- Holland Patent Central School District
- Lead Testing of School Drinking Water
- Frequently Asked Questions
Frequently Asked Questions
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10 NYCRR Subpart 67-4 requires all school districts and boards of cooperative educational services (BOCES) in New York State to test potable water for lead contamination and to develop and implement a lead remediation plan where applicable.
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How does lead get in drinking water?
Plumbing materials, including pipes, new brass faucets, fittings and valves, including those advertised as lead-free, may contribute lead to drinking water. The “on-again, off-again” nature of water use at most schools can raise lead levels in school drinking water. Water that remains in pipes overnight, over a weekend or over vacation periods stays in contact with lead pipes and/or lead solder and may accumulate and contain higher levels of lead.
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Where can I find the regulations?
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How often is school drinking water tested?
Compliance testing occurs every three years. Copies of lead results, including lab reports and any lead remediation plans, must be made available to the public and posted on the school’s website.
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Which water outlets are tested?
Samples must be collected from all outlets (sinks, fountains, bubblers, filling stations, etc.) that are or may be used for drinking or cooking. This includes classroom and laboratory sinks if controls are not in place to prevent the consumption of water from them.
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What it is a "first-draw" sample?
A "first-draw" sample is a water sample that is collected from a cold water outlet before any water is used from that outlet. The water shall be motionless in the pipes for a minimum of eight hours but not more than 18 hours before sample collection. The required sample volume for analysis of lead in school drinking water samples is 250 milliliters (ml).
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What does the "water must be motionless" mean?
The water in the school facility must remain motionless in the plumbing for a minimum of eight hours but no more than 18 hours. During this period, no water can be used in the facility. This includes non-drinking water outlets, janitorial sinks, toilets, outside hoses and irrigation systems (unless the irrigation system is served by its own service line). This amount of time was established to ensure that the collected samples are representative of water that a student or faculty member may consume. Sampling should be conducted to reflect normal school operating conditions.
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Who can collect the samples?
Any individual who is familiar with the regulation's sampling protocol may collect samples. This includes but is not limited to a school staff member, a laboratory representative, or a consultant. The individual collecting the sample must be able to maintain quality assurance and control over the sampling and must ensure the chain of custody of the water samples is maintained. However, the school is ultimately responsible for ensuring that the samples are correctly taken.
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Who can test/analyze the samples?
All water samples must be analyzed by an environmental laboratory certified by the NYS DOH Environmental Laboratory Approval Program (ELAP).
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At what level does remediation need to be done?
Effective December 22, 2022, the action level for lead in school drinking water is 5 micrograms per liter(mcg/L) or parts per billion(ppb), which is also equivalent to 0.005 milligrams per liter (mg/L) or parts per million (ppm).
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How common is lead in drinking water?
Nationwide, as many as 12.8 million lead pipes are still in service, according to the Natural Resources Defense Council. The highest concentrations of lead tend to be in fixtures that students and staff don’t regularly use, allowing the lead to build up – this includes outlets such as science laboratories and lavatory sink outlets, which should not be used for consumption.
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What is the school required to do if the lead test result for an outlet exceeds the action level (5 mcg/L, or ppb)?
Among other requirements, the school must prohibit the use of the outlet (remove from service) until:
- A Remedial Action Plan is implemented to mitigate the lead level at the outlet, and
- Post-remediation test results indicate that the lead levels are at or below the action level.
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What are a school's recordkeeping requirements?
The school shall retain all records of test results, lead remediation plans, determinations that a building is lead-free, and waiver requests for 10 years following the creation of such documentation. Copies of such documentation shall be immediately provided to the Department, local health department or State Education Department, upon request.
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What remedial options are available to address outlets that exceed the action level?
The school may choose to obtain professional services or utilize internal staff to support and perform the following remediation activities:
- Permanent outlet removal. If the outlet is seldom used, it may be disconnected or removed from the water supply line.
- Outlet and/or Pipe replacement with lead-free plumbing materials.
- Flushing. Schools may consider developing a systematic flushing program to implement routinely (at a specified frequency). Flushing is generally used as a short-term measure and paired with permanent remediation, like the replacement or removal of an outlet.
- Point of Use (POU) Filters installed at individual outlets. Schools may choose to use certified lead-reducing filters as a long-term or permanent control measure with proper maintenance.
- “Do Not Drink” Signage. Posting “Do Not Drink” or equivalent signs at outlets is considered a temporary measure. However, some outlets (e.g., science laboratories and lavatory sink outlets) may have signs posted long-term if the school has also instituted other controls, including supervision and education, to ensure the outlets are not used for consumption.
- Supervision of Outlet Use as a Control Measure. In areas where supervision is present and there are policies to prevent the use of water for consumption purposes (e.g., no drinking or eating in science laboratory classrooms), supervision may be used in combination with other remedial action.
- Engineering controls. Engineering controls may be implemented to prevent the consumption of water from specific outlets. Engineering controls include locked doors to janitor’s closets, special keys to operate an outside hose bib, and other controls.
- Education. Educate the school community (students, parents, teachers, and staff) to reinforce understanding and compliance with engineering controls, supervision controls and signage.
Only those outlets that exceeded the action level need to be resampled following remediation, including outlet or pipe replacement, filter installation, implementation of a flushing program, or other measures.
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If an outlet has tested above the action level, can the water still be used for cleaning and handwashing?
Yes, the water can be used for handwashing and cleaning. Lead is not absorbed through the skin. Signage should be placed at non-drinking water outlets stating that water should not be used for drinking; it should only be used for handwashing and cleaning. Pictures should be used if small children are using the water outlets, and staff should ensure they understand what the signs mean and monitor to ensure that they don't drink the water.
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Does Subpart 67-4 require schools to test for any other substances?
No. Only testing for lead is required of schools under this regulation.
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Are private schools required to conduct lead testing under this regulation?
No. Only NYS public school districts and boards of cooperative educational services (BOCES) are required to test for lead under this regulation.
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Ways to Reduce Exposure to Lead in Drinking Water Anywhere
- Use only cold water for drinking and food preparation. If hot water is needed, it should be taken from the cold water faucet and heated on a stove or in a microwave.
- Let it run before use. Running water at a tap, before using it for drinking or food preparation, will typically help reduce lead in the water. This works by removing the water that has been in the longest contact with the plumbing materials. Let the water run for 30-60 seconds or until the water feels cold before using it for drinking or cooking.
- People can virtually eliminate their exposure to lead in water by drinking or using only bottled water that has been certified by an independent testing organization. This may not be the most cost-effective option for long-term use.
- Use only cold water for drinking and food preparation. If hot water is needed, it should be taken from the cold water faucet and heated on a stove or in a microwave.
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Where can I get more information about lead?
Additional information can be found on the Department's website at:
https://www.health.ny.gov/environmental/lead/. The Department will update this website as more information becomes available.If you have further questions, please contact your local health department. Contact information is available at:
hhttps://www.health.ny.gov/environmental/lead/exposure/childhood/program_contact_map.htm.
Definitions
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- Lead - a common metal found in the environment that is toxic and harmful to human health. The greatest risk of harm from lead exposure is to infants, young children and pregnant women. Children and adults can be exposed to lead from lead paint, lead in products and toys, lead in drinking water from plumbing materials, and other sources.
- Potable Water – also known as “drinking water” is water that is safe for ingestion, either when drunk directly in liquid form or consumed indirectly through food preparation. Potable water comes from surface water and groundwater sources. This water is treated to levels that meet state and federal standards for consumption.
- Lead - a common metal found in the environment that is toxic and harmful to human health. The greatest risk of harm from lead exposure is to infants, young children and pregnant women. Children and adults can be exposed to lead from lead paint, lead in products and toys, lead in drinking water from plumbing materials, and other sources.