School & childcare lead-in-water testing

Federal background

Two things drive testing here: the EPA 3Ts, which are voluntary federal guidance, and the Lead and Copper Rule Improvements (LCRI), which place obligations on community water systems rather than on schools directly. The key points:

• EPA 3Ts = Training, Testing, Taking Action; VOLUNTARY guidance for schools/child care, not a federal mandate (EPA 3Ts page; LCRI Schools Fact Sheet EPA 816-F-24-016, Oct 2024).
• The revised 3Ts does NOT set a federal remediation/action level for schools; EPA urges reducing lead to the lowest levels possible (no safe level). States may optionally set a remediation level (e.g., 20 ppb).
• WIIN Act Sec. 2107 (2016) added SDWA Sec. 1464(d), creating the Voluntary School and Child Care Lead Testing and Reduction Grant Program; amended by AWIA Sec. 2006 (2018) and IIJA Sec. 50110 (2021); 2021 amendment added remediation as an eligible use (EPA WIIN Grant page).
• WIIN 2107 grantees must use EPA's 3Ts. EPA cites over $200 million provided since 2018; the LCRI fact sheet notes over $105 million to states since 2021 (EPA WIIN Grant page; EPA LCRI Schools Fact Sheet).
• LCRI signed October 8, 2024; lowers the lead action level to 10 ppb (0.010 mg/L) from the prior 15 ppb; requires lead and GRR service line replacement generally within 10 years (~99% of systems) (EPA LCRI Improvements page; EPA LCRI Q&A).
• LCRI compliance date is November 1, 2027; CWS public-education and school/child-care sampling obligations begin then (EPA LCRI Schools Fact Sheet, EPA 816-F-24-016, Oct 2024).
• LCRI school/child-care requirements bind COMMUNITY WATER SYSTEMS, not schools directly; EPA lacks SDWA Sec. 1412 authority over non-PWS schools; NTNCWSs are excluded (EPA LCRI Schools Fact Sheet, p.1).
• LCRI sampling: elementary schools and child care offered sampling at minimum 20%/year for first 5 years starting Nov 1, 2027, then on request; secondary schools on request only. 5 samples per elementary school, 2 per child care; 250-mL first-draw cold-water after 8-18 hr stagnation (EPA LCRI Schools Fact Sheet, Table 3).
• LCRI exception: requirements do not apply to schools/child care built or fully re-plumbed on/after Jan 1, 2014 that are also NOT on a lead, GRR, or unknown service line (EPA LCRI Schools Fact Sheet, Table 1).
• Non-responsive = after at least two outreach attempts with no response; states may issue written sampling waivers where a state/local program is at least as stringent as LCRI; waivers cover sampling only, not public education (EPA LCRI Schools Fact Sheet, pp.3-5).
• CAUTION: 15 ppb is the OLD pre-LCRI action level, not a current 3Ts threshold and not the current LCRI level (now 10 ppb). The 3Ts sets no federal remediation level. Do not present 15 ppb as the current federal action level (EPA 3Ts; EPA LCRI Q&A).

EPA 3Ts (Training, Testing, Taking Action)

3Ts = Training, Testing, Taking Action. EPA's "3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities" is VOLUNTARY guidance helping schools, child care, and states build their own lead sampling/remediation programs. Training: awareness of occurrence, causes, and health effects. Testing: sample at outlets used for drinking/cooking. Taking Action: remediate and communicate results. The revised 3Ts sets NO federal remediation/action level; EPA urges reducing lead to the lowest levels possible (no safe level); states may optionally set a level (e.g., 20 ppb). The 3Ts is the basis WIIN/2107 grantees must follow and the guidance CWSs must give schools under the LCRI. (Sources: EPA 3Ts page; EPA LCRI Schools Fact Sheet.)

Action levels

LCRI (enforceable, for water systems): lead action level = 10 ppb (0.010 mg/L), lowered from the prior 15 ppb. 3Ts (voluntary, for schools/child care): no federal action/remediation level is set by the 3Ts itself; EPA urges reducing lead to the lowest achievable levels (no safe level). States may optionally adopt a remediation level (EPA cites 20 ppb as an example, or another state-chosen value). Caution: 15 ppb is the OLD pre-LCRI action level, not the current 3Ts threshold nor the current LCRI level (now 10 ppb). (Sources: EPA LCRI Q&A; EPA LCRI Improvements page; EPA 3Ts page; EPA LCRI Schools Fact Sheet.)

Lead & Copper Rule timeline

LCRI signed October 8, 2024. Compliance date: November 1, 2027 - CWS public-education and school/child-care sampling obligations begin, and baseline service-line inventory and initial school/child-care lists are due to the state. Lead action level lowered to 10 ppb (0.010 mg/L) from 15 ppb. Lead and GRR service lines generally replaced within 10 years. Elementary schools and child care: minimum 20%/year sampling offered over first 5 years after Nov 1, 2027, then on request; secondary schools on request only. Annual CWS reporting to states begins January 30, 2029. These bind community water systems, not schools directly. (Sources: EPA LCRI Schools Fact Sheet EPA 816-F-24-016, Oct 2024; EPA LCRI Q&A.)

Funding (WIIN Act §2107)

Voluntary School and Child Care Lead Testing and Reduction Grant Program (WIIN Act Sec. 2107): statutory basis SDWA Sec. 1464(d), added by WIIN Act Sec. 2107 (2016), amended by AWIA Sec. 2006 (2018) and IIJA/Bipartisan Infrastructure Law Sec. 50110 (2021). EPA grants to states, territories, and tribal consortia to assist educational agencies and child care programs with VOLUNTARY lead testing; the 2021 amendment added remediation (certified point-of-use filters, plumbing/outlet replacement) as eligible. Grantees must use the 3Ts. EPA cites over $200 million since 2018 (over $105 million to states since 2021 per the LCRI schools fact sheet). A separate Tribal track exists. This is a grant/funding program, NOT a mandate requiring schools to test. (Sources: EPA WIIN Grant page; EPA Grants for Testing Lead page; EPA LCRI Schools Fact Sheet.)

How to find a certified lab

PATHWAY TO FIND A CERTIFIED LAB FOR LEAD-IN-DRINKING-WATER TESTING How drinking water lab certification works (VERIFIED, EPA): - Under the Safe Drinking Water Act, STATES hold primacy and run the certification of laboratories that analyze drinking water. Public water systems must use a state-certified lab, and EPA approves the analytical methods while states manage the certification process itself. EPA does NOT test residential/commercial water on request, and does not run a single national "find a lab" search for drinking water; it routes you to your state program. (Source: epa.gov/dwlabcert; epa.gov/lead/can-i-get-my-water-tested-lead) - EPA's own lead-in-water guidance states: testing is the only reliable way to detect lead (you cannot see/taste/smell it), and "A list of certified laboratories are available from your state or local drinking water authority or on EPA's website." STEP-BY-STEP PATHWAY: 1. Start at EPA's directory of state certification programs (the primary, authoritative entry point): https://www.epa.gov/dwlabcert/contact-information-certification-programs-and-certified-laboratories-drinking-water . This page links to a PDF and to each state's drinking-water lab certification program and contacts. 2. Use the EPA PDF "State Certification Programs Certify Laboratories to Conduct Drinking Water Analyses": https://www.epa.gov/system/files/documents/2023-03/state-cert-programs-certify-labs-to-conduct-drinking-water-analyses.pdf 3. Contact your STATE drinking-water program (or local water authority) to obtain its current list of state-certified labs and ensure the lab is certified for LEAD in drinking water specifically. NATIONAL LOCATORS (cross-state lab search tools), use to confirm/locate accredited labs, then verify state certification: - TNI/NELAP "LAMS" (National Environmental Laboratory Accreditation Management System): searchable by lab name, TNI lab code, location, state, and accreditation body; covers environmental matrices including DRINKING WATER. Search: https://lams.nelac-institute.org/search . NELAP accreditation is delivered through state/AB accreditation bodies (e.g., FL, IL, KS, LA, MN, NH, NJ, NY, OK, OR, PA, TX, UT, VA). NELAP Accreditation Bodies list: https://nelac-institute.org/content/NELAP/accred-bodies.php - A2LA (American Association for Laboratory Accreditation): Directory of Accredited Organizations, searchable by organization/scope, including environmental/water testing scopes. Directory: https://customer.a2la.org/index.cfm?event=directory.index CRITICAL ACCURACY CAVEAT, do NOT use NLLAP for water: EPA's National Lead Laboratory Accreditation Program (NLLAP) accredits labs ONLY for lead in PAINT CHIPS, DUST WIPES, and SOIL, NOT drinking water. Do not present NLLAP (epa.gov/lead/national-lead-laboratory-accreditation-program-list) as a locator for lead-in-WATER labs. NLLAP recognizes accrediting bodies AIHA-LAP, A2LA, Perry Johnson Laboratory Accreditation, ANAB/ACLASS, and International Accreditation Service. Note A2LA appears in both contexts (paint/dust/soil via NLLAP AND, separately, environmental water testing via its general accreditation), so always check the lab's specific scope/matrix. BOTTOM-LINE GUIDANCE FOR SCHOOLS/CHILDCARE: Use a lab that is certified BY YOUR STATE for lead in drinking water. Begin at the EPA state-certification directory, then verify via TNI LAMS or A2LA. Confirm the lab's scope explicitly covers lead in drinking water (not paint/dust/soil).

• EPA, Contact Information for Certification Programs and Certified Laboratories for Drinking Water (state programs directory), Primary authoritative entry point. Links to each STATE drinking-water lab certification program and contacts; states certify labs to test drinking water (incl. lead). Use this first.
• EPA, State Certification Programs PDF (state-by-state lab certification links), EPA PDF listing each state's drinking-water lab certification program; companion to the directory page above.
• TNI/NELAP LAMS, National Environmental Laboratory Accreditation Management System, National searchable directory of NELAP-accredited environmental labs (search by name, lab code, location, state, accreditation body); covers drinking water matrices. Verify the lab's lead-in-drinking-water scope and confirm state certification.
• TNI, NELAP Accreditation Bodies list, List of state/AB accreditation bodies that grant NELAP accreditation (e.g., FL, IL, KS, LA, MN, NH, NJ, NY, OK, OR, PA, TX, UT, VA).
• A2LA, Directory of Accredited Organizations, Searchable directory of A2LA-accredited testing labs and their scopes (includes environmental/water testing). Check the specific scope/matrix for lead in drinking water.
• EPA, National Lead Laboratory Accreditation Program (NLLAP) list (PAINT/DUST/SOIL ONLY, NOT water), CAUTION: NLLAP accredits labs for lead in PAINT CHIPS, DUST WIPES, and SOIL only, NOT drinking water. Do NOT use as a water-lab locator. Included here to prevent misuse.