Lead Testing in Schools: A Study in Planning Ahead for Compliance
Sophie James, Director of Water Quality, California Water Service (NYSE: CWT)
In 2017, the California State Water Resources Control Board’s Division of Drinking Water (DDW) required that water providers start to test for lead in kindergarten to 12th-grade school campuses. Previously, lead testing was only required in residential neighborhoods. However, a recent study from the U.S. Environmental Protection Agency showed that 10 to 12 percent of total lead exposure in young children, who are the most vulnerable population for lead poisoning, comes from drinking water, prompting DDW to act.
Within a short period of time, DDW issued new permit amendments and later a regulation. With the long-standing commitment to protecting its customers’ health and safety, Cal Water worked quickly to put a plan into place to test all 735 schools serving K-12 in its service areas.
The first piece of the puzzle that Cal Water had to figure out was how many such schools it had in its service areas throughout the state. Obtaining all of this data required coordination of the utility’s operations and engineering teams. Once a list of schools was determined, it was time to start communicating with the schools and educating the administrators about the water system and how to ensure the water coming through the plumbing fixtures at their school sites met lead limits. Cal Water had already started proactively planning prior to the new regulatory requirements. Then the State made testing a mandatory requirement through AB746, effective on January 1, 2018. The new law required water providers to conduct lead testing for all public schools by July 1, 2019.
When it comes to protecting public health, it is always best to be ahead of the regulation, than behind it, and truly show your commitment to protecting your customers’ health and safety 
Cal Water’s early planning efforts were influenced by the information emerging regarding the discovery of lead in the water in Flint, MI. Although the plan evolved over several months, the final product consisted of:
• Submitting a list of all schools that needed to be tested in its California service areas;
• Creating a timeline and plan for testing all of these schools;
• Preparing training material for utility workers and school districts;
• Producing introductory brochures and educational materials;
• Developing a sampling plan, including locating up to five high drinking water usage sampling sites;
• Preparing sample kits for sample collection;
• Coordinating testing with support labs/contract labs;
• Tracking sample collection, receipt, and analysis;
• Notifying schools if results were above the 15 parts-per-billion Action Level (AL);
• Scheduling follow-up sampling if water tested is above the AL; and
• Providing guidance on potential corrective actions schools can take to address any exceedances.
Cal Water’s preplanning helped minimize the inherent challenges of implementing and completing testing so quickly; however, the utility was not immune to all hurdles. The mandate came after the fiscal year’s budget had been set, and so the utility needed to find funding sources to be able to provide the free testing services. Staffing resources were also limited, and Cal Water determined that the schools would benefit from having a dedicated water quality expert to solely focus on the testing, which required additional labor. Also, not all schools were rushing to sign up for the testing initially; even though the schools did not incur any testing-related expenses, they ultimately would be responsible for replacing any lead pipes or fixtures on their property. This could create a hardship for some schools that have small facility budgets. Ultimately though, all of the public schools in Cal Water’s service areas did sign up for and completed the testing – as did many private schools, which are not required at this time to do so.
Why should water providers throughout the country care about water quality standards in California? The Division of Drinking Water anticipates that lead testing in schools will be a requirement in the next revision of the Lead and Copper Rule, meaning the testing requirement will become the standard across America. That is why I recommend that other water purveyors start planning for this requirement now. Start identifying schools in your service areas, work on educating the public on these requirements, and start getting resources in place. When it comes to protecting public health, it is always best to be ahead of the regulation, than behind it, and truly show your commitment to protecting your customers’ health and safety.
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