Lead and Copper Rule:
A Quick Reference Guide for Schools and Child Care Facilities that are Regulated
Under the Safe Drinking Water Act
CHILDREN
This document is designed for
schools and child care facilities
that meet the definition of a public
water system and therefore must
comply with the Lead and Copper
Rule (LCR) requirements. The
guidance contained in this
document does not substitute for
EPA's regulations, nor is it a
regulation itself. This reference
guide provides an overview of the
requirements but does not contain
all of the details you will find in the
LCR. Compliance is based on the
actual rule language. States and
local governments can impose
additional requirements.
OVERVIEW OF THE RULE
Schools and child care facilities that have their own water supply and are considered non-transient, non-community
water systems (NTNCWSs) are subject to the Lead and Copper Rule (LCR) requirements.
The LCR was developed to protect public health by minimizing lead and copper levels in drinking water. The most
common source of lead and copper in drinking water is corrosion of plumbing materials. Plumbing materials that can
be made with lead and copper include pipes, solder, fixtures, and faucets.
The LCR established an action level of 0.015 mg/L (15 ppb) for lead and 1.3 mg/L (1300 ppb) for copper based on the
90th percentile level of tap water samples. This means no more than 10 percent of your samples can be above either
action level. If lead or copper levels are found above the action levels, it does not signal a violation but can trigger
other requirements that include water quality parameter (WQP) monitoring, corrosion control treatment (CCT), source
water monitoring/treatment, public education, and lead service line replacement. An explanation of how to calculate
the 90th percentile level is provided on page 3 of this guide.
HEALTH RISKS OF LEAD AND COPPER
Children are especially susceptible to lead and copper exposure because their bodies absorb these metals at higher
rates than the average adult. Children younger than six are most at risk due to their rapid rate of growth. Exposure to
high levels of lead can cause damage to the brain, red blood cells, and kidneys. Exposure to even low levels of lead
can cause low IQ, hearing impairment, reduced attention span, and poor classroom performance. Exposure to high
levels of copper can cause stomach and intestinal distress, liver or kidney damage, and complications of Wilson's
disease in genetically predisposed people.
Because children spend so much time in school and child care facilities and their bodies are developing rapidly, it is
important to provide safe drinking water to avoid health problems linked to lead or copper exposure.
ADULTS
High lead levels in adults have been linked to increased blood-pressure. Pregnant women and their fetuses are
especially vulnerable to lead exposure since lead can significantly harm the fetus, causing lower birth weight and
slowing down normal mental and physical development.
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KEY POINTS
SOURCES OF LEAD AND COPPER IN DRINKING WATER
When lead and copper are found in tap water it is typically due to leaching from internal plumbing materials. If the
water is too corrosive, it can cause lead or copper to leach out of the plumbing materials and enter the drinking water.
The potential for leaching increases the longer the water is in contact with the plumbing components. School water
supplies tend to have extended periods of no water use (e.g., overnight, weekends, holidays, summer) that increase
the likelihood of elevated lead levels at the tap.
LEAD AND COPPER TAP SAMPLING REQUIREMENTS
• "First draw" samples must be collected.
• Samples must be collected after the water has had time to sit in the pipes for at least 6 hours.
• If either action level is exceeded, water quality parameter (WQP) and source water sampling may be required.
• The number of lead and copper or WQP samples collected depends on the daily population served by the school
or child care facility (see Table 1).
• Lead and copper samples must be collected every 6 months, unless the system qualifies for reduced monitoring
(see Table 2).
• Samples for subsequent rounds of monitoring must be collected from the same sites used in the initial round.
Table 1: Lead and Copper Tap and WQP Tap Monitoring
School or Child
Care Facility Daily
Population Served
Number of Lead and Copper
Tap Sample Sites
Number of WQP
Tap Sample Sites
Standard
Reduced
Standard
Reduced
10,001-50,000
60
30
10
3,301-10,000
40
20
501 -3,300
20
10
101-500
10
<100
Table 2: Criteria for Reduced Lead and Copper Tap Monitoring
Can monitor...
If...
Annually The 90th percentile is less than both action levels (ALs) for 2 consecutive 6-month monitoring
periods; or
Optimal water quality parameter specifications are met for 2 consecutive 6-month monitoring
periods and the primacy agency approves.
Triennially The 90th percentile is less than both ALs for 3 consecutive years of monitoring; or
(every 3 years) optimal water quality parameter specifications are met for 3 consecutive years of monitoring
and the primacy agency approves; or
The 90th percentile lead levels are < 0.005 mg/L and 90th percentile copper levels are < 0.65
mg/L; or
The system is deemed to have optimized corrosion control by meeting the copper action level
and showing:
• for 2 consecutive 6-month periods that the difference between the lead 90th
percentile tap water level and the highest lead source water sample is less than the
Practical Quantitation Limit for lead; or
• the highest source water lead level is below the Method Detection Level and the 90th
percentile tap water lead level is < the Practical Quantitation Limit for lead for 2
consecutive 6-month periods.
Once every
9 years
The school or child care facility population is < 3,300, the system meets monitoring waiver
criteria, and a waiver is approved by the primacy agency.
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KEY POINTS
CALCULATING THE 90™ PERCENTILE FOR LEAD AND COPPER
If you collect 5 samples...
If you collect 10 samples...
If you collect 20 or more
samples...
rank the results from the lowest to the highest value, and then average the two
highest results. This value is the 90th percentile.
rank the results from the lowest to the highest value, numbering each from 1 to 10.
The 9th value is the 90th percentile.
rank the results from the lowest to the highest value, numbering each from 1 up
to the number of samples taken. Multiply the number of samples taken by
0.9. The resulting number is the value that is the 90th percentile.
Example calculation: 20 samples x 0.9 = 18. The 18th value in a ranked set of
sample values is the 90th percentile.
COMPLIANCE REQUIREMENTS IF ACTION LEVEL IS EXCEEDED
Four compliance areas must be addressed within certain time frames following an action level exceedance:
• Public education
• Water quality parameter (WQP) monitoring
• Source water monitoring and source water treatment
• Corrosion control treatment (CCT)
Contact your primacy agency in the event of an action level exceedance to ensure you follow the required steps.
Failure to do so may result in a compliance violation.
Public
Education
within 60
Days
When the AL for lead is exceeded, a water system must issue public education print materials (no public education is
required if only the copper AL is exceeded). (See Appendix A for an example public education poster.)
• Display informational posters on lead in drinking water in a public place or common area in each of the buildings
served by the system; and
• Distribute informational pamphlets and/or brochures on lead in drinking water to each person served by the
system.
You have the option of using the alternative mandatory language provided in §141.85(a)(2) or using the original
language now contained in §141.85(a)(1). You do not need State approval before using this alternative language.
Public Education Requirement
Poster
Pamphlet
Compliance
Letter to State
Within 60 days of exceedence1
Every 12 months for as long
as exceedence occurs
Within 10 days after the end of each period
in which public education was required
'Applies first time action level is exceeded, and applies any subsequent time that a system exceeds the lead action level when it is not already
providing public education.
Water Quality
Parameter
Sampling
within same
Lead and
Copper
monitoring
period
Collect water quality parameter (WQP) tap samples.
• See Table 1 for number of samples required.
• WQP samples are collected at taps and at each entry point to the distribution system.
• WQPs include: pH, alkalinity, calcium, and in the initial sample, conductivity and temperature as well. If treatment
is currently installed, other parameters may also be included depending on the treatment type.
• After follow-up monitoring, the primacy agency will set a range of optimal WQPs.
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Entry Point to
Distribution
System
Monitoring
within 6 months
System must:
• Collect samples at each entry point to the distribution system. (You may want to use the same sampling points
designated for chemical sampling - check with your primacy agency.)
• Make a recommendation for source water treatment.
Corrosion
Control
Treatment
KEY POINTS
within 6 months:
within 18 months:
within 24 months:
within 36 months:
Recommend optimal corrosion control treatment.
Complete corrosion control treatment study if required by primacy agency.
Install corrosion control treatment after primacy agencies has determined appropriate
treatment.
Monitor WQP at entry points for 2 consecutive 6-month periods.
COMPLIANCE REQUIREMENTS IF ACTION LEVEL EXCEEDANCE CONTINUES
If the system continues to exceed the AL after installation of corrosion control treatment or source water treatment
there are two additional compliance areas:
• Lead service line monitoring
• Lead service line replacement
Contact your primacy agency for further assistance if installation of corrosion control treatment or source water
treatment does not end AL exceedances.
DEFINITIONS
90th Percentile The highest concentration of lead or copper in tap water that is exceeded by 10 percent of
the sites sampled during a monitoring period. This value is compared to the lead action
level (AL) to determine whether an AL has been exceeded. (See "Calculating the 90th
Percentile" above for instructions.)
Action Level (AL) The concentration of lead or copper in tap water which determines whether a system may be
required to install corrosion control treatment, collect water quality parameter samples,
collect source water samples, replace lead service lines, and/or deliver public education
about lead. The action level for lead is 0.015 mg/L or 15 ppb. The action level for copper is
1.3 mg/L or 1300 ppb.
Corrosion Control
Treatment (CCT)
Water treatment generally in the form of chemical addition meant to reduce the corrosivity
of the water.
Entry Point to the
Distribution System
First Draw Sample
Method Detection
Limit (MDL)
An entry point to the distribution system is a point after any treatment is applied, but
before water reaches the first consumer. Because this location is often used for sampling, it
is ideal to have a dedicated sampling tap which is inaccessible for drinking purposes.
A tap water sample taken after water has been standing motionless in plumbing pipes for a
period of time and is collected without flushing the tap. Approximately 8 hours is an ideal
amount of time to let the water sit before collecting a first draw sample, a minimum of 6
hours is required.
The minimum concentration of a substance that can be measured and reported with 99
percent confidence that the analyte concentration is greater than zero.
Optimal Water Quality
Parameters
Practical Quantitation
Limit (POL)
Water Quality
Parameters (WQPs)
Ranges or minimums set by the primacy agency that indicate a system's CCT is operating
at a level to most effectively minimize lead and copper concentrations at user's taps.
The concentration that can be reliably measured within specified limits during routine
laboratory operating conditions using approved methods. The PQL for lead is 0.005 mg/L.
The PQL for copper is 0.050 mg/L.
A set of water qualities or characteristics used to help systems and states determine what
levels of CCT would work best for the system and whether this treatment is being properly
operated and maintained overtime. WQPs include: pH, alkalinity, calcium, conductivity, and
temperature. If treatment is currently installed, other parameters such as orthophosphate
and silica may also be included depending on the treatment type.
Office of Water (4606)
EPA 816-F-05-030, October 2005
4
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Appendix A
'AD in Drinkin? Water
HEALTH EFFECTS
OF LEAD
Lead is found throughout
the environment in lead-
based paint, air, soil,
household dust, food, certain
types of pottery porcelain and
pewter, and water. Lead can pose
a significant risk to your health
if too much of it enters your
body.
Lead builds up in the body
over many years and can cause
damage to the brain, red blood
cells and kidneys. The greatest
risk is to young children and
pregnant women. Amounts of
lead that won't hurt adults can
slow down normal mental and
physical development of grow-
ing bodies. In addition, a child
at play often comes into con-
tact with sources of lead con-
tamination - like dirt and dust -
thar rarely affect an adult. It is
important ro wash
children's hands
and toys often,
and to try to
make sure they
only put food
in their mouths.
LEAD IN
DRINKING WATER
Lid in drinking water,
although rarely the
sole cause of lead poi-
soning, can significantly increase
a person's total lead exposure,
particularly the exposure of in-
fants who drink baby formulas
and concentrated juices that are
mixed with water. EPA estimates
that drinking water can makeup
20 percent or more of a person's
total exposure to lead.
THE UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY (EPA) and (a)
are concerned about lead in your drinking water. Some drinking water
samples taken from this facility have lead levels above the EPA action
level of 15 parts per billion (ppb), or 0.015 milligrams of lead per liter
of water (mg/L). Under Federal law we are required to have a program
in place co minimize lead in your drinking water by (b)
This program includes:
1) Corrosion control treatment (treating the water to make it less
likely that lead will dissolve into the water);
2} Source water treatment (removing any lead that is in the water at
the time it leaves our treatment facility); and
3) A public education program.
If you have any questions about how we are carrying out the re-
quirements of the lead regulation please call us at (c)
This poster also explains the simple steps you can take to protect
yourself by reducing your exposure to lead in drinking water.
HOW LEAD ENTERS
OUR WATER
Lid is unusual among drinking
water contaminants in that it
seldom occurs naturally in
water supplies like rivers and lakes.
Lead enters drinking water primarily
as a result of the corrosion, or wearing
away, of materials containing lead in
the water distribution system and
household plumbing. These materials
include lead-based solder used to join
copper pipe, brass and chrome-plated
brass faucets, and in some cases,pipes
made of lead that connect houses and
buildings to water mains (service
lines). In 1986, Congress banned the
use of lead solder containing greater
than 0.2% lead, and restricted the
lead content of faucets, pipes and
other plumbing materials to 8.0%.
When water stands in lead pipes
or plumbing systems containing lead
for several hours or more, the lead
may dissolve into your drinking wa-
ter. This means the first water drawn
FOR MORE INFORMATION
YOU CAN CONSULT a variety of sources for additional information:
Your family doctor or pediatrician can perform a blood test for lead and
provide you with information about the health effects of lead. State and local
government agencies that can be contacted include:
• (d) at (e) can
provide you with information about your facility's water supply; and
• (f) at (g) or the
• (h) at (i) can
provide you with information about the health effects of lead.
from the tap in the morning, or
later in the afternoon if the water
has not been used all day, can con-
tain fairly high levels of lead.
STEPS YOU CAN TAKE
to Reduce Exposure to
Lead in Drinking Water
1. FLUSH YOUR SYSTEM. Let
the water run from the tap before
using it for drinking or cooking
any time the water in a faucet has
gone unused for more than six
hours. The longer water resides
in plumbing the more lead it may
contain. Flushing the tap means
running the cold water faucet for
about 15-30 seconds. Although
toilet flushing or showering
flushes water through a portion of
the plumbing system, you still
need to flush the water in each
faucet before using it for drinking
or cooking. Flushing tap water is
a simple and inexpensive measure
you can take to protect your
health. It usually uses less than
one to two gallons of water.
2. USE ONLY COLD WATER
FOR COOKING AND
DRINKING. Do not cook with,
or drink water from the hot water
tap. Hot water can dissolve more
lead more quickly than cold wa-
ter. If you need hot water, draw
water from the cold tap and then
heat it.
3. USE BOTTLED WATER.
The steps described above will re-
duce the lead
concentrations
in your drink-
ing water.
However, if
you are still con-
cerned, you may
wish to use bottled
water for drinking and cooking.
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