U.S. EPA 3Ts Program

Training, Testing & Taking Action

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

£EPA

~ ~ OFFICE OF GROUND WATER
W AND DRINKING WATER


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o

Disclaimer

This guide is a product of the voluntary program of the U.S. Environmental Protection Agency
(EPA) 3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities - Training,
Testing, and Taking Action Approach.

EPA's 3Ts program is not a 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 or other National Primary
Drinking Water Regulations under the Safe Drinking Water Act (SDWA),

The 3Ts program approach is voluntary and provides tools and informational materials for
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-22-003
June 2022


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INTRODUCTION

First Step: Download the Plan Builder!

Before beginning, to ensure user inputs are saved, please 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.

INTRODUCTION

GETTING STARTED

COMMUNICATE

Why Use the 3Ts Plan Builder?

TRAINING

TESTING

If you are a school, child care facility, tribe, or other group performing lead testing and/or
remediation in drinking water, the 3Ts Plan Builder is for you.

Important: The 3Ts Plan Builder is a tool to help schools create a plan (consisting of schedules,
getting started tips, communication, training, testing and taking action) to implement a program
for reducing lead in drinking water. For child care facilities, use the "Build a Plan for Reducing
Lead in Drinking Water at Small Child Care Facilities".

¦ This document is designed to be used by the person(s) responsible for leading the 3Ts
Program. This is often the director, principal, head of building maintenance/custodial
services, or another leadership team member, or in some cases, it may be the State on
behalf of the school or child care facility.

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

Training school and child care staff to raise
awareness of the 3Ts Program, the potential causes
and health effects of lead in drinking water, and how
to sample and test for lead.

Testing for lead in drinking water in schools and child
care facilities to identify potential lead problems.
Taking Action to reduce lead in drinking water
through short-term and/or long-term measures.

Funding for Reducing Lead
in Schools and Child Cares

The Plan Builder was adapted from EPA's 3Ts for Reducing
Lead in Drinking Water in Schools and Child Care Facilities
Manual. Toolkit, and associated documents (e.g., 3Ts
Checklist). For full details on the 3Ts Program, including
definitions of terminology (3Ts Manual Appendix A), refer to
the 3Ts Toolkit at the following URL:

https://www.epa.gov/ground-water-and-drinking-water/3ts-
reducing-lead-drinking-water-toolkit. Additional documents
are hyperlinked throughout the Plan Builder for your
reference as you work through the document.

TAKING ACTION

TAKE ACTION: TAKE
IT WITH YOU!

Schools and child care
facilities may be eligible for
funds to conduct lead testing
and remediation through the
Water Infrastructure
Improvements for the Nation
(WIIN) Act grant program.
Contact your state program
at

https://www.epa.gov/dwcap
acity/wiin-2107-lead-testing
school-and-child-ca re-
program-drinking-water
state-grant-program.

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INTRODUCTION

First Step: Download the Plan Builder!

Before beginning, to ensure user inputs are saved, please 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.

INTRODUCTION

GETTING STARTED

COMMUNICATE

TRAINING

TESTING

How to Use the Plan Builder

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

1.	GETTING STARTED

2.	COMMUNICATE

3.	TRAINING

4.	TESTING

5.	TAKING ACTION

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
summary pages at the end of the Builder titled "Take It With You!".

1.	In your toolbar - click [File],

2.	Click [Print] and ensure under [Pages to Print] that "All" is selected.

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

TAKING ACTION

TAKE ACTION: TAKE
IT WITH YOU!

TAKE ACTION: TAKE IT WITH YOU!

At the end of this Builder, your responses from the Taking Action chapter will be auto-populated
into summary pages titled "Take Action: Take It With You". Print and use for 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!

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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.

Although you do not have to complete the Plan Builder in
a single session, reviewing and/or completing the Getting Started section provides useful context for
completing the other sections.

Elements of the Plan Builder

Fillable Tables and Text Entry Boxes

Each section provides prompting questions and step-by-step guidance to help users make decisions to
build their school or child care plan.

•	Users enter their answers into tables and text boxes in each section, text boxes shaded light
blue are fully editable and some suggested text may already be provided.

•	Tables and text boxes containing default suggested text can be overwritten or deleted.

•	Resources (e.g., templates, posters, modules) are hyperlinked throughout. Click on the text to
open to the resource.

When working through this document, some form fields will have "tooltips". When you hover over
the tooltip icon or relevant fillable field a note will pop up. These tooltips will provide additional
information to help build your plan. Tooltips are denoted by this symbol: O

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	11

~	My Training Plan	14

I I My Testing Plan	21

I I My Taking Action Plan	34

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GETTING STARTED

Build a BTs Program

Start developing your plan by identifying stakeholders, assembling your team, coordinating with your
state drinking water program for regulatory guidance, and establishing recordkeeping procedures.

Assemble /\ Identify State,	A. Establish	A. Create an

Your	/ 7 \ Tribal, and Local / 3 \ Recordkeeping /A.\ Overall

Schedule

Team	Regulations	Practices

INTRODUCTION

GETTING STARTED

COMMUNICATE

STEP 1: Assemble Your Team (3Ts Module 1)

A successful 3Ts Program depends on having a dedicated and organized team. 3Ts Program
responsibilities are likely additional responsibilities on top of your team members' current
roles, so be thoughtful, deliberate, and clear about the scope of involvement for those you
recruit to assist with the program.

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

The overall 3Ts Team organization is outlined in the graphic below.

TRAINING

TESTING

TAKING ACTION

TAKE; ACTION: TAKE
: itwith youi ; ; ; ; ; ;

STEP 1A: Identify Program Leads

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

Getting Started Table 1: Identify your 3Ts Program Leads.

3Ts Program Administration Contact Information

3Ts Program Lead

3Ts Deputy Program Lead

Name:

Phone Number:
Email:

Name:

Phone Number:
Email:

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GETTING STARTED

STEP IB: Identify Internal and External Stakeholders

• Internal stakeholders include individuals and groups who are required to approve, support, or fund
aspects of your 3Ts Program as well as those who have current job roles that align with protecting
the health of your facility community. Internal stakeholders may include:

Students
Parents

District wellness committees
Parent Teacher Associations (PTAs)
Local plumbing and construction

Principal/Director
Custodial/facilities staff
Board members
Facility nurses
Cafeteria staff

Physical Education staff	contractors/suppliers

Teachers

External stakeholders can help operate and communicate about your 3Ts Program. Update Table 2
regularly and make it available to all team members for when a quick response is necessary.

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

External Stakeholder Contact Information

Civic Leaders

State Drinking Water Program

Name:

Name:

Phone Number:

Phone Number:

Email:

Email:

Local Public Health Officials

EPA Regional Office

Name:

Name:

Phone Number:

Phone Number:

Email:

Email:

State Department of Education

Utility/Water Supplier

Name:

Name:

Phone Number:

Phone Number:

Email:

Email:

State Department of Health

Media

Name:

Name:

Phone Number:

Phone Number:

Email:

Email:

STEP 1C: Assign Communication Roles

•	Identify individuals to help communicate findings to the public about your 3Ts Program activities.
Individuals could include members of your school/child care community, local professionals, and
public leaders.

•	Note: The Communicate section covers how to execute communicating your 3Ts Program activities,
testing results, and remediation actions.

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GETTING STARTED

Getting Started Table 3: Fill in the table below to identify your Communication 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 and helps to coordinate communications
activities, make announcements, and respond to questions.

Name:

Phone Number:
Email:

Partner Liaison Contact: keeps the 3Ts Team up to date with
partners as the 3Ts Program progresses.

Name:

Phone Number:
Email:

Website and Social Media Contact: ensures the website and
social media stay up to date with the latest information
about the 3Ts Program.

Name:

Phone Number:
Email:

Public Hotline Contact: monitors and respond to questions
and concerns from the email and/or hotline number.

Name:

Phone Number:
Email:

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

Name:

Phone Number:
Email:

School/Child Care Facility/District Communications or
Public Relations Office (if any): helps utilize existing
resources, such as a school website, newsletter, or district-
wide announcements.

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.

•	The Training section will cover how to conduct 3Ts training and topics to train team members on.

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

Training Team Roles and Responsibilities

Training Team Lead: acts as the main person in charge of
your trainings.

Name:

Phone Number:
Email:

Training Coordinator: coordinates logistics for trainings
including scheduling, determining locations, and other
administrative activities.

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.

Trainer 1

Trainer 2

Name:

Phone Number:
Email:

Name:

Phone Number:
Email:

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GETTING STARTED

Training Team Roles and Responsibilities

Trainer 3

Trainer 4

Name:



Name:

Phone Number:



Phone Number:

Email:



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 at schools and child care
facilities.

¦ Consider designating a person to serve as the Testing Team Lead for testing and follow-up
activities even if someone else is hired to conduct testing.

•	The Testing section covers the specifics of lead sampling and testing.

Getting Started Table 5: Fill in the table below to identify key team members for developing and
executing the testing portion of your plan.

Testing Team Roles and Responsibilities

Testing Team Lead: designs your sampling methodology,
serves as the point-of-contact for your testing efforts, and
helps coordinate testing activities.

Name:

Phone Number:
Email:

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

Name:

Phone Number:
Email:

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

Name:

Phone Number:
Email:

Laboratory Internal Point of Contact: communicates with
the testing laboratory. This person regularly communicates
the testing schedule and activities to the 3Ts Program Lead.

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 school or child care water, understand the benefits and
considerations associated with each remediation option, and select a remediation provider.

•	In the Taking Action section, you will work together to consider remediation options and routine
practices to help reduce lead exposure in your facility's drinking water.

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GETTING STARTED

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

Taking Action Team Roles and Responsibilities

Taking Action Team Lead: acts as the main person in charge
of the Taking Action portion of your 3Ts Program and
coordinates the Taking Action Team's efforts.

Name:

Phone Number:
Email:

Remediation Contractor Internal Point of Contact: works
with the remediation contractors. This person should
regularly communicate the schedule, activities, and hazards
of remediation to the 3Ts Program Lead.

Name:

Phone Number:
Email:

Head of Building Maintenance/Custodial Services: is

important to include on the Remediation Team as they are
familiar with facility needs and maintenance for any
remediation actions that take place.

Name:

Phone Number:
Email:

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

Name:

Phone Number:
Email:

Local Public Health Officials: helps determine your possible
remediation options.

Name:

Phone Number:
Email:

Local Public Water System (PWS): may be responsible for
your facility's service line pipe replacement effort.

Name:

Phone Number:
Email:

Electrician: may be necessary to include on your 3Ts
Remediation Team if you 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 your facility installs POU filters to remediate
lead problems.

Name:

Phone Number:
Email:

STEP 2: 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 prior to building out 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 schools and/or child care facilities.

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

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GETTING STARTED

STEP 3: 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 implement your 3Ts Program.

STEP 3A: 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:

STEP 3B: Keep Key Records

Keep records of the following list of 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 (CCR) to check if it is available online.

•	Contact Lists: Keep contact information for partners as part of program records. Use the 3Ts Toolkit
Partners Contact Template to identify and record contact information for partners from various
organizations and groups you work with.

•	Completed Plan: Post your completed 3Ts plan in a central location where your team 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 monitory remediation measures for effectiveness.

The Taking Action section covers these remediation actions further.

Recordkeeping Templates

Partners Contact Form

Roles and

Responsibilities Form

School and Child Care

Facility Data eTrackers

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GETTING STARTED

• Schedules of Routine Practices. Keep records of scheduled routine practices to maintain a high level
of water quality and set calendar reminders to help you keep on schedule. The Taking Action
section covers routine practices further.

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 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.,). 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 your 3Ts Program Plan Schedule.

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

Dates

Activities

Activity
Lead

Notes



1. Communicate with stakeholders
about launching a 3Ts Program







2. Develop training materials for the
Administrative Training Group







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







4. Conduct trainings for the

Administrative 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





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GETTING STARTED

Dates

Activities

Activity
Lead

Notes



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. Decide your sampling outlets







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







21. Conduct sampling (include all dates
and times)







22. Receive and interpret results







23. Communicate with stakeholders
after receiving lead results





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GETTING STARTED

Dates

Activities

Activity
Lead

Notes



24. Conduct follow-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 (See
Taking Action Table 3)







29. Take short-term actions (See
Taking Action Table 4)







30. Develop and implement long-term
solutions (See Taking Action Table

5)







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







32. Implement routine practices







Summary:

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

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COMMUNICATE

Build Your Communications Plan

This section will build your plan for communicating about your 3Ts Program to your team, members of the
community, and other stakeholders. The core of an effective communications plan is preparation and
coordination to deliver information swiftly, professionally, and consistently. 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.

6

Identify Your Target	,	.

3	Incorporate	Schedule

Audience and	_	..	_	..

Communications	Communications

Communication
Methods

Best Practices	Activities

INTRODUCTION

GETTING STARTED

COMMUNICATE

TRAINING

TESTING

TAKING ACTION

TAKE ACTION: TAKE
IT WITH YOU!

STEP 1: Identify Your Target Audiences and
Communications Methods (3Ts Module 1)

•	Your Target 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.

•	Communication method examples 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.

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?

Links to Communications
Templates

Customizable Poster

Parent Letter

Newsletter

Postcard

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

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COMMUNICATE

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

Communicate Table 1: Select your Target Audience(s) by clicking in the box to mark it with a check mark.
For each Target Audience selected, list the methods of communications you will use.

Stakeholder Groups

Target
Audience?

Communication Methods

Notes

School or Child Care
Facility Community

~





Building Community

~





Larger Community

~





Local Community
Organizations

~





State Drinking Water
Programs

~





Drinking Water
Community

~





Other:

~





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.

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COMMUNICATE

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

before testing begins.

S Share results regardless of the lead level detected.

S Share plans about remediation activities, including what actions will be taken and when.
S Regularly update your community on water quality improvement efforts and routine practices.
S Being transparent about improvement efforts will ensure your stakeholders 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.

In this section, you identified Target Audiences to share information with, finalized methods of
communication to use, and learned best practices for communicating about your 3Ts Program
activities. Return to this section to identify methods to reach out to the community and internal
stakeholders.

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Build Your Training Plan

TRAINING

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.

Determine	. Group Team	Incorporate Best

Materials for	/ \ Members and	Practices into Training	Schedule

Use in Training	( ^ ) Select Topics for	' Development	"	Trainings

Program	Targeted Training

INTRODUCTION

GETTING
STARTED

COMMUNICATE

TRAINING

TESTING

TAKING ACTION

TAKE ACTION:

TAKE IT WITH YOU!

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

•	Use the following table to identify your Training Groups. You may find 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.

•	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.

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

o Background of your facilities and buildings
o Your relationship to your PWS
o Common terminology used
o Health effects of lead
o Vulnerability of children to lead poisoning
o Sources of lead
o How lead gets into drinking water

o 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.

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TRAINING

trainings, including the training materials from EPA's 3Ts Program, your state or municipal
offices, non-profits, and professional associations.

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

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

o Other local or regional schools/child care facilities,
o 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.

~	EPA 3Ts Materials such as the 3Ts Toolkit. 3Ts Manual, and Interactive Tools

~	State Training Materials

~	Municipal Training Materials

~	Partner Training Materials

~	School or 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 below. You may use the recommended topics and activities auto-populated in the form field 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 and which trainer should lead each
group.

Training Group Names

Topics

Materials

Activities

Location/Platform

Additional Notes

Group: Administration

Leader:

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
Communication-
s Plan

Breakout groups
and discussions
Knowledge
checks





Group: Communications

Leader:

Members:

PTA members, Communications
staff, Translators

Relevant stakeholders
Communicating testing
results

3Ts Toolkit
State resources

Stakeholder
engagement





Group: Testing

Leader:

Members:

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

Facility's sampling
methodology

Interpreting testing results

Plumbing and

fixtures

inventory

Walk through of
facility testing
locations





Group: Taking Action

Leader:

Members:

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

Interpreting testing results
Next steps or immediate
actions Routine practices

State resources

Walkthrough of
key facility fixtures





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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 conducting your trainings.

Outreach

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

S Be transparent in communications with stakeholders. Make sure to 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 materials in advance of trainings and indicate topics that will be discussed so your team
is prepared.

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 that you 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.

S Emphasize that your program is a partnership and highlight the various roles that attendees will
play in your program. Clearly defining responsibilities will encourage continued buy-in to your
program.

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.

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TRAINING

TO-DO: Brainstorm answers to the questions below to get a sense of your training protocols.
• How will you ensure that your 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?

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? O

STEP 4: Schedule Trainings (3Ts Module 3)

• Building your 3Ts Program requires providing team members with the necessary knowledge to carry
out program activities. 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 (Color coded to match to
associated plan activity.)

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





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TRAINING

Dates

Activities (Color coded to match to
associated plan activity.)

Activity Lead

Notes



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





O

Summary:

In this section, you identified useful training materials, then organized and identified content
for training groups. You 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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Build Your Sample Testing Plan

TESTING

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
Walkthrough

Develop a
Plumbing Profile

Select a
Certified Lab

Define the
Lab's Role

Prioritize Testing
Outlets

f \ Establish Testing
4 ) Procedures

Decide How to
Analyze Sample

' \ Schedule and
O ) Conduct Testing

INTRODUCTION

GETTING STARTED

COMMUNICATE

TRAINING

TESTING

TAKING ACTION

;! TAKE ACTJONrTAKE!;!
IT WITH YOU!

STEP 1: Conduct Physical Walkthrough to Create an
Inventory (3Ts Module 4)

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

¦ Identify how your water enters and flows through the building(s)' plumbing, priority
outlets, and additional sites staff or students may be using for drinking water.

•	Before conducting your walkthrough, develop a coding system that will allow each unique
outlet to be identified by location, type, and other relevant characteristics.

TO-DO: Enter your coding system here. Use 3Ts Appendix C for examples of outlet coding. (Ex.

Building Number - Floor - Room Number - Outlet Type - Sample Number). Note: This

information is also needed for the 3Ts "Recordkeeping and Reporting" Tool.

When conducting the walkthrough of the facility, make sure to:

S Take note of all outlets and visible plumbing used for human consumption. O
S If a floor plan is available, mark each tap and water filler on the floor plan with their unique

identifier established through your coding system.

S Take pictures to refer to at a later time.

S Look for signs of outlets with discoloration or rust that may be faulty or corroded. Pay close
attention to these indicators when prioritizing outlets. These indicators include:

¦	Rust around the outlet

¦	Stains on fixtures, dishes, and laundry

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

¦	Frequent leaks

¦	Discolored water coming from the outlet

¦	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 inventory of your facility's outlets used
for human consumption.

Sample Outlet
ID

Location and Type a
of Outlet

Are brass fittings,
faucets, or valves O
used at this location?

Does this outlet
have accessible A

o

screens or
aerators?

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

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

















































































































































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TESTING

STEP 2: Develop a Plumbing Profile (3Ts Appendix G)

•	A plumbing profile can assist you in selecting and prioritizing outlets for sampling (Step 3).

•	In Testing Table 2, the questions in the left column help determine whether lead is likely a problem in a facility and inform outlet
prioritization. Use the gray "TIP" boxes as a guide to interpret your answers and gain a better understanding of the significance of possible
answers. Only skip questions that do not apply to your building. For additional information on creating a plumbing profile, see the 3Ts
Appendix G.

Testing Table 2: Fill out this table to create a plumbing profile for your facility. After answering each question, review the gray boxes to see what
your answer means for potential lead contamination.

Plumbing Profile Question

My Answer

What year was the building(s) built? Include dates for any additions added to
original building.

If built or repaired in/or before 1986, was "lead-free" plumbing and solder used?



TIP: Based on vour building's age identify likelv sources of lead in vour facility's plumbing. For detailed information, refer to 3Ts Appendix G.

•	Plumbing older than 1930: Likely to contain lead pipes that can contaminate water quality.

•	1930 -1986: Likely to contain lead solders used to join copper pipes together. Lead pipes are possible.

•	1986 - 2014: "Lead-free" solders used on plumbing joints, brass fixtures or plumbing components may have lead. Lead pipes are very
unlikely.

•	2014 - Present: Even if "lead-free materials" were used in new construction and/or plumbing repairs, lead leaching may occur. Lead
pipes are very unlikely.

Were any buildings or additions added to the original facility? If so, note the year
for each new building or addition.



TIP: If there are separate buildings or additions, complete a plumbing profile for each building, addition, or wing. Because this plumbing
profile will be used to inform testing order based on the building's plumbing infrastructure, different plumbing setups will result in
different recommended testing orders.

When were the most recent plumbing repairs made? Note the locations and years
by building.



TIP: This is used to determine if lead contamination from plumbing repairs may have occurred. Elevated lead levels may occur if the building,
an addition, new plumbing, or repair is less than 5 years old and lead solder or other leaded materials were used (especially if they were
purchased prior to 2014).

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TESTING

Plumbing Profile Question

What type of solder has been used? Was lead solder used in the plumbing system?
Note the locations with lead solder.

My Answer

TIP: Lead solder can contribute to contamination of downstream fixtures. It is likely that high-lead solder and fluxes continued to be used
until 1988 and even later in some areas. The local plumbing code authority or building inspector may be able to provide guidance regarding
when high-lead solder was last used on a regular basis in the area.

What material(s) is the service connection pipe(s) (i.e., the pipe that carries water
to the school or child care facility from the PWS's main in the street) made from?
Note the locations where the service line enters the building and connects to the
interior plumbing.

TIP: Based on material type, some pipes are at higher risk of contamination than others. Based on your lead testing results, pipes may need to
be replaced. Survey the building for exposed pipes, preferably accompanied by an experienced plumber who should be able to identify the
composition of pipes on site:

•	Lead pipes are dull gray in color, may be easily scratched by an object such as a key and aren't magnetic. They are likely to contaminate
water that flows through them.

•	Galvanized metal pipes are gray or silver-gray in color, usually fitted together with threaded joints, and magnetic. Debris from this material,
which has fallen inside the pipes, may be a source of contamination. Galvanized service lines that are or ever were downstream from a lead
service line can adsorb lead and contribute to lead in drinking water.

•	Copper pipes are red-brown in color, green if corroded, and may be joined together with lead solders.

•	Plastic pipes, especially those manufactured abroad, may contain lead. If plastic pipes are used, be sure they meet NSF International
Standards.

More information about service connections can be found in 3Ts Module 2 and more information identifying pipe materials can be found in
3Ts Module 4.

What are the building's potable water pipes made of (e.g., lead, plastic, galvanized
metal, cast iron, copper, other)? Note the location of the different types of pipe, if
applicable, and the direction of water flow through the building.

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TESTING

Plumbing Profile Question	My Answer

TIP: This is used to determine if your building has a lead service line. A lead service line is a pipe made of lead that connects a water main to
the school's distribution system. In general, larger buildings do not have lead service lines because lead is impractical for the larger water
service pipes typically used in these facilities; however, many facilities reside in small older buildings and have a higher likelihood of being
served by lead pipes. If you have a lead service line, it is recommended that you work with your local PWS to explore options for replacement.
The pipe may fall under your facility's jurisdiction and the PWS's jurisdiction. Replacing only one portion of the service line could lead to more
lead contamination. You may explore state or federal programs to help finance its replacement. Be aware that the lead service line can
produce contaminated water at any fixture. For this reason, it is recommended to fully replace the pipe rather than one section.

More information about service connections can be found in 3Ts Module 2.

Are there tanks in the plumbing system (e.g., pressure tanks or gravity storage
tanks)? Note the locations of any tanks, and information about the tank (e.g.,
manufacturer, date of installation).



TIP: Older tanks may contain coatings that are high in lead content or sediment that could be flushed back into the plumbing system under
certain circumstances. You may wish to contact the supplier or manufacturer to obtain information about coatings. Also, you may also wish
to hire a plumber or tank service contractor to inspect the tanks, especially gravity storage tanks that are located outside of the building.

Is any electrical equipment grounded to water pipes? Note the locations.



TIP: If electrical equipment has been installed using water pipes as a ground, the electric current traveling through the ground wire will
accelerate the corrosion of interior plumbing containing lead. This practice should be avoided; however, if existing wires are already
grounded to water pipes, the wires should not be removed from the pipes unless a qualified electrician installs a grounding system.

Ask the PWS to determine whether any testing has been done. If testing has been
done at your school or child care, note the name of contaminant(s) and
concentrations.

Is testing done regularly at the facility?



TIP: Your water supplier (usually your PWS) should also be able to tell you whether they have conducted lead monitoring or any other kind of
testing at the school or child care facility. If so, your water supplier may be able to provide some indication of whether lead or other
contaminants could be a problem within your building(s).

Are building blueprints available?

Are there known plumbing "dead-ends," low use areas, existing leaks, or other
potentially problematic areas?

Are renovations being planned for part or all of the plumbing system?

TIP: Low use areas and dead-end locations are locations where water quality can be unsafe for consumption and/or use. Incorporate this
information into decisions regarding testing locations and protocols. You may wish to note the direction of water flow and the location of
fixtures, valves, tanks, areas of sediment accumulation, areas of corrosion, etc., on a sketch or blueprint of the plumbing.

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TESTING

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

•	When considering how many 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 six years old

¦	Use by pregnant women

¦	High frequency of use

¦	Old fixtures (especially those constructed before 1988)

¦	Proximity to point of entry

¦	Presence of brass fittings, faucets, or valves

¦	Outlet with accessible screens or aerators

¦	Strong odor

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

¦	Outlets with complaints of unusual (metallic) taste

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

¦	Test multiple types of fixtures and areas of the building. Using results from one outlet to
characterize potential lead exposure from all other outlets may fail to identify localized lead
problems.

¦	Do not include faucets that are not used for human consumption, such as sinks in janitor's
closets or outdoor hoses. If these could potentially be used for consumption (e.g., the
janitor closet is close to kitchen and is used for cleaning appliances or the outdoor hoses are
used to fill water jugs for sports activities), use clear signage to notify people that the faucet
should not be used for drinking or cooking, or include these fixtures in your Testing Plan.

Testing Table 3: In the table below, indicate which outlets you will test. See details in 3Ts Module 4.

Sample Outlet ID

Outlet Location

Types of Outlets

Will you test this
outlet?

Priority Level

















































































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TESTING

STEP 4: Establish Sampling Procedures (3Ts Module 4, 3Ts
Module 5)

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

consistently in your facility.

STEP 4A: Order the Sampling of Your Outlets (3Ts_Module_4j

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

•	Using your inventory (Step 1). the plumbing profile (Step 2). Exhibits 2 and 3 in 3Ts Module 4. 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.

•	Where does water enter the building?

• 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 using the coding system you developed earlier. See information
you entered in Step 2 and Step 3.



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

STEP 4B: Testing Frequency (STs Module 4J

•	How frequently your facility can and should test for lead in drinking water depends on a variety of
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.

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TESTING

TO-DO: Answer the following questions to determine how often you will test for lead.
• What is your budget for lead testing? Q

• Given your answers from the previous three questions, how often will you test for lead in your
facility's drinking water? Q

STEP 4C: Sampling Protocols (3Js Module 4. 3Ts Module 5)

•	Next, choose your sample volume and the types of samples you will collect. 0

•	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.

TO-DO: Enter the sample volume you plan to collect in the text box below.

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, see 3Ts Module 5 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

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TESTING

• Will you collect second-draw samples at the same time that initial samples are taken? O

STEP 4D: Detailed Fixture Evaluations (STs Appendix DJ

•	If you receive a lead-positive result after sample analysis, consider conducting a detailed fixture
evaluation to pinpoint where lead is getting into drinking water.

•	Types of fixtures that often require detailed fixture evaluations include drinking water fountains,
cold water faucets, drinking water fountains with coolers, ice-making machines, and central chiller
units. Note this guidance does not include testing hot water outlets or hot water heaters, because
hot water is not recommended for consumption (drinking/cooking).

•	More information on detailed fixture evaluations, such as how to take and interpret samples from
the above fixtures, can be found in 3Ts Appendix D.

TO-DO: List the fixtures included in your Testing Plan that you may need to conduct a detailed fixture

evaluation on if you receive elevated lead results.

STEP 4E: Shipping Your Samples (STs Appendix E)

•	Establish an organized 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 and cold packs. To prevent sample
degradation, ship the samples as soon as possible.

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

and sending out the containers.

STEP 5: Select a Certified Laboratory (3Ts Module 4)

Select a certified laboratory approved by the state or EPA for analyzing your 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 4: 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:

I



STEP 6: Define the Laboratory's Role (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 services your selected laboratory will provide.

• What kinds of sampling containers will the laboratory provide? 0

STEP 7: Decide How to Analyze Your Drinking Water Samples
(3Ts Module 4)

•	Particles of lead in drinking water may result from physical corrosion of lead distribution system and
interior plumbing components. Physical disturbances (e.g., construction), pipe replacement, and
connection of new fixtures can cause the release of lead particles from system and plumbing
components, which can result in temporary, but significant, increases of lead levels in the water.

•	For more detail about analytical methods, see EPA's Analytical Methods Approved for Drinking
Water Compliance Monitoring of Inorganic Contaminants and Other Inorganic Constituents. This
information should be provided to you by the certified laboratory outlined in their procedure
guidelines.

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TESTING

TO-DO: Answer the questions below to identify details about analyzing for lead.

• Will the laboratory analyze for total lead, dissolved lead, or both to determine particulate lead?

• What other testing could the laboratory conduct for your facility (e.g., microbiological such as total

coliforms)? See 3Ts Appendix D for more information.

STEP 8: Schedule and Conduct Testing (3Ts Module 4,
3Ts Module 5)

•	Now that you have chosen sampling locations and established procedures, create a schedule for
completing Testing activities.

•	When identifying dates and times for sampling, schedule sample collection before the 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 your facility conducts testing, use the 3Ts eTracker to record your sampling and results.

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

• What are your facility's normal hours of operation?

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TESTING

Testing Table 5: 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. Create your plumbing profile







3. Decide your sampling outlets







4. Establish sampling procedures







5. Select your certified laboratory
and backup laboratory







6. Define your laboratory's role







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







8. Conduct sampling (include all
dates and times)







9. Receive and interpret results







10. Communicate with stakeholders
after receiving lead results







11. Conduct follow-up sampling if
necessary (includes another
round of receiving, interpreting
and communicating results)





Summary:

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 typically 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 help to reduce exposure. These remediation actions could be as
easy as shutting off the outlet as an interim measure or putting up signage noting that lead was detected at a
very low level and providing instructions to let the water run for a set amount of time to flush the lead out.
However, results with elevated lead levels, based on your Program Remediation Trigger, will require
immediate action, so know your potential remediation options prior to sampling and prepare a plan to take
remediation actions. This will also help establish routine practices to integrate into your facility's
management program to reduce exposure to drinking water contaminants.

Identify Program
Remediation Trigger

Consider Facility
Features

' \ Identify Remediation
3 ) Contractors

f \ Determine
4 ) Immediate Actions

Determine Short
term Actions

Determine Long
term Solutions

Establish Routine
Practices

Schedule

Remediation

Actions

INTRODUCTION

GETTING STARTED

COMMUNICATE

TRAINING

TESTING

TAKING ACTION

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

•	Establish your Program Remediation Trigger (PRT). This is the level of lead detected (e.g., in
ppb, ng/L, ppm, or 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 receiving funding from the Water Infrastructure
Improvements for the Nation Act (WIIN) grant through the state, then the state is required
to set this level for your 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 the 3Ts Manual.

•	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 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 test for 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

TAKE ACTION: TAKE
IT WITH YOU!

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TAKING ACTION

To assist those schools and child care facilities in a state without a state-specific lead remediation trigger
level, the facility determines the PRT. Contact your 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
WIIN programs and public health organizations:

•	National data from the state WIIN 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.

TO-DO: Indicate your Program Remediation Trigger (e.g., in ppb or ppm) to take remediation actions.

If your results are above the Program Remediation Trigger, you will need to take immediate, short-term,
and long-term actions to reduce lead in your drinking water. If your sample results are below the
Program Remediation Trigger EPA recommends taking action to further minimize potential exposure.
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. For more details, see 3Ts Module 6
to reduce lead exposure.

STEP 2: Consider Facility Features (3Ts Module 6)

• To determine which immediate, short-term, and long-term actions may be best for your facility,

consider certain facility features and keep key questions in mind.

Taking Action Table 1: List the relevant features for your facility that will determine which remediation
methods are potentially feasible for your facility.

Facility Features	Notes

Size (Note number of buildings, floors, wings, and year they
were built)



Budget (Note source of funding, total budget, potential
future funding)



Location (Note presence of lead service lines, technical
assistance programs available)



Season (Note typical use patterns or periods of reduced use
[i.e., summer break])



Facility Status (Note ongoing or planned building projects)



Other



3Ts for Reducing Lead in Drinking Water: Plan Builder

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TAKING ACTION

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

• Identify potential external contractors for remediation. Prior to agreeing to work with any particular
organization, ask contractors for information on schedule, 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.

Taking Action Table 2: List potential remediation contractors and the services they can offer. ®

Contractor Contact
Information

Services Offered

Reference Name and
Contact Information

Notes









































STEP 4: 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, your local health department, or to help answer these questions and
determine which remediation options may be right for you.

3Ts for Reducing Lead in Drinking Water: Plan Builder

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TAKING ACTION

Taking Action Table 3: Fill in the table on the next page to determine which immediate action(s) to take following elevated lead results. The auto-
populated text 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 A
Success

Cost O

Availability of A
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, small
children, make sure
to use pictures in
your signage.

3Ts for Reducing Lead in Drinking Water: Plan Builder

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TAKING ACTION

STEP 5: Determine Short-term Actions (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 Module 6.

Taking Action Table 4: Fill in the table with your short-term actions. The auto-populated text 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
checking with the manufacturer or a third-
party website (such as nsf.org or wqa.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 | December 20181

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).

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 the facility.
Unless you can ensure lead levels remain
low throughout the day, flushing is
recommended multiple times per day.

Flushing relies
on proper
implementatio
n of the
practice for it
to be

successful as
the problem
outlet is left
operational.

There may
be costs
associated
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.

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TAKING ACTION

~ 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
expensive.

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.

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

• Determine long-term solutions you will implement if you 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 Module 6. Refer to your plumbing profile as you determine long-
term solutions.

Taking Action Table 5: Fill in the table with long-term actions. The auto-populated text 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
under your or 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

Replaceme
nt 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.

3Ts for Reducing Lead in Drinking Water: Plan Builder

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TAKING ACTION

Long term Remediation
Actions

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. 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 |
December 2018]

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.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.

~ 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.

No major construction
required.

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TAKING ACTION

STEP 7: 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 your facility will implement.

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

Taking Action Table 6: 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. 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 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 post cards 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 8: Schedule Remediation Actions (3Ts Module 5f 3Ts
Module 6)

Now that you 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.

3Ts for Reducing Lead in Drinking Water: Plan Builder	41 | P a g e


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TAKING ACTION

Taking Action Table 7: 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 Table
4)







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







7. Incorporate routine

practices into your water
management plan (See
Taking Action Table 6)







8. Implement routine
practices





Summary:

In this section, you determined what immediate, short-term, and long-term actions you 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.

Reminder: The next section is the auto-summary of all your responses from the Taking Action
chapter.

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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., 43-47).

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 or ppm) to take remediation actions.

Taking Action Table 1: List the relevant features for your facility that will determine which remediation methods are
potentially feasible for your facility.

Facility Features

Notes

Size (Note number of buildings, floors, wings, and year they were built)



Budget (Note source of funding, total budget, potential future funding)



Location (Note presence of lead service lines, technical assistance
programs available)



Season (Note typical use patterns or periods of reduced use [i.e.,
summer break])



Facility Status (Note ongoing or planned building projects)



Other



Taking Action Table 2: List potential remediation contractors and the services they can offer.

Contractor Contact
Information

Services Offered

Reference Name and Contact
Information

Notes









































3Ts for Reducing Lead in Drinking Water: Plan Builder

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TAKING ACTION: TAKE IT WITH YOU

Taking Action Table 3: Fill in the table on the next page to determine which immediate action(s) to take following elevated lead results. The auto-populated text
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.

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

3Ts for Reducing Lead in Drinking Water: Plan Builder

44 | P a g e


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TAKING ACTION: TAKE IT WITH YOU

Taking Action Table 4: Fill in the table with your short-term actions. The auto-populated text 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 checking
with the manufacturer or a third-party website
(such as nsf.org or wqa.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 | 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).

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 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
associated
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
expensive.

Can be expensive.

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

Using disposable
bottles is not an
environmentally
sustainable
solution.

3Ts for Reducing Lead in Drinking Water: Plan Builder

45 | P a g e


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TAKING ACTION: TAKE IT WITH YOU

Taking Action Table 5: Fill in the table with long-term actions. The auto-populated text 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
under your or 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

Replaceme
nt 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 identify a point of
contact to ensure POU filters are
properly maintained. For details
refer to A Consumer Tool for
Identifying Point of Use (POU)
DrinkinE Water Filters Certified to
Reduce Lead [EPA/600/F-18/335 1
December 2018]

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.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.

~ 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.

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

No major construction
required.

3Ts for Reducing Lead in Drinking Water: Plan Builder

46 | P a g e


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TAKING ACTION: TAKE IT WITH YOU

Taking Action Table 6: 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. 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 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 post cards 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.

Taking Action Table 7: 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 Table 4)







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







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







8. Implement routine practices





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-------