Lead and copper toxicity risks are higher for young children and infants. Excessive intake of drinking water that contains lead or copper can result in irreversible health effects. In fact, no amount of lead is safe. This is why EPA developed the Lead and Copper Rule (LCR) to protect public health by controlling lead and copper in drinking water.
EPA has also required community water systems to test drinking water in schools and child care facilities under their Lead and Copper Rule Revisions (LCRR) to better protect young children from lead exposure. Below are the key things you need to know about LCR and LCRR requirements for schools.
NOTE: This guide only aims to provide you with an overview of EPA’s LCR/LCRR requirements. You need to visit EPA’s website for complete details about these rules.
Overview of EPA’s Lead and Copper Rule (LCR)
The Lead and Copper Rule was established in 1991 to reduce exposure to lead and copper in drinking water, specifically by reducing the corrosivity of water. Since the rule’s establishment, it has undergone multiple revisions including the LCRR which we will discuss in the next section. You can find the LCR in the Code of Federal Regulations, 40 CFR Part 141 Subpart I.
NOTE: The LCR is not based on Health Limits but on Treatment Techniques.
EPA Lead and Copper Rule Revisions (LCRR)
On January 2021, EPA issued revisions to the LCR under the Lead and Copper Rule Revisions (LCRR) to further strengthen the LCR. Among the improvements done under this new rule include requiring testing in schools and child care facilities for the first time. (More on this later.)
Lead and Copper Rule Requirements
Who Are Covered by the Rule?
Utilities covered are public water systems (PWSs):
- Community water systems (CWSs)
- Non-transient non-community water systems (NTNCWSs)
NOTE: The LCR applies to water suppliers serving schools and child care facilities including schools/childcare facilities that have their own water supplies.
Drinking Water Lead and Copper Rule in Schools
Schools and childcare facilities mostly get their water from PWSs and must meet the LCR requirements. The LCRR requires public water systems to identify schools and child care facilities they serve and conduct testing for lead and copper. PWSs also need to prepare an inventory of service lines that meet the rule’s requirements by October 16, 2024. The inventory includes:
- Classification of service line materials
- Information sources
- Public accessibility
EPA’s Guidance for Developing and Maintaining a Service Line Inventory which they released in August 2022 aims to guide water systems in their compliance with the LCRR requirements. The guide includes prioritizing field investigations at certain locations by considering vulnerable or environmental justice populations.
“For example, a water system may want to consider prioritizing investigations at locations served by unknown service lines where children are present, such as schools or child care facilities.”– EPA’s Guidance for Developing and Maintaining a Service Line Inventory
In addition, CWSs must also provide educational materials regarding the health impacts of lead as well as sampling results to schools and childcare facilities.
What Is the Maximum Contaminant Level (MCL) for Lead and Copper in Drinking Water?
There is no MCL for both lead and copper. However, EPA set a Maximum Contaminant Level Goal (MCLG) of zero for lead which means no amount of lead exposure is safe. As EPA stated:
“Because lead contamination of drinking water often results from corrosion of the plumbing materials belonging to water system customers, EPA established a treatment technique rather than an MCL for lead.”– EPA, Basic Information about Lead in Drinking Water
Regulations for treatment techniques are specified under the LCR which water systems are required to follow to control water corrosivity.
Lead and Copper Action Levels: What Are the Safe Levels of Copper and Lead In Drinking Water?
The LCR set the following action levels for lead and copper at the 90th percentile:
- Lead: 0.015 mg/L (15 ppb)
- Copper: 1.3 mg/L (1300 ppb)
Violations & Compliance Requirements When Action Levels Are Exceeded
If over 10% of the samples exceed the above values, it is not a violation. However, the LCR requires water systems to take further actions in controlling corrosion (i.e. treatment techniques).
NOTE: Violations can happen if treatment is not done correctly or if samples are not collected properly and not reported.
Treatment Technique Requirements
Below are the additional treatment technique requirements that water systems must do once action levels for lead and copper have been exceeded:
- Corrosion Control Treatment (CCT)
- Source Water Monitoring & Treatment
- Water Quality Parameter (WQP) Monitoring
- Lead Service Line Replacement (LSLR)
- Public Education
CCT involves treating water using specific chemicals to reduce corrosion and make lead less likely to dissolve into the water. Source water monitoring and treatment involves monitoring water at entry points, making treatment recommendations, and installing source water treatment. LSLR and public education are done if the sampling results still exceed the lead and copper action levels after conducting a CCT and doing source water treatment.
NOTE: Check your local government and state for additional requirements that you must follow.
Other Important Things to Know About LCR and LCRR
Sources of Lead and Copper in Drinking Water: How Do Lead and Copper Get Into Drinking Water?
Lead and copper can enter drinking water primarily due to corrosion of internal lead plumbing materials especially if the water is highly acidic or has low mineral content. These materials include:
- Other bronze, brass, chrome-plated brass, or galvanized plumbing materials
The amount of lead in drinking water increases when water supplies in schools are not used for extended periods of time such as during holidays, summer, and weekends.
Health Effects of Lead and Copper in Drinking Water to Children: Why Is Lead a Concern for Schools?
“EPA and the Centers for Disease Control and Prevention (CDC) agree that there is no known safe level of lead in a child’s blood.”– EPA, Basic Information about Lead in Drinking Water
Children under 6 years of age, formula-fed infants, and pregnant women have the highest risk of developing health complications related to lead and copper exposure. Amounts that won’t hurt adults can cause irreversible damage to growing bodies.
Also, children’s bodies absorb lead and copper at higher rates compared to adults. Moreover, water in schools and childcare facilities often sits overnight and even longer which increases the amount of lead in drinking water.
The health impacts of lead and copper on children include the following:
- Brain damage which leads to low IQ and poor performance
- Behavioral disorders such as reduced attention span
- Damage to red blood cells
- Kidney damage
- Liver damage
- Hearing impairment
- Intestinal and stomach distress
- Cardiovascular disease
Since the damage caused by exposure to lead and copper is irreversible, it is crucial to provide safe drinking water in schools and childcare facilities.
Health impacts on adults include:
- Liver disease
- Increased blood pressure
- The chronic effects of lead and copper exposure are mostly silent. Thus, most poisoned children don’t show symptoms and most cases go untreated and undiagnosed.
- Drinking water is rarely the cause of lead poisoning but can increase an individual’s total lead exposure. Common causes of lead poisoning in children include exposure to lead-contaminated dust, air, and soil along with lead-based paint.
How to Calculate the 90th Percentile
Calculating the 90th percentile will depend on how many samples you are required to collect. List down the results in ascending order and follow the steps below:
Less Than 5 Samples
- The 90th percentile is the average of the fourth and fifth highest samples.
More Than 5 Samples
- Number each value from 1 to the total number of samples.
- Multiply the total number of samples by 0.9.
- The 90th percentile is the value corresponding to the product you just calculated.
Example: 10 samples x 0.9 = 9. The ninth value is the 90th percentile.
EPA Lead and Copper Rule 2024: Lead and Copper Rule Improvements (LCRI)
After EPA has evaluated the LCRR and concluded that it needs further improvements, the agency is intending to promulgate the Lead and Copper Rule Improvements (LCRI) prior to October 16, 2024, which is the compliance date for the LCRR. This new rule aims to support the development of actions to reduce lead in drinking water. EPA is still undergoing multiple consultations and engagements before proposing the new rule.
Tips to Reduce Lead Exposure in Schools
Lastly, below are a few tips you can follow to reduce lead and copper exposure in schools:
- Running the water for at least 30 seconds before your first use
- Using the cold-water tap for drinking and cooking
- Flushing your piping system
- Using bottled water instead
- Repairing your plumbing system
NOTE: Boiling won’t remove lead in the water.
- New Rule for Lead-Contaminated Dust Will Help Protect Children & Set New Industry Standard
- Lead Paint in Homes & Commercial Buildings: Effective Identification, Remediation, and Dangers
Improvements under the Lead and Copper Rule Revisions (LCRR) include the following:
– Finding more lead sources in drinking water through science-based testing protocols
– Testing in childcare facilities and schools
– Driving more lead service line replacements
– Creating a lead service line (LSL) inventory
– Improving public education
The Lead and Copper Rule (LCR) established action levels instead of Maximum Contaminant Levels (MCLs) for lead (0.015 mg/L) and copper (1.3 mg/L). If more than 10% of the samples exceed these values, the water system must take additional actions to control corrosion. The treatment techniques include the following:
– Corrosion Control Treatment (CCT)
– Source Water Monitoring & Treatment
– Water Quality Parameter (WQP) Monitoring
– Lead Service Line Replacement (LSLR)
– Public Education
Contact RPF Environmental for Professional Lead Sampling & Testing in Schools
Lead sampling and testing in schools is a complex process that should be done by certified professionals like RPF Environmental. Samples must be taken correctly at the right locations to ensure the accuracy of the results and prevent violations.