analysis rates for many

samples.

 How quickly do I need to send back the

sample(s)?

Each laboratory has a different way of storing and

preserving your sample f rom the minute you collect it,

so ask how long you have to send it back.

 What analytical techniques do you use?

Ask, do you use EPA -approved methods that can meet

low enough reporting limits (e.g., at or below 1 µg/L)?

This way, you can confirm the accuracy of the results

reported.

The laboratory will send a report back to you after their analysis is complete.

• This report will show the numerical level of lead detected in the water samples. If a report is difficult

to understand, refer to Module 5 in the 3Ts Toolkit

, call the laboratory with questions, or contact

your local water system.

Note: EPA strongly discourages the use of do-it-yourself (DIY) testing kits. These kits can be inaccurate

and many only indicate if lead is detected (i.e., no numerical values are provided). A numerical number

is needed for you to take the appropriate short-term or long-term action to reduce lead exposure.

☐ Develop a Coding and Labeling System

The next step is to create a coding and labeling system that will allow each unique outlet to be

identified by location, type, and other relevant characteristics (e.g., room number, floor, etc.).

• Use the 3Ts factsheet Develop a Code System for Samples (see Module 4 of the 3Ts Toolkit

) to

create a labeling system. Additionally, create a document to record your sampling data and actions

taken based on the results; for example, use the 3Ts Sampling Data eTrackers.

How Do I La

bel My Sample Locations?

Code each outlet using a system that will allow each unique outlet to be identified by location, type, and other

relevant characteristics. Following is an example from Module 4 in the 3 Ts Toolkit:

Floor -Room Number -Outlet Type -Sample Type -Sample Number

Example: 3

rd

floor (003), room 312, drinking water (DW) fountain, first draw sample ( P), 15

th

outlet collected

(015).

☐ Prepare the Sample Site

Schools or child care facilities should request, from the certified laboratory, the appropriate number

of bottles and paperwork prior to sample collection.

Certified laboratories should send sampling bottles, labels, instructions, paperwork, and return shipping

box. Determine how many sample containers you will use for each fixture, and make sure the laboratory

has sent the appropriate number of containers. Leave the containers sealed until it is time to collect the

samples. For more details – view the 2-Step Sampling at the Tap in Module 5 in the 3Ts Toolkit

.

3

Note: Container size may vary.

EPA’s 3Ts program recommends

250 mL plastic bottles that have

wide openings. However, you

may need a smaller container

depending on the purpose of the

sample. A smaller amount of

water sample may be necessary

for detailed fixture evaluations

to pinpoint where lead is getting

into the drinking water, so

appropriate corrective measures

can

be taken. Due t

o the different compositions and dimensions of fixtures (e.g., water fountain, cold

water faucet, ice-making machine, central chiller unit) there are different sample collection procedures

for each fixture, refer to the [Collect

] section for more details. Consult with your laboratory to confirm

they will be able to analyze the smaller sample volume. For more details see Module 5 in the 3Ts Toolkit

-- Detailed Fixture Evaluation.

wa

Source: Variability and sampling of lead (Pb) in drinking

ter: Assessing potential human exposure depends on

the sampling protocol. Triantafyllidou, et al. December

16, 2020; Published by Elsevier Ltd.

Prepare the site location(s) and get ready to begin the sampling process.

Be

low is a list of items you will need to gather before collecting your sample. Place a checkmark by each

item as you collect it.

Materials Needed Before Conducting Sampling Procedure

☐

Hand wipes or bottled water for washing hands. Avoid using water from the fixtures you are

sampling.

☐

A permanent marker to keep careful track of which locations you have sampled on your

sampling plan (Pens may bleed or smear).

☐

A notepad to record observations at the fixtures and any other relevant information.

☐

A stopwatch to keep track of flush times (refer to the [Collect] section for more details on

when this would apply to you).

☐

Labeled sample containers (from the laboratory) to collect the water.

☐

Sampling form to document additional details about the sampling environment. Use the

3Ts Sampling Data eTrackers

1

. The chain-of-custody form from the laboratory may also ask

for these details.

☐

A small table to place materials on while collecting samples. Do not place materials on the

floor as they are easily contaminated there and more susceptible to being accidentally

knocked over.

1

For more information about the 3Ts Sampling eTrackers, visit the [Receiving Results] subsection below.

4

Materials Needed Before Conducting Sampling Procedure

☐

Disposable plastic gloves (non-latex or nitrile) may be used to collect samples and avoid

direct contact with the sampling containers. Some laboratories may send sample

containers preserved with acid.

☐

Labeled reference map of the building’s floorplan or plumbing system to use while

sampling.

☐

Signs alerting building users not to use the fixtures until after you have collected your

samples. These should be posted prior to the sampling date.

At the moment of taking the sample, the water should have sat in the pipes for at least eight (8)

hours, but for no more than eighteen (18) hours, prior to collection.

• These samples are typically collected in the morning before the facility opens and before the

fixtures have been used.

Example Sign

ATTENTION!!!

Do not use any water (including flushing toilets) in the building. We are collecting lead samples and this is a

procedural requirement.

Sampling Date: Friday, October 1, 2021

Time: Do not use water from 8:00 PM Thursday September 30th to 8:00 AM Friday October 1st

We appreciate your cooperation!

There should be no water usage at the school or childcare facility before sampling.

•

Plan accordingly to wash your hands, fill up any water bottles for personal consumption, and

use bathroom facilities before arriving on-site.

• Prior to the sampling date, post signs with the date and time period of non-use to alert

building users that they should not turn on any water (including flushing toilets) in the

building. With teachers, maintenance, sports teams, and clubs potentially using facilities

after hours, be sure to communicate about sampling beforehand so there is no confusion or

accidental usage.

• Take the following assurances before sampling:

 Make sure the area is free of potential contaminants, your materials are ready, and

you are fully prepared to begin sampling. It is better to focus on being thorough

while sampling, rather than collecting samples quickly.

 Place a checkmark by each task as you complete it. After reviewing and completing

the tables in this section, you can move onto the next section: [Collect

].

5

Assurances to Take Before Conducting Sampling

☐

The night before, post signs alerting people not to use the fixture (EPA recommends the

water should sit in the pipes for at least 8-hours, but no more than 18-hours, prior to

sampling). These samples are typically collected in the morning before the facility opens

and before any fixtures have been used.

☐

Do not close the shut-off valves to prevent their use prior to sample collection, as this may

result in nonrepresentative results. It is important for the system to run normally to

receive results that represent typical use.

☐

Do not use the facilities’ restrooms or sinks that morning prior to sampling.

☐

Wear gloves to avoid contaminating the samples and for your own safety, as some

laboratories may send sample containers preserved with acid.

☐

Make sure there is no food, drink, or other substance around the sampling location that

could contaminate the sample.

☐

Double check that all containers have been labeled and have no visible indication of

contamination (such as an ajar lid or hole in the container).

☐

Verify with your map and sampling plan that you are at the correct fixture with the

correctly labeled sampling containers.

☐

Set up your table next to the fixture with the sampling containers unopened and labeled,

in addition to any other necessary materials. Keep containers closed until you are ready to

collect the sample.

☐

When you open the container, set the lid on the table facing up to avoid contamination

from contact. Keep the threads also facing up. If the threads or container interior are

touched, do not use the container.

☐

Do not remove aerators prior to sampling. See Module 5 in the 3Ts Toolkit for details on

“Determining aerator/screen debris contribution”.

☐

If there are multiple floors, it is typically recommended to sample from the bottom floor

and continue up. Start sampling closest to where the water pipe comes into the building

and work away. Refer to Module 4 in the 3Ts Toolkit for more details.

6

Collect

In this section, you will learn about the appropriate sampling techniques and best

practices to obtain accurate results, as well as how to properly ship your sample to the

laboratory for analysis. There are three potential sampling types that this guide covers

(Refer to Modules 4 and 5 in the 3Ts Toolkit for more details on sample types):

 First-draw Samples

 Flush Samples

 Sequential Samples

I

mportant Notes:

• Collect all samples from cold water taps. Although EPA encourages routine

maintenance of hot water heaters, this guidance does not include sampling hot

water outlets or hot water heaters, because hot water is not recommended for consumption

(drinking/cooking). Refer to Module 6 under “Temperature Control”

in Remediation and

Establishing Routine Practices in the 3Ts Toolkit.

• After collecting the samples, you will need to ship them to the laboratory in a timely manner

(typically within 2 weeks). Carefully follow any packing and shipping instructions the laboratory

has sent. If no instructions were provided, please review the [Shipping Your Samples

] section in

this guide for additional directions.

☐ First-draw Samples

First-draw samples are typically collected in the morning before the facility opens and before the

fixtures have been used. Collect samples from the cold water tap.

• First draw samples represent the water that may be consumed at the beginning of the day or

after infrequent use. These results will indicate if the fixture and its parts are a source of lead in

your water.

• First draw samples are collected before a facility opens and before any water is used (including

flushing toilets) after an 8- to 18-hour stagnation period. EPA recommends the water should sit

in the pipes for at least 8 hours, but no more than 18 hours, prior to sampling. Using this

approach maximizes the likelihood that the highest concentrations of lead will be found because

the first 250-mL sample is collected after the water has sat in the pipes for at least 8-hours.

• The flow rate when collecting the sample should be consistent and as high as feasible, without

splashing or overfilling.

• Below is a checklist of steps you can use to complete a first-draw sample. Please refer to

instructions sent by the certified laboratory or your state program and use those if they differ

from the steps below.

7

-

Instructions for First draw Sampling

☐

1. Double check you have the correct sampling bottles for the sampling site.

☐

2. Label containers with your coding identification (ID) (use the permanent marker),

if not already done.

☐

3. Take out your recordkeeping document (e.g., chain-of custody-form, 3Ts Data

eTracker) for immediate access.

☐

4. Put on gloves.

☐

5. Place the opened container under the fixture ready for water collection.

☐

6. Turn on the fixture and immediately fill the 250 mL container to the top (or

appropriately sized container based on the sample purpose), but do not overflow.

☐

7. Turn off the fixture.

☐

8. Close the container according to the laboratory’s instructions. Tightly cap the

container and set it aside.

☐

9. Record any observations that may impact the lead sample results, such as a leaking

faucet, water discoloration, or variable water pressure. You may also take photos

that will be useful when interpreting results. Reminder: Record the date, time, and

sample type.

☐

10. Repeat steps 1-9 at each sampling site until you have the appropriate number of

samples requested.

☐

11. Prepare the shipping container and send samples to the laboratory according to

the laboratory’s instructions.

☐ Flush Samples

Flush samples are taken after the water from the fixture has been running for a specific amount of

time, commonly 30 seconds. Collect samples from the cold water tap.

• A flush sample is typically needed if the results of the initial first-draw sample detect lead.

• Flush samples are used to further determine if lead is coming from the fixture itself or from

interior plumbing. Your state program or certified laboratory may instruct you to collect a flush

sample, or you may do so on your own based on an elevated lead level that was previously

detected.

8

• The purpose of the flushing is to rid the pipes of stagnant water so that you can better identify

t

he source of lead. These results will indicate if the pipes behind the fixtures and its parts are

a

s

ource of lead in the water

.

• Flush samples are collected before a facility opens and before any water is used (including

f

lushing toilets) after an 8- to 18-hour stagnation period

.

 For a more accurate result, samples taken from different fixtures that are near each

o

ther should be collected on different days

.

 F

or drinking fountains or other fixtures that are close together, a single flush sampl

e

ma

y be representative of their shared interior plumbing

.

• The f

low rate when collecting the sample should be consistent and as high as feasible, withou

t

s

plashing or overfilling

.

• EP

A’s 3Ts program recommends conducting a 2-step sampling procedure to identify if there i

s

le

ad in the outlet or behind the wa

ll.

 Step 1 is collecting the first-draw sample and step 2 is collecting the flush sample.

 Yo

u may collect flush samples in the same sample event or on a different day. Collecti

ng

t

he samples in the same sampling event may reduce cost and provide you with mor

e

i

nformation on lead levels sooner. In this case, the flush sample is collected immediate

ly

a

fter the first-draw sample

.

 I

f the first-draw sample and the flush sample are not taken in the same sample event

,

and your elevated lead level of concern is found in step 1, do not consume the water

w

hile preparing to take the flush sampl

e.

• B

elow is a checklist of steps you can use to collect a flush sample. Please refer to instruction

s

ent by the certified laboratory or your state program and use those if they differ from the step

s

be

low

.

Instructions for Flush Sampling

☐

1. If

you did not collect the first-draw sample first, follow steps 1-4 in First Dr

aw

Sampling checklist and then proceed to Step 2.

☐

2. Turn on the fixture and start your stopwatch. Time the water so it runs for a fixed

amount of time, usually 30 seconds. Maintain a consistent rate of flow during that

time.

☐

3. A

fter 30 seconds, fill the 250 mL container (or appropriately sized container bas

ed

o

n the sample purpose) to the top, but do not overflow

.

☐

4. Tur

n off the fixture

.

☐

5. C

lose the container according to the laboratory’s instructions. Tightly cap th

e

c

ontainer and set it aside

.

☐

6. Record any observations that may impact the lead sample results, such as a leaking

faucet, water discoloration, or variable water pressure. You may also take photos

t

hat will be useful when interpreting results. Reminder: record the date, time, an

d

sample type.

9

Instructions for Flush Sampling

☐

7. Repeat steps 1-6 at each sampling site until you have the appropriate number of

samples requested.

☐

8. Prepare the shipping container and send samples to the laboratory according to

the laboratory’s instructions.

☐ Sequential Samples

Sequential samples involve collecting a series of water samples at a single fixture, without flushing

beforehand or running the water between samples. Collect samples from the cold water tap.

• The purpose of a sequential sample is to pinpoint if your source of lead is from the fixture itself.

The samples you collect will represent water that was in contact with the fixture and any piping

or plumbing behind the wall.

• How you collect the sample will depend on what fixture you are collecting the sample from. See

the Detailed Fixture Evaluation in Module 5 of the 3Ts Toolkit for specific instructions on how to

conduct sampling for each of these fixtures:

 Drinking Water Fountains  Cold Water Faucets

 Drinking Water Fountains with  Icemaking Machines

Coolers

 Central Chiller Unit

☐ Shipping Your Samples

Most certified laboratories will provide shipping containers, so take advantage of this and closely

follow their instructions for packaging and shipping.

• Bring the shipping kit with you to the sampling sites so that you can place finished containers

directly into it after confirming they are appropriately labeled.

• Use the labeling system you created in [Develop a Coding and Labeling System]. Document

your sample event information (e.g., date and time of sample collection, sample type, fixture

location, etc.) for each sample collected [Use the 3Ts Sampling Data eTrackers.]

10

• The lab typically will ask that you complete a chain-of-custody (COC) form to ensure the

contents of your sample are safely received by the appropriate entity [Figure 1

]. Use the

information from your Data eTracker or other recordkeeping to fill out the COC form.

Figure 1. Example of a Chain of Custody Record.

 [Figure 1] shows an example COC form that your laboratory should send you with the

shipping instructions. Once completed, make a copy of the COC for your records and

place the original in the shipping container. The last step is to pack your samples and get

ready to ship them.

• Coordinate with your laboratory regarding a return date for your samples, typically within the

next two weeks.

 It is very important to ship your samples in a timely manner. Upon receipt, the

laboratory will acidify the sample to preserve it (unless they have already provided you

with preserved sample containers). If the laboratory fails to receive or analyze your

samples in time (as instructed), you may need to re-collect the sample and pay for the

additional sampling bottles the laboratory will send you.

 Follow any directions provided by the laboratory and consider the following best

practices for shipping:

 Ship your sample as soon as possible, preferably the same day after sampling is

conducted. Prepare ahead of time and avoid shipping on Fridays, around

holidays and long weekends, or during other times when shipping services may

be delayed.

11

Results

This section will cover the steps you can take after you receive the lead sample results from your

selected laboratory. The steps include receiving and interpreting your results, taking action to address

problem fixtures, and sharing the results with your school or child care community.

☐ Receiving Results

The laboratory will provide you with an estimated time frame that you will receive the results.

• Use the 3Ts Sampling eTrackers to record your lead sample results for each fixture.

Interactive Tool: EPA 3Ts Sampling eTrackers

The

3Ts Sampling

eTrackers were developed

to assist schools and

child

care

facilities to track and document

sampling

event information (i.e., inventory,

results,

actions).

For

WIIN

grant recipients

it

also includes the

date

elements needed

to report

to your

state. You

can

access

the eTrackers

here:

3Ts Sampling eTrackers

.

Common Lead Concentration Units

• Use this table to convert units of

measurement. Different units of

measurements are often used

between programs or documents.

Unit Conversion

Parts per billion (ppb) 1 ppb = 1 µg/L = .001 ppm = .001 mg/L

Parts per million (ppm) 1 ppm = 1 mg/L = 1000 ppb = 1000 µg/L

Microgram per liter (µg/L) 1 µg/L = 1 ppb = .001 mg/L = .001 ppm

Milligram per liter (mg/L) 1 mg/L = 1 ppm = 1000 µg/L = 1000 ppb

☐ Interpreting Results

Once you receive your lead sample results, you will need to determine which fixtures or plumbing

material need immediate, short term and/or permanent actions.

Results from one outlet should not be used to generalize the lead levels at other outlets in the facility

nor to determine the overall quality of your drinking water throughout the building.

• Lead contamination can occur from fixtures, building plumbing, and/or lead service lines (i.e.,

the pipe that connects a water main to a user's premises). Refer to Module 4 in 3Ts Toolkit

for

more details on “Do You Have a Lead Service Line?”

• A sample result is a snapshot of the lead level taken at the time it was collected.

 Prior low or non-detected lead levels should not be used to assume that an outlet or

facility is lead-free.

• Lead levels at an outlet or within a building have been shown to vary over time whether it

be from usage frequency, seasonal variations, new or aging fixtures, or changes made by

your public water system.

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It is important to establish a program that includes routine testing and evaluations to limit lead

contamination, as well as routine practices to ensure that you are providing safe drinking water to

students and staff.

Make sure you know your 3Ts Program Remediation Trigger (PRT) or level of concern before you

receive the lead sample results.

• Contact your appropriate state agency and discuss your state’s requirements.

 If you are a recipient of funding from your state’s Water Infrastructure Improvements

for the Nation (WIIN) Act, the state will provide the PRT, unless you choose a lower

level.

 Visit EPA’s

WIIN 2107: Lead Testing in School and Child Care Program Drinking

Water State Grant Program Contacts to find your state program.

 The numeric value for taking action is determined by you or your state. If that lead level

of concern or PRT is detected in your sample results, you should take immediate action

to reduce the lead exposure for that source.

Review your plan (which you prepared before sampling) to determine the action(s) you will take when

lead is detected.

• The 3Ts program recommends taking immediate action (e.g., within 24 hours) for sample results

with “elevated lead levels” based on the 3Ts PRT or level of concern you selected.

☐ Taking Action

Remember, there is no safe blood lead level in children. The 3Ts program recommends that you take

appropriate action on each drinking water outlet with a detected lead level; starting with the results

that exceed your level of concern or PRT.

• Solutions to lead problems typically should be addressed on both a short-term and a long-term

basis.

 When selecting a remediation solution, you should engage the local health

department, public water system, and other available resources to ensure the

organization performing remediation is qualified and reputable.

 Ask vendors for information on the schedule, health precautions that must be taken

during and following remediation and request regular status updates on their progress

prior to agreeing to work with any particular organization. Refer to

Module 6 in the 3Ts

Toolkit for more details.

• It’s important to remember that each result is intended to identify a specific source of lead. It’s

not an indication of the lead levels throughout the entire building or the water system.

• [Figure 2

] shows some steps you can take to address fixtures that you have been tested for lead.

 There are immediate, short term (i.e., temporary), and permanent actions you can take

to prevent lead exposure. Refer to Module 6 in the 3Ts Toolkit, which includes

information on follow-up sampling, best practices for flushing, and remediation options

and considerations.

• Ask your state program or local water system for tangible recommendations regarding your

specific lead sampling results.

13

• An elevated result that exceeds your PRT or state action level will require follow-up sampling,

which could include flush samples, service line flush samples (further discussed in the [Collect

]

section), or a detailed fixture evaluation to pinpoint which part of the outlet or plumbing is

adding lead to your drinking water (discussed in more detail in the Detailed Fixture Evaluation in

Module 5 of the 3Ts Toolkit).

• Note: Use the 3Ts Sampling eTrackers to track whether follow-up, remediation, and/or

replacement actions have been taken for each of the outlets sampled.

If your lead sample results detected lead levels that exceed your PRT or state action level, the 3Ts

program recommends taking immediate action (for example, within 24 hours) and use the remediation

options (i.e., short or long-term control measures) that you put in-place to reduce exposure.

• See recommendations in [Figure 2] and refer to Module 6 in the 3Ts Toolkit for more details.

If your lead sample results detected lead levels below your PRT or state action level, the 3Ts program

recommends taking action to further minimize potential exposure.

• Actions may include posting a sign at the fixture to inform that lead was found, installing filters,

implementing routine flushing, removing the fixtures from service, or replacing drinking water

fountains. See recommendations in [Figure 2].

• Next, start preparing for the next round of testing. Lead testing is an iterative process that

requires continuous efforts to help provide safer drinking water for your community and to

contribute to a healthy school or child care environment for all.

o At a minimum, EPA encourages annual sampling even when a sample result is non-

detect or low. Lead in drinking water can vary widely in space and in time (i.e., between

buildings, within buildings and even at the same fixture over time), as the combined

result of water chemistry, hydraulics, lead plumbing sources and water consumption

patterns. Refer to Module 6 in the 3Ts Toolkit

, which includes remediation options and

routine practices.

☐ Sharing Results and Actions

Regardless of the sample results, maintaining records is important for future sampling and remediation

efforts, schedules for upkeep and maintenance, and communicating with your school community and

partners and contacts that assisted you.

It is critical that you share your results and actions you took to reduce lead exposure with your

community members, including students, parents, staff, and anyone else who uses the building.

• You can use resources from the 3Ts Toolkit to prepare your communication plan.

Module 1 of

the 3Ts Toolkit includes newsletter templates, a parent letter template, a postcard template, a

customizable poster, and other guidance to help you communicate your testing program along

with the lead sample results and actions taken. It is important to be transparent in your

communications and to keep your community updated about past, ongoing, and upcoming

efforts.

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Figure 2. Steps to Consider After Receiving Your Sampling Results.

Taking Action After Receiving Your Sampling Results

Did the results exceed your 3Ts

Program Remediation Trigger?

Ye

Yes

s

Immediate Response

- Use your actions as determined in your 3Ts plan

- Use actions recommended in 3Ts Module 6

o

Shut off

problem

fixtures

o

Post "Not for

Consumption" signs at

problem

fixtures

o

Reach

out to

your water system

for

guidance

o

Share test

results with stakeholders (see

templates

)

o

Increase

awareness and public education

(see posters/factsheets)

Conduct further

sampling and

implement control

measures.

Short Term Control Measures

- Provide and maintain point of use

(POU) filters. See li st of certified

filters at -

A Consumer Tool for

Identifying Point of Use (POU)

Drinking

Water

Filters

Certified

to

Reduce Lead

-

Flush fixtures prior to

use

-

Provide bottled water

-

Reach

out to

your water system

for

guidance

Permanent Control M easures

- Replace problem pipes or

fixtures

- Provide and maintain filters

at problem fixtures

- Replace any other plumbing

containing lead

- Reconfigure plumbing

Follow-Up Sampling

- Ensure additional samples are taken before

facility opens or water is used

- Sample fixtures that have been replaced or

reconfigured piping

- Compare results to original sa mples to see i f

remediation efforts were successful

No

What was the sample result?

Below the Program

Remediation Trigger

Recommended Measures to

Minimize Exposure

- Use your actions as determined in

your 3Ts plan

- Continue the testing, monitoring,

and/or routine maintenance options in

your 3Ts plan to minimize e xposure to

lead in drinking water

- Consider implementing additional 3 Ts

routine maintenance,

flushing

procedure, and aerator cleaning

options

- Implement short-term and permanent

remediation action plans accordingly

- Provide and maintain point of use

(POU) filters. See li st of certified filters

at -

A Consumer Tool for Identifying

Point of Use (POU) Drinking Water

Filters Certified to Reduce Lead

- Post a sign at the fixture to inform that

lead was found and any action the

user should take

- Share test results with stakeholders

(see templates

)

Non-detect

Recommended Measures

- Use your actions as determined in your 3Ts plan

- Continue the testing, monitoring, and routine maintenance

measures in your 3Ts plan to ensure there is not lead in the

plumbing system

- Consider implementing additional 3 Ts routine maintenance

,

flushing procedure, and aerator cleaning options

- Share test results with stakeholders (see templates)

15

Helpful Resources

This Lead Sampling Collection Field Guide builds on EPA’s continued efforts to provide proactive steps to protect children’s health. Specific to lead testing and

water quality, EPA develops tools and materials for schools and child care facilities to use.

Visit the accompanying Lead Sample Collection Video: https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water

• 3Ts Revised Manual for Reducing Lead in Drinking

W

ater in Schools and Child Care Facilities:

https://nepis.epa.gov/Exe/ZyPDF.cgi/P100VLI2.PDF?Dockey=P100VLI2.PDF

• 3

Ts

Toolkit: https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water

• 3Ts Sampling eTrackers: https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water#mod7

• List of EPA Certified Labs: https://www.epa.gov/dwlabcert/contact-information-certification-programs-and-certified-laboratories-drinking-water

• Lead Testing in School and Child Care Program Drinking Water Grant Contact Information: https://www.epa.gov/dwcapacity/wiin-2107-lead-testing-

school-and-child-care-program-drinking-water-state-grant-program

• EPA’s Website on Certification of Laboratories: https://www.epa.gov/dwlabcert

• EPA’s National Accredited Laboratory List: https://www.epa.gov/lead/national-lead-laboratory-accreditation-program-list

• EPA’s Website on Lead in Drinking Water in Schools and Childcare Facilities: https://www.epa.gov/dwreginfo/lead-drinking-water-schools-and-

childcare-facilities

• EPA’s Information on Maintaining or Restoring Water Quality in Buildings with Low or No Use: https://www.epa.gov/coronavirus/information-

maintaining-or-restoring-water-quality-buildings-low-or-no-use

• EPA’s Consumer Tool for Identifying POU Drinking Water Filters Certified to Reduce Lead: https://www.epa.gov/water-research/consumer-tool-

identifying-pou-drinking-water-filters-certified-reduce-lead

• EPA’s Water Infrastructure Improvements for the Nation Act Lead Testing in School and Child Care Program Grant:

http://www.epa.gov/safewater/grants

• 3Ts Child Care Poster: https://www.epa.gov/ground-water-and-drinking-water/3ts-child-care

• EPA’s Extended Closure Factsheets for Child Care Facilities and Schools: https://www.epa.gov/ground-water-and-drinking-water/audience-factsheets

• EPA’s Sample Collection Guide for Child Care Facilities Comic Strip: https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-

drinking-water#mod5

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