Lead in School Water

The Flint, Michigan, water crisis this winter brought newfound attention to lead-poisoning and water quality. A tainted water source left untreated for corrosive properties and contaminant levels lead to twice as many children been diagnosed with high lead blood concentrations and associated health problems.

The Associated Press investigated the issue further and found that the water quality crisis was not limited to Flint, MI. The Associated Press (AP) completed a comprehensive review of U.S. Environmental Protection Agency (U.S. EPA) lead test records and found that nearly 1,400 water systems serving 3.7 million people in 49 states have exceeded permissible lead levels since 2013. Reoccurring exceedances across systems of all types and sizes demonstrate that the problem is ongoing and widespread.

The results of the review, which were first reported by USA Today, also uncovered an unsettling pattern of high lead levels in school water systems that have, for many years, gone unaddressed.

In the wake of these results and the Flint, Mich., crisis, schools across the nation must turn their attention to plumbing and answer the question: are our children drinking lead-contaminated water at school?

How did we get here?

We’ve known that lead exposure is bad for a long time now. So we also probably thought that most lead hazards had been eliminated years ago. But that’s not necessarily the case.

Lead-containing plumbing products, among others, remained on the market for years after we knew lead was bad for us. Surprising? Maybe. But consider a few details and maybe the fact that we’re finding lead in school water isn’t so surprising after all.

First of all, not all lead and brass pipes have been removed from schools. They should have been, but spotty enforcement and lenient regulations on lead concentrations in plumbing products meant that lead-containing pipes were still being installed into this century (more on that later).

And then you also have to consider the budget and staffing issues that schools face.

Tight budgets mean fewer staff to maintain facilities and less money for voluntary upgrades and testing. Not to mention the fact that schools have not been held directly responsible for their water quality in the past.

And regardless of budget concerns, many schools have put off voluntary lead testing because it’s thought that it’s just better to not know. What if those test results come back with bad news? You’ll be forced to spend lots of money (that you probably don’t have in your budget) to fix a problem that no one had noticed to date.

Of course we want to provide the safest possible environments for our children. But with tighter budgets and higher standards, voluntary plumbing upgrades and testing often get pushed to the bottom of the priority list.

The cumulative effects of those delays have just now been revealed in the aforementioned review that reported high lead leaves in 278 water systems owned and operated by schools and day care facilities in 42 states.

Why do we care about lead in school water?

Aside from the fact that lead is a known human toxin, here are a few reasons we care about lead in schools, specifically:

Lead impairs development

Lead-exposure has more lasting and serious effects on children’s bodies and brains because they are still developing.

Children spend much of their early lives at school

School water serves as the main source of drinking water for children during most of the week. Regular and constant exposure at school would put children at an increased risk for lead poisoning as the toxin accumulates in their bodies.

No amount of exposure is safe

No level of lead exposure, even below the EPA’s ‘permissible level’ has been deemed safe for children. This is partly because lead accumulates in the body for months and even years, leading to development issues, damage to organs and lead poisoning.

It’s a widespread problem

Schools across the country have failed water quality tests with levels well above permissible levels for lead. The fact that so many school water systems nationwide have failed lead tests speaks to the magnitude of the problem.

Not knowing is not an option

If parents are concerned about lead in schools, they’re going to want to know if their children’s schools are testing their water. If the answer is no, it’s an uphill battle convincing parents, and the general public, that their children are adequately protected at school. (And that’s if nobody decides to sue.)

The Science of Lead Exposure

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How does lead contaminate school water?

Most urban and suburban schools get their water from a municipal public water utility, while schools in more rural areas commonly use private wells. These public water utilities and well providers are required to monitor their water for lead and remove contaminants under the EPA’s Safe Water Drinking Act.

Almost always, lead contamination doesn’t occur until after water leaves the public water utility or well

And comes in contact with:

1. Lead or brass supply lines between the water source and building, or
2. Lead or brass pipes and fixtures inside the facility.

Yes, that means that lead contamination is pretty much always due to conditions on school property.

According to the EPA, the riskiest plumbing features include:

• Lead pipes and solder. (These were commonly used until 1986.)
• Faucets, valves and other plumbing components made of brass.

In schools, lead water-cooler coils and linings, and leaded-metal fountains and taps pose a particular risk for contamination.

Factors that increase risk for lead leeching

Corrosion plays a huge role in how much lead leaches into water. Corrosion occurs when chemical and physical interaction between water and plumbing components cause pipes and fixtures to deteriorate and release elemental components into the water supply.
Water that is ‘soft’ or acidic can lead to higher corrosion tends to be more corrosive than hard water with higher pH. Other factors that contribute to corrosion include:

• water velocity,
• temperature,
• chlorine levels,
• alkanity,
• the age and condition of plumbing fixtures,
• water stagnation in pipes, and
• contamination by bacteria, dirt and other contaminants.

Water stagnation is also of special concern for schools because many facilities have intermittent water use on weekends, during the summer and other academic breaks. Standing water in pipes can lead to much higher concentrations of lead because it has more time leach into water from the pipes. This was the issue for one Omaha-area high school whose water tests came back positive for lead.

Finally, waterborne minerals will often form a protective biofilm inside pipes that protect water from direct exposure to lead pipes. Activities like school renovations, plumbing changes or adjustments to water treatment can dislodge these biofilms and cause lead levels to spike when water runs through the newly exposed pipes.

Lead Risks in Rural Communities

One surprising finding of the AP review was that the majority of water systems who tested above the EPA’s action level for lead tended to be smaller water systems serving smaller communities. In fact, 93.3% of systems with excessive lead levels served between 1,000 and 3,000 people, while 4.9% of systems served 3,000 to 10,000 people.

It’s hard to determine why the size of the water system made a difference in these cases, but a range of factors could have contributed, including limitations in control over water treatment, system maintenance gaps and slow updates to plumbing fixtures. Challenges related to the makeup of local water sources could play a role as they did in Flint, Mich.

Schools in smaller communities who provide their own water from a private well should pay special attention to information to EPA testing regulations, below, as water source providers fall under different jurisdiction than many urban schools.

Lead Risks in Omaha

Lead Tests

Omaha’s Metropolitan Utilities District (MUD) provides over 200,000 customers 90 million gallons of water every day. According to the District, Omaha’s water meets (or exceeds) all federal and state standards for safe drinking water and has done so consistently for years. http://www.mudomaha.com/water

MUD checks its water for lead monthly, including untreated water from its source, treated water at its treatment plants and water in its water mains. The Utility reports that none of these tests have come back showing lead exceedances. http://www.mudomaha.com/news/mud-water-meets-all-federal-and-state-standards-safe-drinking-water

The U.S. EPA and Nebraska Department of Health and Human Services (DHHS) require M.U.D. to test for lead and copper every three years, with the next round of tests scheduled to start in the summer of 2016.

Water Treatment

MUD notes that it treats its water with anti-corrosion chemicals to reduce the chance that pipes will break down and release toxins into the water.

Anti-corrosion treatment is essential to good water quality and turned out to be key factor in the Flint, Mich., water crisis. Apparently officials in Flint did not add anti-corrosion chemicals to an already questionable water source, which allowed excessive lead to leach into the water.

Natural Water Properties

Relative to the East Coast, Nebraska’s water is thought to be favorable for reduced lead leaching. Nebraska’s water is naturally “hard” or high in minerals which helps protect pipes from corrosion. Minerals also tend to form a film inside pipes that protect water from exposure to lead pipes.

Lead Pipes

Water almost always leaves treatment plants and water mains free of contamination. It’s usually not until the water enters the property’s service line or plumbing system that lead contamination occurs.

The property owners owns and is responsible for the the repair and replacement of their own service lines. Prior to 1950, many of these service lines were made from lead. MUD records estimate that 15,428 (7.5%) of its 207,026 customers have service lines made from lead and approximately 19,109 (9.2%) service lines are made of unknown materials and can’t be ruled out as having lead. Most remaining service lines are thought to be made of copper.

Specific advice for limiting lead exposure in homes and buildings built before the 1950s can be found on MUD’s website.

Children and Lead Exposure

How are children exposed to lead at school?

Children are most often exposed to lead at school when they drink water from drinking fountains or tap water from faucets. They can also consume lead if school meals are prepared with tap water contaminated by lead.

According to the EPA, contaminated drinking water is responsible for approximately 20 percent of lead exposure for humans. However, drinking water can make up 40 to 60 percent of exposure for babies fed formula made with contaminated tap water.

Aside from tap water, deteriorating lead paint and contaminated soil are the main sources of lead exposure and poisoning in the United States.

Why is lead exposure more harmful for kids?

Children ages 6 and under are at the highest risk for lead exposure. Here are just a few reasons why:

1. Frequent hand-to-mouth activity means that young children more likely to be exposed to and ingest lead.
2. Infants who are fed formula made with tap water have a significantly higher risk for exposure to lead.
3. The growing bodies of children and infants absorb more lead than adult bodies.
4. Children’s nervous systems are very sensitive and exposure to lead and seriously disrupt development.
5. Lead exposure is most harmful to developing fetuses in women who are pregnant.

Lead Poisoning

Lead poisoning can occur when lead builds up in the body over a period of months or years. Anyone can be affected by lead poisoning, but children under 6 years are especially vulnerable. Information on symptoms of lead poisoning in children and adults can be found on the Mayo Clinic’s website.

Lead Legalese

Who regulates lead in drinking water?

The U.S. EPA is tasked with ensuring safe drinking water from the nation’s public water supplies. Here are a few key milestones in the agency’s quest for safe drinking water.

1974 Safe Water Drinking Act

Congress passed the EPA’s Safe Water Drinking Act (SWDA) in 1974 to regulate the public drinking water supply. Under the SWDA, the EPA has set maximum allowable limits for over 90 water contaminants, including lead. They have also defined specific measures for controlling lead in water intended for consumption.

1986 SWDA Lead Ban

Congress amended the SWDA in 1986 to include a ban on any pipes, solder or flux that were not considered “lead free”. At the time, the definition of “lead free” meant that solder and flux could contain no more than .2% lead and pipes could not contain no more than 8 percent lead.

1988 Lead Contamination and Control Act (LCCA)

The goal of this act was to reduce lead exposure and associated health risks. Schools were a focus, with requirements for lead monitoring and reporting in schools and plans to replace drinking water units that contained high levels of lead.

While many lead risks in schools could have been eliminated at this time, these regulations were generally poorly enforced, if at all. The EPA published a document called Lead in School Drinking Water, but there was no federal oversight to ensure that schools followed the requirements and recommendations outlined in the document.

Poor enforcement might have been good news for school budgets in the eighties, it also makes it unlikely that all lead-laden plumbing and water fixtures were actually removed from schools.

1991 Lead and Copper Rule

The Lead and Copper established new requirements for public water suppliers to monitor their drinking water for lead. If lead or copper are found at unsafe levels, public water suppliers are supposed to treat water for corrosion and test drinking water at individual residences for lead.

Only Public Water Systems (PWSs) fall under the EPA’s jurisdiction. A PWS is defined as a system that provides water for consumption to an average of at least 25 individuals a day using its own water source (e.g. a well, treated river water, etc.)

This means that many rural schools who provide their own water from a private well are considered PWSs and are required by the EPA to test their drinking water for lead.

However, most schools do not fall under EPA jurisdiction because they do not provide water from their own source. Instead, they are served by PWSs owned by a city, town, or other entity. So while the city or town has to test their PWS water for lead, the schools those PWSs serve are off the hook for lead testing.

So haven’t lead pipes been outlawed for decades?

Yes. And no.

Remember that Lead Ban from 1986. Sounds great. But at the time, “lead free” meant that flux and solder could contain less than 0.2% lead and plumbing pipes could still contain up to 8% lead. Not exactly “lead-free”.

It wasn’t until Congress passed the Reduction of Lead in Drinking Water Act in 2011 that the permissible levels for “lead free” plumbing products were lowered to a respectable .25% weighted average. (When determining the weighted average, lead components are given more or less “weight” on the average based on how likely that component is to affect lead levels.) More information on lead-free certification can be found here.

In sum, schools and day care facilities built before 1986 likely contain unfavorable levels of lead in their pipes and fixtures. But even newer facilities built within the past 10 years are not totally safe because plumbing hardware often contained up to 8 percent lead through 2011.

Are schools required to test for lead?

The U.S. EPA requires that public water sources test their water for lead and copper under the 1991 Lead and Copper Rule. There are about 10,000 schools (or 10 percent of schools) that fall under this jurisdiction because they provide their own water from a private well. As such, they must test their facility’s drinking water for lead.

But the other 90 percent— approximately 90,000 schools across the nation—and an additional 50,000 child care facilities source their water from a PWS owned by a city, town or other entity.

So while the EPA requires that the PWS test for lead, the schools and daycares that receive that water are not required to test their own facilities for lead. As a result, many schools and daycares have never been tested for lead and any testing that does occur is purely voluntary.

Should schools test for lead, even if they’re not required to?

If lead testing isn’t required, schools can find many reasons not to.

For most, budget is a main concern. And oftentimes it’s thought that not testing and not knowing is better than dealing with unfavorable test results.

Even though many schools are not regulated by the U.S. EPA as far as testing goes, they still need to provide safe drinking water for students and staff. And since the the source of lead-contamination is usually facility-related, schools should seriously consider testing their water to find out if there’s a problem in their facilities so they can solve it.

While student health is obviously the ultimate reason to sample, liability is a consideration as well. Lead issues will continue to make their way into headlines and parents will always ask questions. If you’ve been proactive and tested your water, you’ll be able to hand over your test results and move on.

If not, it’ll be an uphill battle convincing parents and other interested parties that lead problems are being taken care of, even after corrective action has been taken.

How can you protect students from lead exposure?

• Test your facility’s water for lead.
• Notify parents, staff and other relevant parties if lead levels at or above 15ppb (parts per billion) are found.
• Find out if your school’s plumbing system or service line are made of lead.
• Remove and replace lead-containing pipes and fixtures if any are found.
• Use filters on faucets.
• Avoid using water softeners in your facility.
• Commit to regular maintenance of your school’s plumbing systems.
• Avoid stagnation by running taps and flushing toilets during breaks.
• Provide bottled water or water coolers for students to drink from.

What’s next?

1. If in doubt, get your school’s water tested for lead. As many schools have discovered, not knowing is not better. If lead test results come back at or above the action level (15 ppb), take proper actions to ensure compliance with EPA regulations, including notifying relevant parties and replacing plumbing components.
2. Check out the E.P.A.’s Guidance and Tools for improving water quality in schools.
3. Let us know if you have any questions. We can always be reached at 1-800-828-8487 or info@amienvironmental.com.

QUICK FACTS:

• Nebraska and Iowa are pretty lucky as far as water goes. We have lots of natural minerals to coat our pipes and reduce lead leaching.
• 7.5% of M.U.D. customers have lead or partial-lead pipes.
• Another 9.2% of M.U.D. have pipes whose composition may include lead.
• The action level for lead is 15 parts per billion (ppb).
• Children under 6, infants and pregnant women have the highest risk for lead-related health problems.
• The human body cannot tell the difference between lead and calcium.
• Lead pipes account for 20 to 40 percent of lead exposure.
• No level of lead exposure has been found safe for humans.
• The U.S. EPA is tasked with ensuring safe drinking water from the nation’s public water supplies.
• Public drinking water is regulated under the U.S. EPA’s 1974 Safe Water Drinking Act (SWDA).
• Approximately 90,000 schools (or 90%) and 50,000 child care facilities are not regulated under the SWDA.

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