BTs: TRAINING, TESTING, TAKING ACTION
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TESTING
Module 4: Developing a Sampling Plan
Understanding the Sampling Procedures
Communication Plan: Before you begin sampling, it is important to engage
with the community and develop a plan for how to communicate
throughout the sampling process.
The Who, What, and When of Sampling
Who should collect 3Ts Samples?
What is the recommended sample volume?
EPA recommends the use of small samples (e.g., 250-mL)
because a smaller sample represents a smaller section of
plumbing, which can help you to identify the sources of lead at
an outlet (e.g., fixture, interior plumbing, or water entering the
school). A smaller sample is also more representative of the
amount of water consumed per serving.
What are the recommended types of samples?
First-draw samples
First-draw samples are typically collected in the morning at outlets that are used for drinking or cooking, after
the water has been sitting still the night before. Begin collecting the sample immediately after turning on the
faucet or valve, not allowing any water to spill. EPA strongly recommends that schools collect first-draw
samples from all fixtures used for consumption and prioritize sampling from high-risk fixtures.
Flush Samples
Flush samples are taken after water has been running from the fixture for a pre-determined length of time.
These types of samples are used in Step 2 (described in the Conducting Sampling section of the 3Ts). Flush
samples can be used to determine if lead is coming from the fixture itself or from interior plumbing.
v>EPA
AND DRINKING WATER
Office of Water (4606M)
EPA 815-F-18-017
October 2018
It is important that water samples be collected properly. Certified laboratories chosen to analyze samples may
provide specialists to assist with sample collection. If the laboratory is not supplying someone to sample, be
sure to identify an individual who is adequately trained to collect lead samples to help avoid sampling errors. It
is useful to ask for references to confirm that individuals are qualified to test for lead in schools and child care
facilities. Some state drinking water programs or public water systems may provide both services, although
there is no federal requirement that they do so.

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TESTING
BTs: TRAINING, TESTING, TAKING ACTION
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Sequential samples
Sequential samples involve collecting a series of water samples at a single fixture, without flushing beforehand
or running the water between samples. This sampling procedure is another method used in a Detailed Fixture
Evaluation described in Appendix D, to sample multiple sections of plumbing,
When should samples be collected?
Collect all water samples before the facility opens and before any water is used. Ideally, the water should sit in
the pipes unused for at least 8 hours but not more than IS hours before a sample is taken. However, water
may be more than 18 hours old at some outlets that are infrequently used. If this is typical of normal use
patterns, then these outlets should still be sampled. Make sure that no water is withdrawn from the outlets
prior to their sampling. Remember not to use the facilities' restrooms or sinks that morning prior to sampling.
Unless specifically directed to do so, do not collect samples in the morning after vacations, weekends or
holidays because the water will have remained stagnant for too long and will not represent the water used for
drinking during most of the days of the week. See Establishing Routine Practices to learn ways to improve
water quality throughout the year and after long breaks.
When should I take action?
There is no safe level of lead for children. EPA encourages schools to prioritize remediation efforts based on
lead sample results and to use the steps in the toolkit to pinpoint potential lead sources to reduce their lead
levels to the lowest possible concentrations.
Before sampling, facilities should establish a plan on how they will respond to their sample results to protect
the school and child care facility population from lead in drinking water. This may be dependent on a variety
of factors (e.g., age of plumbing, population, water corrosivity, available resources, and other school and child
care program priorities). EPA recommends that you prioritize remediation of drinking water outlets with the
highest lead levels.
Make sure to also check with your state and locai health department. They may have guidance or even
requirements that include a lead remediation trigger.
Note: EPA's Lead and Copper Rule (LCR) establishes a lead action level of 15 parts per billion (ppb) for
water systems and facilities that have and/or operate their water source (e.g., own their own well). If the
90th percentile lead level concentration of tap samples exceeds the 15 ppb action level, water systems
must take additional actions, such as optimizing corrosion control, public education and lead service line
replacement. The action level for lead is not a health-based standard and is based upon EPA's evaluation of
available data on the ability of corrosion control to reduce lead levels at the tap. The action level is a
screening tool for determining when certain treatment technique actions are needed.
Don't forget to maintain a record!
Recording sample information is critical to tracking and managing
water quality year-over-year. Make sure to note sampling locations
and sampling procedures.

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