U.S. EPA 3Ts Program Training, Testing & Taking Action Plan Builder


U.S. EPA 3Ts Program

Training, Testing & Taking Action Plan Builder

Plan eBuilder - Interactive Tool to
Build an Implementation Plan for
Testing and Reducing Lead in
Drinking Water in Child Care Facilities

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Disclaimer

This guide is a product of the voluntary program of the U.S. Environmental Protection Agency
(EPA) STsfor Reducing Lead in Drinking Water in Schools and Child Care Facilities-Training,
Testing, and Taking Action Approach.

EPA's 3Ts program is nota federal requirement under the National Primary Drinking Water
Regulations. Therefore, this guide is not intended for use by public water systems that are
subject to compliance under the Lead and Copper Rule Revisions orother National Primary
Drinking Water Regulations under the Safe Drinking Water Act (SDWA).

The3Ts program approach is voluntas and provides tools and informational materialsfor

schools, child care facilities, states, territories, and Native American Tribes to implement lead
testing programs in drinking water, at their discretion.

This document does contain overviews of federal regulatory requirements concerning lead in
drinking water that apply to public water systems. EPA has made every effort to ensure the
accuracy of the discussion in this guidance, in the event of a conflict between the discussion in
this document and any statute or regulation, this document would not be controlling.

The general description in this document does not substitute for any law or regulation. Many
states (or tribes) and localities have different, more stringent requirements than EPA's, some of
which may apply to schools and child care facilities even if they are not a public water system.

Therefore, schools and child care facilities should not rely solely on this guidance for that
compliance information.

This document does not impose legally binding requirements on EPA, states, or the regulated
community.

This document does not confer legal rights or impose legal obligations upon any member of the
public.

Office of Water (4606M)
EPA- 816-B-220-02
June 2022

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INTRODUCTION

jjgi I'ji^

First: Download the Plan Builder!

Before beginning, to ensure inputs are saved, download the Plan Builder as a PDF file and save it to your
computer or shared network location. The Plan Builder is designed to be used with a desktop PDF viewer
such as Adobe Acrobat or Adobe Reader.

GETTING STARTED

.TAKE .ACTION

iTAKEltWITH-YQll!-

Important: Ifvou are a small child care facility, school, tribe, or another facility with 10 or fewer water
outlets performing lead testing and/or remediation for drinking water, this 3Ts Plan Builder is for
you. Use the3Ts Program Plan Builder for Schools if vour facility has more than 10 water outlets.

EPA's 3Ts Program approach for reducing lead in drinking waterfollows three key steps:

¦ Training child care staff to raise awareness of the3Ts Program, the potential causes and
health effects of lead in drinking water, and how to sample and testfor lead.

¦ Testing for lead in drinking water in child care facilities to identify potential lead problems.

¦ Taking Action to reduce lead in drinking water through short-term and/or long-term
measures.

How to Use the Pian Builder

This Plan Builder will walk you through five sections to create your 3Ts Program plan:

1. GETTING STARTED

2. COMMUNICATF

3. TRAINING

4. TFSTING

5. TAKING ACTION

The Plan Builder was adapted from EPA's 3Ts for Reducing Lead in Drinking Water Manual. Toolkit.

and associated documents (e.g.. 3Ts Checklist). For full details on the3Ts Program, including
definitions of terminology (3Ts Manual Appendix A), refer to the3Ts Toolkit at the following URL:
https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water-toolkit.

Additional documents are hyperlinked throughoutthe Plan Builder for your reference as you work
through the document.

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INTRODUCTION

FIRST: Download the Plan Builder!

Before beginning, to ensure inputs are
saved, download the Plan Builder as a PDF
file and save it to your computer or shared
network location. The Plan Builder is
designed to be used with a desktop PDF
viewer such as Adobe Acrobat or Adobe
Reader.

Important Notes

• Users do not have to complete the Plan Builder in
a single session as progress can be saved in the
downloaded PDF.

• Users are encouraged to walk through the steps in
order, as each provides important context for
future steps.

• You can use the checklist below to track progress
through the document noting which sections have
already been completed.

Elements of the Plan Builder
Tables and Text Entry Boxes

Each section provides prompting questions and step-by-step guidance to help users make decisions to
build a 3Ts plan. Tables and text boxes containing default suggested text can be overwritten or deleted.

When working through this document, several of the form fields will have "tooltips" that will appear when
you hover over them. These tooltips will provide additional information to help build your plan. Tooltips
are denoted by this symbol: ®.

Completion Checklist

TO-DO: To help you keep track of your progress, check the box after you complete each section of the

Plan Builder.

~ Introduction 1

~ My Getting Started Plan 4

~ My Communications Plan 10

~ My Training Plan 12

~ My Testing Plan 18

~ My Taking Action Plan 26

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INTRODUCTION

Instructions for Printing the Plan Builder

This entire document is intended to be printed for easy reference to your lead reduction implementation
plan. Complete the following steps to print all plans, including the sum maty pages at the end of the
Builder titled "Take Action: Take It With You".

•	In your toolbar - elicit,[File],

•	Click [Print] and ensure under [Pages to Print] that "AH" is selected.

•	Click [Print], The entire document will print to your selected printing device.

TAKE ACTION: TAKE IT WITH YOU!

At the end ofthis Builder,your responses from theTakingAction chapter will beauto populated into
summary pages titled "Take Action: Take It With You Print and use for a quick reference of your
planned actionswhen lead isdetected in your school's drinking water.

Note: ifchanges are needed, make them in theTakingAction chapterto re populate the summary
pages of Take It With You!

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GETTING STARTED

Build a 3Ts Program

Get started by assembling your team, establishing
recordkeeping practices, and coordinating with your state
drinking water program regarding local regulations.

Assemble
1 ^ Your Team

Establish

Recordkeeping

Practices

identify State,
Tribal, and Local
Regulations

Let's get
started!

Create an

Overall

Schedule

A

Mi*

I!

STEP 1: AssembleYourTeam (3Ts Module 1)

Depending on your facility's size and resources, you may have one person responsible for several
program activities.

STEP 1A: Identify Program Leads

Designate your 3Ts Program and Deputy Program Leads. The Program Leads coordinate the design,
implementation, and execution ofyour3Ts Program.

Getting Started Table 1: Identifyyour 3Ts Program Lead(s).

3Ts Program Administration Lead Contact Information

3Ts Program Lead

3Ts Deputy Program Lead

Name:



Name:

Phone Number:



Phone Number:

Email:



Email:

S TEP IB: Identify Internal and External Stakeholders

•	Internal stakeholders include individuals and groups who may approve, support, or fund aspects
ofyour3Ts Program as well as those who have current job roles that align with protecting the
health of your facility community. Internal stakeholders may include:

¦	Principal/Director/Owner	¦ Parents

¦	Custodial/Facilities Staff	¦ Local Plumbing and Construction

¦	Cafeteria Staff	Contractors/Supplier

¦	Teachers

•	External stakeholders can help operate and communicate aboutyour3Ts Program.
UpdateTabie2 regularly and make it available to all team members for when a quick
response is necessary.

3Ts for Reducing Lead in Drinking Water: Plan Builder	4 | 3age

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GETTING STARTED

Getting Started Table 2: Create a contact list of your external stakeholders.

External Stakeholder Contact Information

State Drinking Water Program

Local Public Health Officials

Name:

Phone Number:

Email:

State Department of Education

Local Public Water System (PWS)/Water Supplier
(if applicable*)

Name:

Phone Number:

Email:

State Department of Health

Media

Name:

Phone Number:

Email:

*Note - if you are served by a groundwater weii and not a local PWS, contact your state drinking water
program for assistance instead.

STEP 1C: Assign Communication Roles

• Identify individuals to communicate to the public a bout your 3Ts Program activities. Individuals could
include members of your child care community, local professionals, and public leaders.

Getting Started Table 3: Fill in the table below to identify your Communications Team.

Communications Team Roles and Responsibilities

Communications Team Lead: acts as the main point of
contact to ensure the accuracy and consistency of public
information. The lead coordinates communications activities,
make announcements, and keeps the 3Ts Team up to date as
the program progresses.

Name:

Phone Number:
Email:

Public Relations Contact: monitors and responds to
questions via email or phone. Helps utilize existing resources,
such as a website, newsletter, or larger announcements.

Name:

Phone Number:
Email:

Communication of Health Risks Contact: works with your
health department to communicate lead health risks and
information about blood lead testingforchildren to
stakeholders.

Name:

Phone Number:
Email:

STEP ID: Assign Training Roles

• You will need to train your team members and stakeholders about the health effects of lead, its effect
on children, and aspects of your 3Ts Program. It may be necessary to train your staff on how to take
drinking water samples.

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GETTING STARTED

Getting Started Table 4: Fill in the table to identify key Training Team members.

TrainingTeam Roles and Responsibilities

TrainingTeam Lead: acts as the main person in
charge ofyourtrainings including logistic
activities (e.g., location, schedule).

Name:

Phone Number:
Email:

Other team members: could lead trainings. Consider using internal staff, consultants, state and local
agency contacts, or laboratory staff for the various trainings.

Trainerl

Trainer 2

Name:

Phone Number:

Email:

STEP IE: Assign Testing Roles

• Involve knowledgeable and experienced individuals (such as consultants, laboratories, or other
partners) to help design a comprehensive testing plan and conduct testing.

• Who conducts testing may depend on whether the certified laboratory also provides specialists to
assist with sample collection. If certified laboratory representatives or consultants are used, ensure
that they have experience in conducting lead testing for drinking water.

• Consider designating a person to serve as the Testing Team Lead for testing and follow-up activities.

Getting Started Table 5: Fill in the table below to identify key team members for developing and executing

the testing portion of your plan.

TestingTeam Roles and Responsibilities

TestingTeam Lead: designsyoursampling methodology,
serves as the point-of-contact for your testing efforts,
coordinates sampling and testing activities, and informs the
3Ts Program Lead of the testing result activities.

Name:

Phone Number:
Email:

Sample Collector: collects samples and coordinates the
sampling schedule. This may be an employee of the certified
laboratory you work with.

Name:

Phone Number:
Email:

Sample Shipper: ensures that samples are labeled, stored
properly, and shipped to the testing laboratory correctly.

Name:

Phone Number:
Email:

STEP IF: Assign Taking Action Roles

• Work closely with maintenance staff and plumbers who make repairs to your facility's water
infrastructure to identify and evaluate remediation options for your facility, ensure that chosen
remediation options will reduce lead in water, understand the benefits and considerations associated
with each remediation option, and select a remediation provider.

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GETTING STARTED

Getting Started Table 6: Fill in the table below to assign key team members for developing and
implementing remediation plans.

Taking Action Team Roles and Responsibilities

Taking Action Team Lead: acts as the main person in
charge of theTakingAction portion ofyour3Ts Program
and coordinates theTakingAction Team's efforts.

Name:

Phone Number:
Email:

Head of Building Maintenance/Custodial Services: is

important to include on theTakingAction Team as they
arefamiliarwith thefacility's needs and maintenance for
any remediation actions that take place.

Name:

Phone Number:
Email:

Plumbers: are important to include for replacing pipes or
making other plumbing changes to remediate elevated
lead levels.

Name:

Phone Number:
Email:

Local PWS/WaterSupplier: can help determineyour
possible lead remediation options and may be
responsible for your facility's water service line
replacement effort.

Name:

Phone Number:
Email:

Electrician: may be necessary to include on your 3Ts
TakingAction Team ifyou pursue pipe replacement.
Electrical wires may be grounded to the water pipes and
in some cases can be removed by a qualified electrician
and replaced by an alternative grounding system.

Name:

Phone Number:
Email:

Point-of-Use (POU) Filter Maintenance Contact: is

necessary if yourfacility installs POU filters to remediate
lead problems.

Name:

Phone Number:
Email:

STEP 2: Establish Recordkeeping Practices (3Ts Module 7)

Recordkeeping is critical to building an effective 3Ts Program. Keep and regularly update an ongoing
record of partners, team contacts, testing efforts, remediation efforts, public outreach, and
communication activities as you implementyour3Ts Program.

STEP2A: Identify a Recordkeeping Lead

• Appoint someone to ensure methods and results are documented to reduce the impact of staff
turnover on your 3Ts Program. This recordkeeper will work with all team members to gather and
store information in a centrally accessible place.

Getting Started Table 7: identify your Recordkeeping Lead.

3Ts Program Recordkeeping Lead Contact Information

Name:

Phone Number:
Email:

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GETTING STARTED

STEP2B: Keep Key Records

Keep records of the following key items to help improve your program and prevent the loss of important
programmatic knowledge.

Annual Water Quality Reports: Your local PWS may be required to
produce and distribute an annual water quality report that includes
system-wide lead monitoring results. Contact your PWS to obtain a
copy of the latest water quality report or visit the website Find Your
Local Customer Confidence Report fCCR) to check if it is available
online.

Contact Lists: Keep contact information for partners as part of program
records. Use the 3Ts Toolkit Partners ContactTemplate to identify and
record contact information.

Recordkeeping Templates

• Partners Contact Form

• Roles and

Responsibilities Form

• School and Child Care

Facilitv Data eTrackers

Completed Plan: Postyour completed 3Ts plan in a central location whereyourteam members can
access it.

Communications Materials: Keep an ongoing record of communication activities, including dated
copies of past communication materials and questions received from the community that could be
addressed in the future. The Communicate section covers these materials further.

Training Attendance, Schedule, and Materials: Keeping attendance and schedule records helps you
track training progress and better plan your future training needs. The Training section covers these
topics further.

Testing Plan and Results: Throughout the testing process, document the sampling methodology,
sampling locations, any implemented procedures or protocols, and testing results. The Testing
section covers these topics further.

Record Remediation Actions: Record remediation actions, schedules for upkeep and maintenance,
and lists of partners and contacts that assisted in your efforts. Keeping records of remediation actions
will help maintain and actively monitor remediation measures for effectiveness. TheTakingAction
section covers these remediation actions further.

Schedules of Routine Practices: Keep records of scheduled routine practices to maintain a high level of
water quality and set calendar reminders to helpyou stay on schedule. TheTakingAction section
covers routine practices further.

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GETTING STARTED

STEP 3: Identify State, Tribal, and Local Regulations (3Ts Introduction)

Reach out to your state drinking water program to find out what rules or regulations may apply to your
facility and your program, then tailor your plan to meet any local or state requirements. Some states,
tribes, and local jurisdictions have established their own laws, regulations, or guidance for testing drinking
water lead levels in child care facilities.

TO-DO. Input relevant local laws or regulations about testing for lead in your child care facility's drinking
water and/or include relevant website links.

STEP 4: Create an Overall Schedule

Use the table below to keep track of all the important information you may need along the way to test for
lead in your child care facility's drinking water. Activities may have a corresponding table as you continue
through the Plan Builder. Font colors correspond with the appropriate sections if more information is
needed. Some of the items below have already been auto-populated based on your answers to previous
questions in the Getting Started section (e.g., invitees for the communication group). Fill out the rest of
the Plan Builder to populate your schedule! Once you have filled-in all the sections of the Plan Builder,
your answers will appear here, and you can view and make adjustments to your3Ts Program Plan
Schedule.

Getting Started Table 8. Below is a schedule for your 3Ts Program. You can refer back to this table and edit
your dates, activities, and responsible leads as your program evolves and you child care facility's needs
change.

Dates Activities Activity Lead Notes

1. Communicate with stakeholders about
launching a 3Ts Program

2. Develop training materials for the
Administration Training Group

3. Schedule and invite attendees to the
trainings for the Administration
Training Group

4. Conduct trainings for the
Administration Training Group

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GETTING STARTED

Dates

Activities

Activity Lead

Notes



5. Develop training materials for the
Communication Training Group







6. Schedule and invite attendees to the
trainings for the Communication
Training Group







7. Conduct trainings for the

Communication Training Group







8. Develop training materials for the
Testing Training Group







9. Schedule and invite attendees to the
trainings for the Testing Training Group







10. Conduct trainings for the Testing
Training Group







11. Develop training materials for the
Taking Action Training Group







12. Schedule and invite attendees to the
trainings for Taking Action Training
Group







13. Conduct trainings for the Taking Action
Training Group







14. Create an outlet inventory







15. Create your plumbing profile







16. Decideyoursamplingoutlets







17. Establish sampling procedures







18. Select your certified laboratory and
backup laboratory







19. Define your laboratory's role







20. Communicate with stakeholders about
testing schedule and when water must
remain unused





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GETTING STARTED

Dates

Activities

Activity Lead

Notes



21. Conduct sampling (include all dates
and times)







22. Receive and interpret results







23. Communicate with stakeholders after
receiving lead results







24. Conductfollow-up sampling if

necessary (includes another round of
receiving, interpreting, and
communicating results)







25. Identify if you receive any elevated lead
results







26. If you receive elevated lead results,
identify the source of lead







27. Communicate with stakeholders about
plans for taking action if you received
elevated lead results







28. Take immediate actions
(SeeTaking Action Table3)







29. Take short-term actions
(SeeTaking Action Tabled







30. Develop and implement long-term
solutions (SeeTaking Action Table 5)







31. Incorporate routine practices into your
water management plan
(SeeTaking Action Table 6)







32. Implement routine practices





Summary:

In this section, you identified your program's stakeholders, assembled your 3Ts Team,
established your recordkeeping procedures, reviewed a schedule, and noted any relevant
state or local regulations. Return to this section to create and review your plan schedule.

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COMM UN IC ATE

Build Your Communications Plan

This section builds your 3Ts Program communications plan for
your team, members of the community, and other stakeholders.
Communicating early and often about your testing plans,
results, and next steps will build stakeholder confidence in your
ability to provide a safe learning environment.

Identify Your Target
Audience and
Communication
Methods

Incorporate
Communications
Best Practices

Schedule

Communications

Activities

IW
__

GETTING STARTED

STEP 1: Identify YourTarget Audiences and Communication Methods (3Ts
Module 1)

• YourTarget Audiences are the groups that you plan on regularly informing about your 3Ts
Program. Communications should always be directed at these audiences. Descriptions of target
audiences can be found in 3Ts Module 1.

• Communication methods will depend on the level of importance of the message, audience
preferences, and the number of people in the Target Audience.

TO-DO: Answer the following questions to work through things to consider when selecting

communication methods.

• What communication methods have you used in the past? What made those methods successful?
Examples of communication methods include press releases, letters/fliers, social media, mailbox
stuffers, websites, staff newsletters, and presentations. Detailed descriptions of communication
methods can be found in 3Ts Module 1.

• Will you change your communication methods based on the message? Indicate the factors that
will influence changing your communication methods, such as the importance of the message,
level of concern, timeliness of the message, and risk beingcommunicated.

What languages do you anticipate using? If you will need to use multiple languages, how
will you accommodate language needs (e.g., provide language-based contacts, translated
information)?

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COMM UN IC ATE

• What stakeholder groups do you anticipate communicating to (e.g., parents, staff)? What methods
will you use to communicate with each of these groups?

STEP 2: Incorporate Communications Best Practices (3Ts Module 1)

When carrying out communications activities, keep the
following best practices in mind:

S Take the initiative to communicate with your
community.

S Make sure your information is honest, accurate, and

comprehensive.

S Speak with one consistent voice.

S Anticipate questions and concerns and address them proactively.

S Be positive and forthcoming.

S Keep your audience up to date with the newest information.

S Have a plan created for communicating the results ofyour sampling effort to your audience

before testing begins.

S Share results regardless of the lead level detected.

S Share plans about remediation activities, includingwhatactions will betaken and when.
S Regularly update your community on water quality improvement efforts and routine practices.
S Being transparent about improvement efforts will ensureyourstakeholders and community
members have agency.

STEP 3: Schedule Communications Activities (3Ts Module 1)

• You will create schedules for completing program activities in the Training, Testing, and Taking
Action sections. These schedules will also include communications activities that align

with activities in these other sections. Communications activities are indicated by orange font.

• Time your communications to coincide with other activities so that your stakeholders remain
informed throughout the process.

Communication Templates

• Customizable Poster

• Parent Letter

• Newsletter

• Postcard

Summary:

In this section, you finalized methods of communication to use and learned best practices for
communicating aboutyour3Ts Program activities. Return to this section to identify methods to
reach out to the community and internal stakeholders.

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TRAINING

Build Your Training Plan

Let's use this section to build your internal training and
educational outreach process. This section helps you select
relevant topics, communicate background information on health
effects and drinking water regulations, group team members
and stakeholders with similar roles into targeted trainings,
incorporate best practices for conducting trainings into your
trainings, and utilize existing materials for training sessions.

mam

->&
J0

Group Team
Members and
Select Topics for
Targeted Training

Determine
Materials for
Use in Training
Program

A Incorporate Best
0 \ Practices into Training
J Development

Schedule
Trainings

GETTING STARTED

TAKING ACTION

STEP 1: Group Team Members and Select Topics for Targeted Training (3Ts
Module 3)

• Use the following table to identifyyourTrainingGroups. You mayfind it efficient to train groups
of people with similar roles. You may have personnel in more than one Training Group; if this is
the case, be sure to avoid scheduling conflicts.

• Use the following table to guide your selection of the appropriate training topics.

¦ Some topics are broadly applicable to all trainings, as they provide helpful context and
generate buy-in. There is no oneway to conduct trainings but referring to these
topics at the beginning of each training may serve as a useful starting point. These
topics include:

Background of your facilities and buildings
Your relationship to your PWS
Common terminology used
Health effects of lead

Vulnerability of children to lead poisoning
Sources of lead

How lead gets into drinking water

Regulatory background (state and/or federal requirements) of lead in
drinking water

Refer to 3Ts Module 2 for more information about the above topics. For additional training
resources, see EPA's Lead webpage.

Refer to the "Best Practices" listed in Step 3 later in this section for suggestions on
activities your trainings can incorporate and the best format for each group. For example,
breakout groups may be useful for larger Training Groups with clusters of similar roles.

Physical walkthroughs may be beneficial for those involved with facility infrastructure.

Varying the format of your trainings can help engage different types of learners; some
attendees may be visual, auditory, or kinesthetic learners.

o
o
o
o
o
o
o
o

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TRAINING

STEP 2: Determine Materials for Use in Your Training Program (3Ts Module 2)

•	There are multiple training materials available for your use when conducting the various trainings,
including the training materials from EPA's 3Ts Program, your state or municipal offices, and non-
profits and professional associations.

•	Your partners may have other materials that may be useful for your trainings. Check with:

¦	Your district's public relations team, who may have existing training materials.

¦	Other local or regional schools/child care facilities.

¦	Professional water organizations like the Water Research Foundation or local chapters of the
American Water Works Association and National Rural Water Association.

•	You may find it useful to develop your own training materials based on guidance from EPA, your state,
and partners, or to include supplemental materials attached to the plan. If you decide to develop
your own training materials, refer to Step 3 later in this section.

TO-DO: Select the training materials your program will use.

~	EPA3Ts Materials such as the3Ts Manual and Toolkit

~	StateTraining Materials

~	Municipal Training Materials

~	PartnerTraining Materials

~	Child Care Facility Training Materials

~	Develop your own

•	List the specific training materials you will use for the categories checked above:

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TRAINING

Training Table 1: Fill in the table to organize trainings for your groups. You may use the recommended topics and activities in italics or adjust to what will best work
for your team members. Refer to the Getting Started section to identify who should be grouped together for trainings.

Training Group Names

Topics

Materials

Activities

Location/Piatform

Additional Notes

Group: Administration

Trainer:

Members:

Principal/Director, Teachers,
Cafeteria Staff,

Custodial/facilities staff, Facility
nurses, Other funding
administrative staff

•	Health effects of lead

•	Why do testing?

•	Who is involved in testing?

•	Review Communications
Plan

•	Cover recordkeeping
practices and requirements

•	PowerPoint slides

•	3Ts Toolkit

•	Communications
Plan

•	Breakout groups
and discussions

•	Knowledge
checks





Group: Communications

Trainer:

Members:

PTA members,
Communications staff,
Translators

•	Relevant stakeholders

•	Communicating testing
results

•	Discuss Communications
Plan

•	3Ts Toolkit

•	State resources

•	Stakeholder
mapping exercise

•	Breakout groups
to brainstorm
messaging





Group: Testing

Trainer:

Members:

Sample collector, Personnel
conducting building
walkthroughs and fixture
assessments, Sample analysis
personnel

•	Facility's sampling
methodology

•	Interpreting testing results

• Plumbing and
fixtures inventory

•	Walkthrough of
facility testing
locations

•	Mock sampling
exercise





Group: Taking Action

Trainer:

Members:

Custodial/facilities staff,
Cafeteria staff, Remediation
person(s)

•	Interpreting testing results

•	Next steps or immediate
actions

•	Routine practices

• State resources

• Key facility

fixtures

walkthrough





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TRAINING

STEP 3: Incorporate Best Practices into Your Training Development (3Ts Module 3)

The following steps guide you through the process of developing trainings to prepare your team members

and stakeholders for their roles in the program.

Best Practices for Training Development

Incorporate supportive and inclusive best practices to sustain buy-in and investment in your program.

Keep these best practices in mind when developing and conductingyour trainings.

Outreach

S Employ your Communications Team to announce trainings and provide materials that may be
beneficial to the larger community. This may include information on the EPA's 3Ts Program and
state and local resources on lead in drinking water.

S Be transparent in communications with stakeholders. Include stakeholders across your whole
community, including underserved populations so that everyone is made aware of your trainings.

S Begin training early in your 3Ts Program to ensure your team is informed of their responsibilities.

Training Materials

S Provide discussion materials and topics before trainings so your team is prepared in advance.

S Vary training tools and presentation formats to keep trainings fresh and attendees engaged.

Some training tools work better with different audiences.

S Enhance your training materials with graphics, examples, and pictures.

Training Procedures

S Create an open, honest, and inclusive learning environment, as this may be new information for
many attendees.

S Allot ample time for questions. Encourage attendees to ask questions, and repeat questions
asked back to them to ensure thatyou can properly answer their questions.

S Incorporate interactive activities to engage attendees. Some examples of interactive activities are
knowledge checks and quizzes, tours of testing sites, group discussions, case studies, and hands-
on exercises.

Developing Your Trainings

While the content of each training session may vary based on the training audience and timing, there are

some structural features that are applicable to all your trainings.

TO-DO: Brainstorm answers to the questions below to get a sense of your training protocols.

• How will you ensure thatyour trainings are accessible for all attendees? For example, if you will be

holding remote trainings, will you use video, audio, and phone line? Will they be recorded for future

reference?

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TRAINING

• Will training materials be made available in languages other than English (including ASL)?

• Will these trainings be incorporated with other training programs that your facility is involved in? If so,
how will you integrate materials related to your 3Ts Program? ©

STEP 4: Schedule Trainings (3Ts Module 3)

• Plan out your training dates so that all team members have the necessary information before
beginning their assigned roles.

Training Table 2: Enter the dates by which you will complete training activities, the activity leads, and any
relevant notes in the table below. If applicable, revise activities to match the Training Groups you have
created above.

Dates

Activities

Activity Lead

Notes

1. Communicate with stakeholders
about launching a 3Ts Training
Program

2. Develop training materials for the
Administration Training Group

3. Schedule and invite attendees to the
trainings for the Administration
Training Group

4. Conduct trainings for the
Administration Training Group

5. Develop training materials for the
Communication Training Group

6. Schedule and invite attendees to the
trainings for the Communication
Training Group

7. Conduct trainings for the

Communication Training Group

8. Develop training materials for the
Testing Training Group

9. Schedule and invite attendees to the
trainings for the Testing Training
Group

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TRAINING

Dates

Activities

Activity Lead

Notes



10. Conduct trainings for the Testing
Training Group







11. Develop training materials for the
Taking Action Training Group







12. Schedule and invite attendees to the
trainings for Taking Action Training
Group







13. ConducttrainingsfortheTaking
Action Training Group







Summary:

In this section, you identified useful training materials, organized, and identified content for
Training Groups, learned some training best practices, and developed features of your training
program. Review this section to determine how and when you will implement training for your
3Ts Program.

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TESTING

Build Your Sampling and Testing Plan

Create
sami

Define
the Lab's
Rote

Use this section to help build your Lead Testing Plan. Testing
includes the process of sample collection, which is usually
conducted by your team members, and sample analysis,
which is conducted by a certified laboratory. This section will
cover how to plan, prioritize, and determine sampling
locations, develop sampling collection procedures, and begin
to analyze and interpret your results. This plan will depend
on the physical infrastructure of your building and your
facility's schedule and needs.

Conduct

Physical A. Identify a. Establish A. Select a

Walkthrough to AA Priority / \ Sampnng / \ certified

Create an Outlet \) 0utlets for \9) Procedures \ ) Lab

inventoiy Sampling

TAKING ACTION

STEP 1: Conduct Physical Walkthrough to Create an Outlets Inventory (3Ts
Moduie4)

• Create an inventory to help you choose which outlets to sample. Begin by conducting a physical
walkthrough to create an inventory of your outlets used for human consumption in all buildings.

• Identify how your water enters and flows through the building(s)' plumbing, priority outlets, and
additional sites that staff or students use for drinking water.

When conducting the walkthrough of the facility, makesure to:

S Take note of all outlets and visible plumbing used for human consumption. ®

S Take pictures to refer to at a later time.

S Pay close attention to the following indicators when prioritizing outlets as they may be more
likely to have elevated lead results. These indicators include:

¦ Rust around the outlet or discolored water coming from the outlet

¦ Colored stains on fixtures and/or around the plumbing

o Blue-green deposits on pipes and sinks indicate copper corrosion; brown
stains resultfrom the corrosion of iron

¦ For more information on these indicators, refer to 3Ts Appendix G.

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TESTING

Testing Table 1: Conduct a walkthrough of your building(s) and fill out the table on the next page with an in ventory of your facility's outlets used for human
consumption.

Sample Outlet

Location and Type of
Outlet ®

Are brass fittings,
faucets, orvaives used
at this location? ®

Does this outlet have
accessible screens or
aerators? ®

Are there signs of rust,
frequent leaks, or discolored
water? ®

Have there been any
complaints of metallic
taste at this outlet?

















































































































































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TESTING

STEP 2: Identify Priority Outlets for Sampling (3Ts Module 4)

•	Use outlets from TestingTabie 1 in Step 1 to prioritize and identify the outlets you will test. You may
need to prioritize some locations due to time or resource constraints. The following are factors that
increase outlet priority:

¦	Use by children under the age of sixyears old

¦	Use by pregnant or nursing women

¦	High frequency of use

¦	Old fixtures (especially those constructed before 1988)

¦	Presence of brass fittings, faucets, or valves

¦	Outlet with accessible screens or aerators

¦	Visible signs of corrosion, such as rust (See Step 1)

¦	Outlets with complaints of unusual (metallic) taste or strong odor

•	When determining which outlets to test, include a variety of fixtures used for human consumption.

¦	Test multiple types of fixtures to characterize potential lead exposure from various outlets.

¦	Do not include faucets that are not used for human consumption, such as sinks in janitor's
closets or outdoor hoses.

Testing Table 2: In the table below, indicate the outlets you will test See details in 3Ts M od u le 4.

Sample Outlet

Outlet Location

Types of Outlets

Is a filter attached
to this outlet?

Priority Level

















































































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TESTING

STEP 3: Establish Sampling Procedures (3Ts Module4.3Ts Module 5)

Determine sampling procedures and protocols to ensure that lead sampling is implemented properly and

consistently in yourfacility.

STEP3A: Outlet Sampling Sequence f3Ts Module^

• First, consider the order in which you will sample outlets. Sampling typically follows the flow of water
through a building, start on the bottom floor (where the water main is located) then continue up.

• Usingyour inventory (Step 1). Exhibits 2 and 3 in 3Ts Module4. and the questions below, decide on
the order of taking samples. You also may want to refer to useful documents such as floor plans.

TO-DO: List the order of floors and/or parts of the building where you will test.

• How does water flow through your building? Include the point of entry, where the water goes from
floor to floor, and the order in which fixtures receive water on the same floor. Identify the order in
which priority outlets are serviced. See information you entered in Step 1 and Step 2.

• List the order of floors and/or parts of the building where you will test.

STEP3B: Testing Frequency f3Ts M od u le 4 j

• Howfrequentlyyourfacilitycan and should testforlead in drinking water depends on avarietyof
factors (e.g., plumbing, water quality, lead results, budget, and competing priorities).

• Annual monitoring provides information on changes in the lead levels and the effectiveness of
remediation or treatment efforts, as well as timely notice of faulty or damaged outlets, and other
problems that may need to be addressed.

TO-DO: Answer the following questions to determine how often you will test for lead.

• What is your budget for lead testing? O

Have you had lead-positive sample results in the past?

Given your answers from the previous two questions, how often will you testfor lead in yourfacility's
drinking water? ®

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TESTING

STEP 3C: Sampling Protocols /3Ts Module4.3Ts Module5J

• It is recommended for child care facilities to collect 250 mL samples after a minimum of 8 hours not
using the water. A 250-mL sample volume can help identify the sources of lead at an outlet, as it is
representative of the amount of water consumed per serving. O

• For each outlet to be sampled, determine which type of sample is appropriate: first-draw samples
and/or flush samples. For more information about types of sample and sampling protocols, including
the recommended 2-Step sampling procedure, see3Ts Module5 including the Sampling Field Guide
and Sampling Guide Video.

TO-DO: Answer the questions below about sample types.

• From which outlets and fixtures will you collect first-draw samples? O

STEP 3D: Shipping Your Samples f3Ts Appendix E)

• Establish an organized labeling and shipping process prior to collection to help ensure that samples
are properly handled.

• In your shipping procedures, keep samples properly labeled and sealed between collection and
preparation by the laboratory.

• Most laboratories will provide the necessary shipping containers. To prevent sample degradation,
ship the samples to the testing laboratory as soon as possible.

TO-DO: Describe your comprehensive storage and shipping procedure from storing samples to packaging

and sending out the containers.

STEP 4: Select a Certified Laboratory (3Ts Module 4)

Select a certified laboratory approved by the state or EPA for analyzingyour samples. It is best practice to
have a backup laboratory in case your primary laboratory cannot analyze samples within your desired
timeframe. See 3Ts Module 4 for more information about selecting a certified laboratory.

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TESTING

Testing Table 3: Enter the laboratory and backup laboratory that will analyze your samples.

Laboratory
Name

Position

Contact Information

Shipping Address

Cost

Primary

Phone Number:
Email:

Backup

Phone Number:
Email:

STEP 5: Define the Laboratory's Roie (3Ts Module 4)

Define the laboratory's role in your testing procedures (i.e., collecting samples vs. conducting analysis).
Communicate with the laboratory to confirm testing details, such as when they will send out the sample
kit, their timeline for conducting sample analysis, and providing the results.

TO-DO: identify the sen/ices your selected iaboratoty will provide.

• What sampling containers will the laboratory provide? O

STEP 6: Schedule and Conduct Testing (3Ts Module 4.3Ts Module 5)

• Now thatyou have chosen sampling locations and established procedures, create a schedule for
completing testing activities.

• When identifying dates and times for sampling, schedule sample collection beforethe facility opens
and before any water is used. Ideally, the water should sit in the pipes unused for 8 to 18 hours before
a sample is taken.

• When identifying dates for multiple rounds of sampling, makesureto look at the calendar to ensure
you are not sampling on holidays. If so, confirm with the chosen laboratory that they will receive your
samples.

• When yourfacility conducts testing, use the 3Ts eTracker to record your sampling and results.

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TESTING

TO-DO: Answer the questions below to help determine when to conduct your testing.

• On what holidays and vacations is your facility closed? Avoid testing after a building was closed for 18
hours or more. O

• Identify the best time periods to take samples below. What are your facility's normal hours of
operation?

Testing Table 4: Enter the dates you will complete certain activities, the activity leads, and any relevant
notes in the table below.

Dates Activities Activity Lead Notes

1. Create an outlet inventory

2. Decideyoursamplingoutlets

3. Establish sampling procedures

4. Selectyour primary and backup
certified laboratory

5. Defineyour laboratory's role

6. Communicate with stakeholders
about testing schedule and when
water must remain unused

7. Sampling schedule (include all
dates and times)

8. Receive and interpret results

9. Communicate with stakeholders
after receiving lead results

10. Conductfollow-up sampling if
necessary (includes another round
of receiving, interpreting, and
communicating results)

Summary: Jk

In this section, you captured information about outlets and plumbing in your facility, established
sampling procedures, determined how your samples will be analyzed, and identified times to sample
for lead in drinking water. Return to this section to identify your laboratory, sample locations, and the
frequency of your samples.

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TAKING ACTION

Build Your Remediation Plan

Use this section to build your plan for taking action after receiving
lead testing results. You will consider immediate, short term, and long
term actions to remediate lead in your drinking water and determine
which actions could be best for your facility and community. Solutions
to lead problems need to be implemented on both a short term and a
long term basis.

Remember, there is no level of exposure to lead that is without risk
to children; taking actions on all outlets that show a detected lead
level can reduce exposure. These remediation actions could be as easy
as shutting off the outlet as an interim measure, putting up signage
noting that lead was detected at a very low level, and/or providing
instructions to let the water run for a set amount of time to flush the
lead out.

Identify Program

1) Remediation Trigger (2) Remediation

V_y Contractors

identify

\ Determine Short
4 ) term Actions

\ Determine iong
•3 ) term Solutions

\ Determine immediate
3 ) Actions

\ Establish Routine
O ) Practices

GETTING STARTED

STEP 1: Identify Program Remediation Trigger and Interpret Results (3Ts
Module 5)

• At a minimum, establish your Program Remediation Trigger (PRT). This is the level of lead or
concentration detected (e.g., in parts per billion or ppb, micrograms per liter or |ig/L, parts per

It is especially important
to ensure drinking water
is safeforvulnerable
infant populations when
reconstituting infant
formula.

million or ppm, or lastly, milligrams per literor mg/L) in
your drinking water sample at which you will prioritize to
take immediate remediation action(s) to reduce or
eliminate the exposure that exceeds the PRT.

The level may be set by the facility and/or state, depending
on existing state regulations and funding support. If your
facility is receivingfundingfrom the Water Infrastructure
Improvements for the Nation Act (WIIN) grant through the
state, then the state is required to set this level foryour
facility. Contacts for EPA and state agencies administrating the WIIN grant program can be found
at: https://www.epa.gov/dwcapacitv/wiin-2107-lead-testing-school-and-child-care-program-
drinking-water-state-grant-program. For more guidance on this level, ask your state or refer to
the3Ts Manual.

Check with your state and local agencies to see if they have additional guidance or requirements
(e.g., state-specific lead remediation trigger).

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TAKING ACTION

EPA regulates public water systems (PWSs) and does not have a health-based standard for lead. To
keep lead from entering the water, EPA's Lead and Copper rule (LCR) requires PWSs to treat water
using certain chemicals that keep the lead from leaching into the water by reducing corrosion of
pipes and plumbing. This treatment is called corrosion control. To check if corrosion control is
working, EPA requires PWSs to testfor lead at the tap in certain homes. PWSs compare sample results
from these homes to EPA's action level of 15 ppb. If 10 percent of
the samples from these homes have lead levels that are greater
than 15 ppb, then the PWSs must perform actions such as public
education and lead service line replacement. For more details on
LCR refer to Lead and Copper Rule 101 factsheet.

To assist child care facilities in a state without a state-specific
lead remediation trigger level, the facility determines the PRT.

Contactyour appropriate local agency (e.g., public health
department) for guidance. Recognizing there is no level of

exposure to lead that is without risk to children, the following illustrates baseline action levels
recommended by other federal agencies, state WlIN programs and public health organizations:

¦	National data from the state Wl IN grant program show PRT levels range from 4 ppb to 15 ppb.

¦	World Health Organization baseline level is 10 ppb.

¦	American Pediatric Association baseline level is 1 ppb.

Small child care
facilities are more
likely to have lead
service lines that may
need to be replaced.

TO-DO: Indicate your Program Remediation Trigger (e.g., in ppb orppm) to take action below.

•	If your results are above the PRT, you will need to take immediate, short-term, and long-term actions
to reduce lead in your drinking water. Action may include posting a sign at the fixture to inform that
lead was found, installing filters, implementing routine flushing, removing the fixtures from service.

•	If your sample results are below the PRT, EPA recommends taking action to further minimize
potential exposure. Action may include routine maintenance and flushing procedures. For more
details, see 3Ts Module 6 to reduce level lead exposure.

STEP 2: Identify Remediation Contractors (3Ts Module 6)

•	Identify potential external contractors for remediation. Prior to agreeing to work with any specific
organization, ask contractors for schedule information, health precautions that must be taken during
and following remediation, upfront costs, and operations and maintenance costs.

•	When selecting a contractor, confer with your local health department, PWS, and other internal or
external stakeholders to ensure the organization performing remediation is qualified and reputable.

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TAKING ACTION

Taking Action Table 1: List potential remediation contractors and the services they can offer. ®

Contractor Contact
Information

Services Offered

Reference Name and
Contact Information

Notes









































STEP 3: Determine Immediate Actions (3Ts Module 6)

•	Determine which actions you will take first if you receive elevated lead results. For these actions to be
effective, you may take all or a combination of several actions.

•	As you evaluate the feasibility of each option and choose the actions that you will integrate into your
plan, consider the questions that appear when you hover over each box. Work with your remediation
provider, oryour local health department, to help answer these questions and determine which
remediation options may be rightforyou.

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TAKING ACTION

Taking Action Table 2: Fill in the table to determine which immediate action(s) to take following elevated lead results. The text in italics provides information to
consider as you determine which actions to take. Additional information about these actions can be found in 3TsModuleS

^ . ... Likelihood of A ~ Availability of A Staffing _ , . ,,, ^

Immediate Remediation Actions _ V Cost O ^ O ^ Additional Notes

Success Water Requirements

~ Immediate shutoff: Shut off or
disconnect the problem outlet
until the problem is resolved.

Likely to be a
successful
immediate action.

Little to no
cost.

Not available
from these
outlets.

Small amount of
staff time
required to
initially shut off
the outlet.

If the outlet is not used
regularly, this can be a
long-term solution.

~ Do not drink (or cook) orders:

Post clear signage to notify
people that the outlet is not to be
used fordrinkingorcooking.

Relies on clear
signage and
individuals
following do not
drink (or cook)
orders.

Little to no
cost.

Drinking or
cooking water
would not be
available from
these outlets.

Small amount of
staff time
required to post
signage and to
communicate
about outlets.

If the outlet is used by
small children, make sure
to use pictures in your
signage.

~ Share test results: Let

stakeholders know aboutyour
test results.

Being transparent
will help set you
up for success.

Little to no
cost.

No effect on
availability of
water.

Time to develop
communications
and answer
questions.

Helpful to share test
results with your PWS,
health department or other
partners that can help.

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TAKING ACTION

STEP4:DetermineSho rt-te rm Actio ns (3Ts Module 6)

• Determine which short-term actions you will take following elevated lead results. Additional information about these actions can be found in 3Ts
Module6.

TakingAction Table 3: Fill in the table with your short-term actions. The text in italics provides information foryou to consider asyou determine which actions you will
take.

Short term Remediation Actions

Likelihood of
Success

Cost

Availability of
Water

Staffing
Requirements

Additional Notes

~ POU Filters: Install POU filters at each problem outlet.
Ensure that the selected POU device is certified to
remove lead by checking with the manufacturer or a
third-party website (such as nsf.orgorwqa.org) to verify
the product was tested and certified against NSF/ANSI
Standard 53 and for particulate lead, certified against
NSF/ANSI Standard 42. For details refer to A Consumer
Tool for Identifying Point of Use (POU)

Drinking Water Filters Certified to Reduce Lead
[EPA/600/F-18/335 | December2018]

Commercially
available.
Effectiveness
varies and they
may be vulnerable
to vandalism.

Price
per unit
can
range
from
about
$65 to
$500.

Drinking
water would
be available
at taps with
filters.

Need routine
maintenance
(e.g., cartridge
filter units need to
be replaced
periodically and
test 1/3 sites
annually so each
site gets tested
every 3 years).

Consult with your
state drinking water
office before
installation.
Effectiveness
varies. Can be a
long-term
remediation action
as well.

~ Flushing: Flush individual problem water outlets or all
outlets within thefacility. Unless you can ensure lead
levels remain low throughout the day, flushing is
recommended multiple times per day.

Flushing relies on
proper implementation
of the practice for it to
be successful as the
problem outlet is left
operational.

There
may be
costs
associate
d with
staff time.

Drinking water
would be
available at
problem taps if
they are flushed
prior to use.

Staff may need
to implement
routine flushing.

No installation or
maintenance of
equipment is required
however the practice
may become time
consuming.

~ Providing bottled water: Provide students and staff
with bottled water to minimize use of tap water. This
may be warranted if you are aware of widespread
contamination and other remediation is not a near-term
option.

Successfully
protect children
from drinking
contaminated water
if it meets FDA and
state standards.

Can be

expensiv

Makes drinking
water available
to the school
community but
with less ease
than taking from
the tap.

Staff time may
be needed to
procure and
distribute the
bottled water.

Using disposable
bottles is not an
environmentally
sustainable
solution.

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TAKING ACTION

STEP 5: Determine Long-term Solutions (3Ts Module 6)

• Determine long-term solutionsyou will implement ifyou receive elevated lead results. Long-term solutions may involve replacement or
repairs. When making any repairs or conducting work to replace plumbing or fixtures, ensure that "lead-free" solders and other materials are
used. Additional information about these actions can be found in 3Ts Module6.

Taking Action Table 4: Fill in the table with long-term actions. The text in italics provides information for you to consider as you determine which
actionsyou will take.

Long term Remediation ,... . ^ Availability of Staffing

, ° Likelihood of Success Cost ^ , Additional Notes

Actions Water Requirements

~ Replacement of Problem
Outlets: Replace identified
problem outlets and any
identified upstream
plumbing components
(e.g., valves, leaded solder)
permanently.

Can be effective for
localized lead
problems.

Relatively

inexpensive

compared

to other

long-term

solutions.

No effect on
availability
of water.

Staff or

contractors will
be required to
install

replacements.

May not solve
widespread

contamination problems
depending on the
source of lead.

~ Pipe Replacement:

Replace lead pipes and
portions of lead service
lines. Lead service lines
may fall underyouroryour
PWS's jurisdiction.

Can completely
remove the source of
lead contamination
but may introduce
issues with particulate
lead, if adequate
precautions (e.g.,
post-replacement)

Can be
expensive.

Replacemen
t activities
may impact
availability
of water.

Staff or

contractor time
may be required
for construction.

Conduct follow-up
testing after replacing
pipes to check for
particulate lead.

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TAKING ACTION

Long term Remediation

Likelihood of Success

Cost

Availability of
Water

Staffing
Requirements

Additional Notes

~ POU Filters: Install and
maintain POU filters. Create
maintenance schedules
and identify a point of
contact to ensure POU
filters are properly
maintained. Fordetails
refer to A Consumer Tool
for Identifying Point of Use

Commercially available.
Effectiveness varies and
they may be vulnerable to
vandalism. Properly
certified and maintained
filters have been shown to
reduce lead in drinking
water. Make sure the POU
filter was tested and
certified and certified to

Price per
unit can
range from
about $65
to $500.

Drinking
water would
be available
at taps with
filters.

Need routine
maintenance
(e.g., cartridge
filter units need
to be replaced
periodically).

Consult with your state
drinking water office
before installation.
Conduct follow-up lead
testing of the filtered
water to assess whether
the filter is successful in
reducing the lead below
the program trigger
level.

Effectiveness of POU
filters varies. Can be a
short-term remediation
action as well.

(POU)

Drinking Water Filters
Certified to Reduce Lead.

remove lead against the
NSF/ANSI Standard 53.
For added protection for
particulate lead, look for a
POU filter that is also
certified against NSF/ANSI
Standard 42.







~ Reconfigure Plumbing:

Modify plumbing system to
bypass sources of lead
contamination. Ongoing
renovation of school or
child care buildings may
provide an opportunity. You
may need to conduct
additional testing to be
certain you have properly
identified all sources of lead
contamination.

Successful
reconfiguring of
plumbing relies on
pinpointing exact
source of lead
contamination which
can be difficult.

Can be
less

expensive
than other
long-term
solutions.

May impact

available

outlets.

Staff time would be
required to conduct.
Need routine
maintenance (e.g.,
cartridge filter units
need to be replaced
periodically)ct lead
testing to pinpoint
source of
contamination and
to modify the
plumbing system.



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TAKING ACTION

STEP 6: Establish Routine Practices (3Ts Module 6)

• Establish routine practices to reduce exposure to elevated lead levels and other environmental
hazards in the future.

• Below are examples of routine activities that can be conducted to prevent exposure to drinking water
contaminants. Determine which practices yourfacility will implement.

• The frequency with which you implement these practices will depend on yourfacility, type of fixtures,
and amount of lead found in your facility.

TakingAction Table 5: Check which routine practices to include in your facility's overall water

management program.

Routine Practices

Cleaning

~ Clean fountains, aerators, and water fountain strainers regularly and post a cleaning time tracking
card by the water fountains/outlets for maintenance staff to complete. Seta reminder on the calendar to
notify maintenance staff when cleaning is required.

POU Maintenance

~ Create a schedule for filter replacement to notify maintenance staff when it is time to change the
filter.

Temperature Control

~ Use only cold water for food and beverage preparation as hot water will dissolve lead more quickly.
Communicate this to cafeteria staff and post notices.

~ If hot water is necessary, take it from the cold-water faucet and heat on a stove or in a microwave
oven.

Cross-Connections Control

~ Evaluate the facility for the presence of cross-connections (e.g., connections of non-potable water to
potable sources) and address any sources of potential contamination.

Communication

~ Create and postcards near bathroom handwashing sinks with notices that water should not be
consumed.

~ Organize events for the community to explain how everyone can help.

~ Use pictures if there are small children using bathrooms and ask teachers to remind students.

Routine Flushing Practices

~ Flushing as a routine practice can help prevent elevated lead results proactively as opposed to
flushing as a remediation action. For guidance on flushing, refer to 3Ts Module 6.

STEP 7: Schedule Remediation Actions (3Ts Module 5.3Ts Module 6)

Now thatyou have determined your action steps following lead testing and chosen routine practices you
will implement into your water quality management plan, make a schedule to execute this action plan.

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TAKING ACTION

Taking Action Table 6: Enter the dates you will complete certain activities, the activity leads, and any
relevant notes in the table below.

Dates	Activities	Activity Lead Notes



1. Identify if you receive any
elevated lead results







2. If you receive elevated lead
results, identify the source of
lead







3. Communicate with stakeholders
about plans for taking action if
you received elevated lead
results







4. Take immediate actions (See
Taking Action Table3)







5. Take short-term actions (See
Taking Action Table4)







6. Develop and implement long-
term solutions (SeeTaking
Action Table 5)







7. Incorporate routine practices
into your water management
plan (See Taking Action Table6)







8. Implement routine practices





Summary:

In thissection,you determined what immediate,short term, and long term actionsyou will take
in the event of elevated lead levels. You also decided on routine practices that you will establish
as part of your facility's water management plan to reduce your community's exposure to not
only lead but other drinking water contaminants. Refer to this section to confirm your
remediation trigger and next steps for when you receive your lead results.

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TAKE ACTION:

TAKE IT WITH YOU

Take Action: Your Summary Input

This section auto-summarizes your input from the Taking Action chapter of the Plan Builder.

Print and use for a quick reference of your planned actions when lead is detected in your
school's drinking water. To print this summary only, complete the following steps:

1.	In the toolbar - click [File]

2.	Click [Print] and select [Pages], then enter all the page numbers of Take It With You!
(e.g., 36-41).

3.	Click [Print] and you will have a quick reference of your planned actions when lead is

detected in your school's drinking water.

Note: If changes are needed, make them in the Taking Action chapter to re-populate the summary pages of
Take It With You!

TO-DO: Indicate your Program Remediation Trigger (e.g., in ppb orppm) to take action below.

Taking Action Table 1: List potential remediation contractors and the services they can offer.

Contractor Contact
Information

Services Offered

Reference Name and
Contact Information

Notes









































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TAKE ACTION: TAKE IT WITH YOU

Taking Action Table2. Fill in the table to determine which immediate action(s) to take following elevated lead results. The text in italics provides information
to consider as you determine which actions to take. Additional information about these actions can be found in 3Ts Module 6.

Immediate Remediation Actions

Likelihood of
Success

Cost

Availability of Water

Staffing
Requirements

Additional Notes

~ Immediate shutoff: Shut off or
disconnect the problem outlet until
the problem is resolved.

Likely to be a
successful
immediate action.

Little to no
cost.

Not available
from these
outlets.

Small amount of
staff time
required to
initially shut off
the outlet.

If the outlet is not used
regularly, this can be a
long-term solution.

~ Do not drink (or cook) orders:

Post clear signage to notify people
that the outlet is not to be used for
drinking or cooking.

Relies on clear
signage and
individuals
following do not
drink (or cook)
orders.

Little to no
cost.

Drinking or
cooking water
would not be
available from
these outlets.

Small amount of
staff time
required to post
signage and to
communicate
about outlets.

If the outlet is used by
small children, make sure
to use pictures in your
signage.

~ Share test results: Let

stakeholders know about your test
results.

Being transparent
will help set you
up for success.

Little to no
cost.

No effect on
availability of
water.

Time to develop
communications
and answer
questions.

Helpful to share test
results with your PWS,
health department or other
partners that can help.

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Taking Action Table 3: Fill in the table with your short-term actions. The text in italics provides information for you to consider as you determine which actions
you will take.

Short-term Remediation Actions

Likelihood of
Success

Cost

Availability of
Water

Staffing
Requirements

Additional Notes

~ POU Filters: Install POU filters at each problem
outlet. Ensure that the selected POU device is certified
to remove lead by checkingwith the manufacturerora
third-party website (such as nsf.orgorwqa.org) to
verify the product was tested and certified against
NSF/ANSI Standard 53 and for particulate lead,
certified against NSF/ANSI Standard 42. Fordetails
refer to A Consumer Tool for Identifying Point of Use
(POU)

Drinking Water Filters Certified to Reduce Lead
[EPA/600/F-18/335 | December 2018]

Commercially
available.
Effectiveness
varies and they
may be
vulnerable to
vandalism.

Price
per unit
can
range
from
about
$65 to
$500.

Drinking
water would
be available
at taps with
filters.

Need routine
maintenance
(e.g., cartridge
filter units need
to be replaced
periodically and
test 1/3 sites
annually so each
site gets tested
every 3 years).

Consult with your
state drinking
water office before
installation.
Effectiveness
varies. Can be a
long-term
remediation action
as well.

~ Flushing: Flush individual problem wateroutlets or
all outlets within the facility. Unless you can ensure
lead levels remain low throughout the day, flushing is
recommended multiple times per day.

Flushing relies on
proper

implementation of
the practice for it to
be successful as the
problem outlet is left
operational.

There
may be
costs
associate
d with
staff time.

Drinking water
would be
available at
problem taps if
they are
flushed prior to
use.

Staff may need
to implement
routine flushing.

No installation or
maintenance of
equipment is required
however the practice
may become time
consuming.

~ Providing bottled water: Provide students and staff
with bottled waterto minimize use of tap water. This
may be warranted if you are aware of widespread
contamination and other remediation is not a near-
term option.

Successfully
protect children
from drinking
contaminated
water if it meets
FDA and state
standards.

Can be
expensi
ve.

Makes

drinking water
available to
the school
community but
with less ease
than taking
from the tap.

Staff time may
be needed to
procure and
distribute the
bottled water.

Using disposable
bottles is not an
environmentally
sustainable
solution.

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Taking Action Table 4: Fill in the table with long-term actions. The text in italics provides information for you to consider as you determine which actions you will take.

Long-term Remediation Actions

Likelihood of success

Cost

Availability of
Water

Staffing
Requirements

Additional Notes

~ Replacement of Problem Outlets:

Replace identified problem outlets and
any identified upstream plumbing
components (e.g., valves, leaded solder)
permanently.

Can be effective for
localized lead problems.

Relatively
inexpensive
compared to
other long-term
solutions.

No effect on
availability of
water.

Staff or

contractors will
be required to
install

replacements.

May not solve
widespread
contamination
problems depending
on the source of lead.

~ Pipe Replacement: Replace lead
pipes and portions of lead service lines.
Lead service lines may fall underyouror
your PWS's jurisdiction.

Can completely remove the source of
lead contamination but may introduce
issues with particulate lead, if adequate
precautions (e.g., post-replacement

Can be
expensive.

Replacement
activities may
impact availability
of water.

Staff or

contractor time
may be required
for construction.

Conduct follow-up testing
after replacing pipes to
check for particulate lead.

~ POU Filters: Install and maintain POU
filters. Create maintenance schedules
and identifya point of contact to ensure
POU filters are properly maintained. For
details referto A ConsumerTool for
Identifying Point of Use (POU)

Drinking Water Filters Certified to
Reduce Lead.

Commercially available. Effectiveness
varies and they may be vulnerable to
vandalism. Properly certified and
maintained filters have been shown to
reduce lead in drinking water. Make
sure the POU filter was tested and
certified and certified to remove lead
against the NSF/ANSI Standard 53.
For added protection for particulate
lead, look for a POU filter that is also
certified against NSF/ANSI Standard
42.

Price per unit
can range from
about $65 to
$500.

Drinking water
would be
available at
taps with
filters.

Need routine
maintenance
(e-9-,

cartridge filter
units need to
be replaced
periodically).

Consult with your state
drinking water office before
installation. Conduct follow-up
lead testing of the filtered
water to assess whether the
filter is successful in reducing
the lead below the program
trigger level.

Effectiveness of POU filters
varies. Can be a short-term
remediation action as well.

~ Reconfigure Plumbing: Modify
plumbing system to bypass sources of
lead contamination. Ongoing
renovation of school orchild care
buildings may provide an opportunity.
You may need to conduct additional
testing to be certain you have properly
identified all sources of lead
contamination.

Successful reconfiguring
of plumbing relies on
pinpointing exact source
of lead contamination
which can be difficult.

Can be less
expensive than
other long-term
solutions.

May impact

available

outlets.

Staff time would be
required to conduct.
Need routine
maintenance (e.g.,
cartridge filter units
need to be replaced
periodically)ct lead
testing to pinpoint
source of
contamination and
to modify the
plumbing system.

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Taking Action Table 5:Check which routine practices to include in your facility's overall water management
program.

Routine Practices

Cleaning

~ Clean fountains, aerators, and waterfountain strainers regularly and post a cleaningtime tracking
card by the water fountains/outlets for maintenance staff to complete. Set a reminder on the calendar
to notify maintenance staff when cleaning is required.

POU Maintenance

~ Create a schedule for filter replacement to notify maintenance staff when it is time to change the
filter.

Temperature Control

~ Use only cold waterforfood and beverage preparation as hotwaterwill dissolve lead more quickly.
Communicate this to cafeteria staff and post notices.

~ If hot water is necessary, take it from the cold-water faucet and heat on a stove or in a microwave
oven.

Cross-Connections Control

~ Evaluate the facility for the presence of cross-connections (e.g., connections of non-potable water to
potable sources) and address any sources of potential contamination.

Communication

~ Create and postcards near bathroom handwashing sinks with notices that water should not be
consumed.

~ Organize events forthe community to explain how everyone can help.

~ Use pictures if there are small children using bathrooms and ask teachers to remind students.
Routine Flushing Practices

~ Flushing as a routine practice can help prevent elevated lead results proactively as opposed to
flushing as a remediation action. Forguidance on flushing, referto 3Ts Module 6.

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Taking Action Table 6: Enter the dates you will complete certain activities, the activity leads, and any
relevant notes in the table below.

Dates

Activities

Activity Lead

Notes



1. Identify if you receive any
elevated lead results







2. If you receive elevated lead
results, identify the source of
lead







3. Communicate with

stakeholders about plans for
taking action if you received
elevated lead results







4. Take immediate actions (See
Taking Action Table 3)







5. Take short-term actions (See
Taking Action Table4)







6. Develop and implement long-
term solutions (See Taking
Action Table 5)







7. Incorporate routine practices
into your water management
plan (See Takine Action Table 6)







8. Implement routine practices





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