U.S. EPA 3Ts Program

Training, Testing & Taking Action

Lead Sample Collection
Field Guide

For Schools and Child
Care Facilities

PLAN

about lead
drinking wa1

your 3Ts
Program

and establish
routine
practices

sampling
plan

sampling and
interpret results

SEPA

OFFICE OF GROUND WATER
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-F-22-009
July 2022

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Purpose

The purpose of this Lead Sample Collection Field Guide is to provide clear
instructions to designated personnel on how to effectively and accurately
collect samples to test for lead in drinking water in schools and child care
facilities.

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 (referred to as "3Ts program"
hereafter).

Before collecting samples, go to Module 3: Planning your 3Ts Program to
establish a plan for:

(1)	Communicating (e.g., methods and frequency to communicate
results and actions to parents and staff);

(2)	Training (e.g., who and how personnel will be trained);

(3)	Testing (e.g., prioritize outlets for sampling and identify the type of
lead samples to collect); and

(4)	Taking Action (e.g., identify the type of short-term and/or long-term
measures to take if lead is detected).

Transparency and communication are key to developing a successful
program for reducing lead in drinking water in schools and child care
facilities. Use the 3Ts program resources, including step-by-step instructions
and interactive tools, to create your plan.

Connection to US EPA Drinking Water Regulation --
Lead and Copper Rule Revisions

The Lead and Copper Rule Revisions (LCRR) includes provisions for public water
utilities to conduct sampling in schools and child care facilities. However, as part of
President Biden's E.O. 13990 regulatory review of the LCRR, the agency received
stakeholder input suggesting improvements to these and other provisions. EPA will
be considering these suggestions as part of a planned immediate rulemaking and
non regulatory actions to equitably improve public health protection and improve
implementation of the rule to ensure that it prevents adverse health effects of lead
to the extent feasible. For more information, visit EPA's Review of the National
Primary Drinking Water Regulation: Lead and Copper Rule Revisions.

Funding for Reducing Lead in
Schools and Child Cares

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 listed here: WIIN 2107:
Lead Testing in School and Child
Care Program Drinking Water

State Grant Program Contacts.

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Why is this important?

There is no safe blood lead level in children. Children are most susceptible to the effects of lead
because their bodies are still developing; therefore, they tend to absorb more lead from any source,
including drinking water, than adults. Lead exposure in children can cause adverse health effects
both physical (e.g., impaired growth and hearing loss) and behavioral (e.g., reduced IQand attention
span, hyperactivity, and learning disabilities).

The only way to know if there is lead in your drinking water is to test each fixture used for human
consumption (i.e., drinking, food preparation, brushing teeth, dishwashing, and hand washing). EPA
suggests that schools and child care facilities implement lead testing programs for reducing lead in
drinking water as part of their overall plans for maintaining healthy learning environments.

•	It is important to establish a program that includes routine testing and evaluations to limit
lead contamination, as well as routine practices to ensure that you are providing safe
drinking water to students and staff.

•	It is important to identify lead fixtures and plumbing materials and be familiar with the
source of your drinking water. Some schools and child care facilities are served by nearby
public or private water systems, while others operate their own water systems and are
regulated under the Safe Drinking Water Act (SDWA). Even when water entering a facility
meets all federal and state public health standards for lead, older plumbing materials in
schools and child care facilities may contribute to elevated levels lead in their drinking
water. The potential for lead to leach into water increases the longer the water remains in
contact with leaded plumbing materials. As a result, facilities with intermittent water use
patterns, such as schools and child care facilities, are more likely to have elevated lead
concentrations in their drinking water.

•	Lead can enter your drinking water through the corrosion of lead-containing plumbing
materials within your facility or through the water service line connected to your school or
child care facility.

•	Building age and plumbing installations/repairs may increase the risk of elevated lead levels
in your drinking water if corrosion occurred in the plumbing materials. Factors to consider
may include:

o Buildings older than 1930: Likely to contain lead pipes that can contaminate water
quality.

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

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

o 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.

Is this Lead Sample Collection Field Guide for me?

This Guide is designed to support any school or child care personnel (e.g., maintenance staff, child
care support staff, on-site water system staff) who is asked to collect lead samples in drinking water
at their facility.

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The information and resources included in this guide will help the designated personnel
understand the procedures and process to follow to collect lead samples and provides actions to
consider based on laboratory results. For more details on remediation, refer to Module 6 in the
3Ts Toolkit or 3Ts Manual (published October 2018; EPA 815-B-18-007).

The sampling collection procedures outlined in this guide also meet the minimum requirements
for schools and child care facilities that are recipients of funding from their state grant program
as part of the Water Infrastructure Improvements for the Nation (WIIN) Act. States may have
additional procedures or processes to follow.

If you have questions about the WIIN grant program, you can find your state program at: EPA's
WIIN 2107: Lead Testing in School and Child Care Program Drinking Water State Grant Program
Contacts.

This guide assumes that each school and child care facility wiil run its testing program
independently. However, as you read through this guide, check with your state drinking
water/environmental program, certified laboratory, plumbing professional, or public water
system to see if they can help you with the sample collection.

do I use this Lead Sample Collection Field Guide?

•	Blue text indicates a hyperlink to a resource. Click the text to navigate to the link.

•	Text in brackets [ ] contain a hyperlink to applicable sections (i.e., Prepare, Collect, Results)
within the guide. Click the text to navigate to that section.

•	Section icons (below) are hyperlinked. Click the icon to navigate to a section of interest.

Prepare	1

.nnn.

Collect	7

Results	12

9

Helpful

Resources	16

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l^-l Prepare

Before collecting samples, facilities should develop a plan for (1) Communicating; (2) Training; (3)
Testing; and (4) Taking Action. Preparation is key for testing lead in drinking water. Use the "3Ts Plan
eBuilder" to create your plan at 3Ts program website.

Remember the importance of due diligence and the role you,
as the collector, are serving to help protect the children at your
facilities. It is important for personnel collecting the lead
samples to follow the steps as outlined in this Lead Sample
Collection Field Guide and use the sampling instructions
provided by your selected certified laboratory.

Use these steps to ensure proper preparation and effective
testing:

How Can Water Systems Help?

Your public water system are critical partners
iri helping schools and child care facilities test
for lead. They may be able to:

•	Offer technical guidance.

•	Help you develop sampling plans or
plumbing profiles.

•	Assist with sample collection and
laboratory analysis.

•	Support you in communicating lead
sample results to the community.

•	Help interpret results and determine
potential lead sources.

For more information, see the 3Ts for Public
Water Utilities factsheet or visit EPA's Final

Revisions to the Lead and Copper Rule to learn

more about the role of the system in sampling.

S Prioritize sample sites based on the plumbing profile
questionnaire (Module 4 in the 3Ts Toolkit) and your
existing knowledge of the building.

S Decide which certified laboratory will analyze your
samples for lead and ask if they can help you collect
the samples. To find approved,, certified labs, visit EPA
Certified Labs.

S Develop a coding and labeling system that clearly identifies each sample before collection.

S Collect all the materials listed in the [Prepare the Sample Sitel subsection below, before
conducting sampling on-site.

Lead Sampling Considerations

•	There is no safe blood lead level in children. Children are most susceptible to the effects of lead because their bodies
are still developing; therefore, they tend to absorb more lead from any source, including drinking water, than adults.

•	A sample test is a snapshot of the lead level taken at the time it was collected. Prior low or non-detected lead
levels should not be used to assume that an outlet or facility is lead-free. Lead levels at an outlet or within a building
have been shown to vary over time.

•	Regularly scheduled testing and routine maintenance are essential to reducing lead in drinking water. Consult with
your public water system for guidance.

•	Results from one outlet should not be used to generalize the lead levels at other outlets in the facility. Lead
contamination can occur both in fixtures and in building plumbing, so a sample taken at any given outlet is not
representative of the entire facility.

•	Buildings and fixtures built before 1986 are most likely to have lead solder and/or plumbing components that
contain lead. The 1986 Safe Drinking Water Act (SDWA) Amendments included a "lead ban" requirement stating that
only "lead-free" materials could be used in new plumbing and plumbing repairs. However, it is likely that lead pipes,
high-lead solder, and fluxes were used until 1990. The Reduction of Lead in Drinking Water Act of 2011 made the
definition of "lead free" more stringent by lowering the lead maximum lead content permitted. Up until 2014, even
those plumbing materials labeled as "lead-free" could contain up to 8% lead.

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~ Determine Which Fixtures to Sample

Many factors can contribute to selecting and prioritizing sampling locations. Some considerations:

•	Oldest known fixtures because these are more likely to contain lead (especially those installed
prior to the Lead Ban Act of 1986);

•	Sampling sites should be those used for human consumption;

•	Outlets that are used by children under the age of six or pregnant women (e.g., drinking
fountains, nurse's office, early childhood education classroom, kitchen, teachers' lounges);

•	Areas with known service lines or lead pipes;

•	Areas with corroded plumbing; and

•	Frequency of use. The longer the water remains in contact with the lead plumbing material, the
potential increases for lead to leach into the water.

Testing each fixture used for human consumption is important. During the first sampling round, if you
are not able to sample all fixtures in the building, the above factors can be used to prioritize the
sampling order. For example, first round samples may include drinking water fountains, water bottle
refill stations, sinks and kettles in kitchens, and nurse's office sinks If faucets are rarely used, consider
taking them out of service or designating them "not for human consumption," if they cannot be
sampled. For more information on prioritizing sampling site locations, refer to Module 4 in the 3Ts
Toolkit and answer the Plumbing Profile Questionnaire.

U Select a Certified Laboratory

Your school or child care facility should identify a

certified laboratory to analyze the water samples.

•	Use a laboratory certified by the state or EPA for
testing lead in drinking water. Certified laboratories
have been validated by EPA or the state to use
appropriate analytical techniques that guarantee
accuracy and precision.

•	Visit EPA's Website or your state WIIN grant program
to find a list of certified drinking water labs and refer
to Module 4 in the 3Ts Manual for a list of
considerations when choosing a laboratory. Your
selected certified laboratory will be able to provide
sampling bottles, labels, relevant paperwork, and
specific instructions. Some may also offer to send
qualified individuals to collect the samples for you
(Be sure to check with the laboratory to determine if
there will be an extra cost for their sampling
services).

Questions to Ask Certified Laboratories

/ What is the cost of the laboratory's services and
what is included?

Costs will vary, depending upon the extent of the
services provided (e.g., if only analyses are conducted
or if sample collection is provided as well), and some
laboratories may have bulk analysis rates for many
samples.

S How quickly do I need to send back the
sample(s)?

Each laboratory has a different way of storing and
preserving your sample from the minute you collect it,
so ask how long you have to send it back.

S What analytical techniques do you use?

Ask, do you use EPA approved methods that can meet
low enough reporting limits (e.g., at or below 1 ng/L)?
This way, you can confirm the accuracy of the results
reported.

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The laboratory will send a report back to you after their analysis is complete.

•	This report will show the numerical level of lead detected in the water samples. If a report is difficult
to understand, refer to Module 5 in the 3Ts Toolkit, call the laboratory with questions, or contact
your local water system.

Note: EPA strongly discourages the use of do-it-yourself (DIY) testing kits. These kits can be inaccurate
and many only indicate if lead is detected (i.e., no numerical values are provided). A numerical number
is needed for you to take the appropriate short-term or long-term action to reduce lead exposure.

~ Develop a Coding and Labeling System

The next step is to create a coding and labeling system that will allow each unique outlet to be
identified by location, type, and other relevant characteristics (e.g., room number, floor, etc.).

•	Use the 3Ts factsheet Develop a Code System for Samples (see Module 4 of the 3Ts Toolkit) to
create a labeling system. Additionally, create a document to record your sampling data and actions
taken based on the results; for example, use the 3Ts Sampling Data eTrackers.

How Do I Label My Sample Locations?

Code each outlet using a system that will allow each unique outlet to be identified by location, type, and other
relevant characteristics. Following is an example from Module 4 in the 3Ts Toolkit:

Floor Room Number Outlet Type Sample Type Sample Number

003-312-DW-P-015

Example: 3rd floor (003), room 312, drinking water (DW) fountain, first draw sample (P), 15th outlet collected
(015).

~ Prepare the Sample Site

Schools or child care facilities should request, from the certified laboratory, the appropriate number
of bottles and paperwork prior to sample collection.

Certified laboratories should send sampling bottles, labels, instructions, paperwork, and return shipping
box. Determine how many sample containers you will use for each fixture, and make sure the laboratory
has sent the appropriate number of containers. Leave the containers sealed until it is time to collect the
samples. For more details - view the 2-Step Sampling at the Tap in Module 5 in the 3Ts Toolkit.

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Note: Container size may vary.

EPA's 3Ts program recommends
250 mL plastic bottles that have
wide openings. However, you
may need a smaller container
depending on the purpose of the
sample. A smaller amount of
water sample may be necessary
for detailed fixture evaluations
to pinpoint where lead is getting
into the drinking water, so
appropriate corrective measures
can be taken. Due to the different compositions and dimensions of fixtures (e.g., water fountain, cold
water faucet, ice-making machine, central chiller unit) there are different sample collection procedures
for each fixture, refer to the [Collect! section for more details. Consult with your laboratory to confirm
they will be able to analyze the smaller sample volume. For more details see Module 5 in the 3Ts Toolkit
-- Detailed Fixture Evaluation.

Prepare the site location(s) and get ready to begin the sampling process.

Below is a list of items you will need to gather before collecting your sample. Place a checkmark by each
item as you collect it.

Materials Needed Before Conducting Sampling Procedure

~

Hand wipes or bottied water for washing hands. Avoid using water from the fixtures you are
sampling.

~

A permanent marker to keep careful track of which locations you have sampled on your
sampling plan (Pens may bleed or smear).

~

A notepad to record observations at the fixtures and any other relevant information.

~

A stopwatch to keep track of flush times (refer to the [Collec section for more details on
when this would apply to you).

~

Labeled sample containers (from the laboratory) to collect the water.

~

Sampling form to document additional details about the sampling environment. Use the
3Ts Samolina Data eTrackers1. The chain-of-custodv form from the laboratory mav also ask
for these details.

~

A smaii table to place materials on while collecting samples. Do not place materials on the
floor as they are easily contaminated there and more susceptible to being accidentally
knocked over.

a. Faucet

b. Bubbler

Water Volume captured (mL)

Source: Variability and sampling of lead (Pb) in drinking
water: Assessing potential human exposure depends on
the sampling protocol, Triantafyllidou, et al. December
16, 2020; Published by Elsevier Ltd.

1 For more information about the 3Ts Sampling eTrackers, visit the Receiving Results] subsection below.

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Materials Needed Before Conducting Sampling Procedure

~

Disposable plastic gloves (non-latex or nitrile) may be used to collect samples and avoid
direct contact with the sampling containers. Some laboratories may send sample
containers preserved with acid.

~

Labeled reference map of the building's floorplan or plumbing system to use while
sampling.

~

Signs alerting building users not to use the fixtures until after you have collected your
samples. These should be posted prior to the sampling date.

At the moment of taking the sample, the water should have sat in the pipes for at least eight (8)
hours, but for no more than eighteen (18) hours, prior to collection.

• These samples are typically collected in the morning before the facility opens and before the
fixtures have been used.

Example Sign

ATTENTION!!!

Do not use any water (including flushing toilets) in the building. We are collecting lead samples and this is a
procedural requirement.

Sampling Date: Friday, October 1, 2021

Time: Do not use water from 8:00 PM Thursday September 30th to 8:00 AM Friday October 1st

We appreciate your cooperation!

There should be no water usage at the school or childcare facility before sampling.

•	Plan accordingly to wash your hands, fill up any water bottles for personal consumption, and
use bathroom facilities before arriving on-site.

•	Prior to the sampling date, post signs with the date and time period of non-use to alert
building users that they should not turn on any water (including flushing toilets) in the
building. With teachers, maintenance, sports teams, and clubs potentially using facilities
after hours, be sure to communicate about sampling beforehand so there is no confusion or
accidental usage.

•	Take the following assurances before sampling:

S Make sure the area is free of potential contaminants, your materials are ready, and
you are fully prepared to begin sampling. It is better to focus on being thorough
while sampling, rather than collecting samples quickly.

S Place a checkmark by each task as you complete it. After reviewing and completing
the tables in this section, you can move onto the next section: [Collect!.

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~

Assurances to Take Before Conducting Sampling

~

The night before, post signs alerting people not to use the fixture (EPA recommends the
water should sit in the pipes for at least 8-hours, but no more than 18-hours, prior to
sampling). These samples are typically collected in the morning before the facility opens
and before any fixtures have been used.

~

Do not close the shut-off valves to prevent their use prior to sample collection, as this may
result in nonrepresentative results. It is important for the system to run normally to
receive results that represent typical use.

~

Do not use the facilities' restrooms or sinks that morning prior to sampling.

~

Wear gloves to avoid contaminating the samples and for your own safety, as some
laboratories may send sample containers preserved with acid.

~

Make sure there is no food, drink, or other substance around the sampling location that
could contaminate the sample.

~

Double check that all containers have been labeled and have no visible indication of
contamination (such as an ajar lid or hole in the container).

~

Verify with your map and sampling plan that you are at the correct fixture with the
correctly labeled sampling containers.

~

Set up your table next to the fixture with the sampling containers unopened and labeled,
in addition to any other necessary materials. Keep containers closed until you are ready to
collect the sample.

~

When you open the container, set the lid on the table facing up to avoid contamination
from contact. Keep the threads also facing up. If the threads or container interior are
touched, do not use the container.

~

Do not remove aerators prior to sampling. See Module 5 in the 3Ts Toolkit for details on
"Determining aerator/screen debris contribution".

~

If there are multiple floors, it is typically recommended to sample from the bottom floor
and continue up. Start sampling closest to where the water pipe comes into the building
and work away. Refer to Module 4 in the 3Ts Toolkit for more details.

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Collect

In this section, you will learn about the appropriate sampling techniques and best
practices to obtain accurate results, as well as how to properly ship your sample to the
laboratory for analysis. There are three potential sampling types that this guide covers
(Refer to Modules 4 and 5 in the 3Ts Toolkit for more details on sample types):

4 First-draw Samples

4 Flush Samples

4 Sequential Samples

Important Notes:

•	Collect all samples from cold water taps. Although EPA encourages routine
maintenance of hot water heaters, this guidance does not include sampling hot
water outlets or hot water heaters, because hot water is not recommended for consumption
(drinking/cooking). Refer to Module 6 under "Temperature Control" in Remediation and
Establishing Routine Practices in the 3Ts Toolkit.

•	After collecting the samples, you will need to ship them to the laboratory in a timely manner
(typically within 2 weeks). Carefully follow any packing and shipping instructions the laboratory
has sent. If no instructions were provided, please review the [Shipping Your Samples] section in
this guide for additional directions.

~ First-draw Samples

First-draw samples are typically collected in the morning before the facility opens and before the
fixtures have been used. Collect samples from the cold water tap.

•	First draw samples represent the water that may be consumed at the beginning of the day or
after infrequent use. These results will indicate if the fixture and its parts are a source of lead in
your water.

•	First draw samples are collected before a facility opens and before any water is used (including
flushing toilets) after an 8- to 18-hour stagnation period. EPA recommends the water should sit
in the pipes for at least 8 hours, but no more than 18 hours, prior to sampling. Using this
approach maximizes the likelihood that the highest concentrations of lead will be found because
the first 250-mL sample is collected after the water has sat in the pipes for at least 8-hours.

•	The flow rate when collecting the sample should be consistent and as high as feasible, without
splashing or overfilling.

•	Below is a checklist of steps you can use to complete a first-draw sample. Please refer to
instructions sent by the certified laboratory or your state program and use those if they differ
from the steps below.

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Instructions for First draw Sampling

~

1. Double check you have the correct sampling bottles for the sampling site.

~

2. Label containers with your coding identification (ID) (use the permanent marker),
if not already done.

~

3. Take out your recordkeeping document (e.g., chain-of custody-form, 3Ts Data
eTracker) for immediate access.

~

4. Put on gloves.

~

5. Place the opened container under the fixture ready for water collection.

~

6. Turn on the fixture and immediately fill the 250 mL container to the top (or

appropriately sized container based on the sample purpose), but do not overflow.

~

7. Turn off the fixture.

~

8. Close the container according to the laboratory's instructions. Tightly cap the
container and set it aside.

~

9. Record any observations that may impact the lead sample results, such as a leaking
faucet, water discoloration, or variable water pressure. You may also take photos
that will be useful when interpreting results. Reminder: Record the date, time, and
sample type.

~

10. Repeat steps 1-9 at each sampling site until you have the appropriate number of
samples requested.

~

11. Prepare the shipping container and send samples to the laboratory according to
the laboratory's instructions.

~ Flush Samples

Flush samples are taken after the water from the fixture has been running for a specific amount of
time, commonly 30 seconds. Collect samples from the cold water tap.

•	A flush sample is typically needed if the results of the initial first-draw sample detect lead.

•	Flush samples are used to further determine if lead is coming from the fixture itself or from
interior plumbing. Your state program or certified laboratory may instruct you to collect a flush
sample, or you may do so on your own based on an elevated lead level that was previously
detected.

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•	The purpose of the flushing is to rid the pipes of stagnant water so that you can better identify
the source of lead. These results will indicate if the pipes behind the fixtures and its parts are a
source of lead in the water.

•	Flush samples are collected before a facility opens and before any water is used (including
flushing toilets) after an 8- to 18-hour stagnation period.

/ For a more accurate result, samples taken from different fixtures that are near each
other should be collected on different days.

S For drinking fountains or other fixtures that are close together, a single flush sample
may be representative of their shared interior plumbing.

•	The flow rate when collecting the sample should be consistent and as high as feasible, without
splashing or overfilling.

•	EPA's 3Ts program recommends conducting a 2-step sampling procedure to identify if there is
lead in the outlet or behind the wall.

/ Step 1 is collecting the first-draw sample and step 2 is collecting the flush sample.

S You may collect flush samples in the same sample event or on a different day. Collecting
the samples in the same sampling event may reduce cost and provide you with more
information on lead levels sooner. In this case, the flush sample is collected immediately
after the first-draw sample.

S If the first-draw sample and the flush sample are not taken in the same sample event,
and your elevated lead level of concern is found in step 1, do not consume the water
while preparing to take the flush sample.

•	Below is a checklist of steps you can use to collect a flush sample. Please refer to instructions
sent by the certified laboratory or your state program and use those if they differ from the steps
below.

Instructions for Flush Sampling

~

1. If you did not collect the first-draw sample first, follow steps 1-4 in First Draw
Sampling checklist and then proceed to Step 2.

~

2. Turn on the fixture and start your stopwatch. Time the water so it runs for a fixed
amount of time, usually 30 seconds. Maintain a consistent rate of fiow during that
time.

~

3. After 30 seconds, fill the 250 mL container (or appropriately sized container based
on the sample purpose) to the top, but do not overflow.

~

4. Turn off the fixture.

~

5. Close the container according to the laboratory's instructions. Tightly cap the
container and set it aside.

~

6. Record any observations that may impact the lead sample results, such as a leaking
faucet, water discoloration, or variable water pressure. You may also take photos
that will be useful when interpreting results. Reminder: record the date, time, and
sample type.

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~

~

7. Repeat steps 1-6 at each sampling site until you have the appropriate number of
samples requested.

~

8. Prepare the shipping container and send samples to the laboratory according to
the laboratory's instructions.

~ Sequential Samples

Sequential samples involve collecting a series of water samples at a single fixture, without flushing
beforehand or running the water between samples. Collect samples from the cold water tap.

•	The purpose of a sequential sample is to pinpoint if your source of lead is from the fixture itself.
The samples you collect will represent water that was in contact with the fixture and any piping
or plumbing behind the wall.

•	How you collect the sample will depend on what fixture you are collecting the sample from. See

the Detailed Fixture Evaluation in Module 5 of the 3Ts Toolkit for specific instructions on how to
conduct sampling for each of these fixtures:

Most certified laboratories will provide shipping containers, so take advantage of this and closely
follow their instructions for packaging and shipping.

•	Bring the shipping kit with you to the sampling sites so that you can place finished containers
directly into it after confirming they are appropriately labeled.

•	Use the labeling system you created in [Develop a Coding and Labeling Svsteml. Document
your sample event information (e.g., date and time of sample collection, sample type, fixture
location, etc.) for each sample collected [Use the 3Ts Sampling Data eTrackers.1

Drinking Water Fountains
Drinking Water Fountains with
Coolers

4 Cold Water Faucets
4 Icemaking Machines
6 Central Chiller Unit

~ Shipping Your Samples

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• The lab typically will ask that you complete a chain-of-custody (COC) form to ensure the
contents of your sample are safely received by the appropriate entity [Figure 11. Use the
information from your Data eTracker or other recordkeeping to fill out the COC form.

Figure 1. Example of a Chain of Custody Record.

CHAIN OF CUSTODY

CLIENT NAME

John Doe Johnson

PROJECT:

ABC High School Lead in Water Sampling

ANALYSES REQUESTED

TURN AROUND TIME 1

D Standard
0 5 Day

~	3 Day
0 2 Day

~	24 Hours
0 Other

* 4:!v He ca,-s

|Lead (EPA 200.8) |





















ADDRESS

123 School Street.

Made Up. State

PHONE:
PAX.
EM- L

PROJECT MANAGER

SAMPLER

John Doe Johnson

SAMPLE ID

DATE
SAMPLED

TIME
SAMPLED

SAMPLE TYPE

CODE:

NOTES

TYPE
COKT

PRESER-
VATIVE

tor
corn

Method of Shipment

COMMENT^ '[

003-312-DW-P-015

1/1/2021

9:00

DW

Clear Sample Water

Plastic

None

1

X





















Sample taker. 3: wa-.er hiMi on 3ra floor
Destoe room 312 and the 15tfi outlet

































































































































































RELINQUISHED BY

Jo fin I>oe Jofinson

DATE / TIME

t/t/sost 12:00

RECEIVED BY

DA

E /

1Mb



SAMPLE CONDITION

Actual Temperate

Rsc*ive<] On toe Y / N
Preserved Y / N
Evidence Seals Presets Y I N
Container Attacked Y 1 N
Preserved at Lab Y / N

SAMPLE TYPE COOE

son Aqueous
Si -Swage
DW - Dining water
WW - waste Water
*w - "Ur water
GW- Ground Water
SO-Sou
sw - so«a watte
OL " Oi

RELINQUISHED BY

DATE / TIME:

RECEIVED BY

DATE 1 TIME

RELINQUISHED BY

DATE / TIME

RECEIVED BY

DATE / TIME

PRESCHEDULED RUSH ANALYSES WILL TAKE PRKDRITY
OVER UNSCHEDULED RUSH REQUESTS

SPECIAL REQUIREMENTS / BILLING INFORMATION

S fFigyre 11 shows an example COC form that your laboratory should send you with the
shipping instructions. Once completed, make a copy of the COC for your records and
place the original in the shipping container. The last step is to pack your samples and get
ready to ship them.

• Coordinate with your laboratory regarding a return date for your samples, typically within the
next two weeks.

¦S It is very important to ship your samples in a timely manner. Upon receipt, the

laboratory will acidify the sample to preserve it (unless they have already provided you
with preserved sample containers). If the laboratory fails to receive or analyze your
samples in time (as instructed), you may need to re-collect the sample and pay for the
additional sampling bottles the laboratory will send you.

S Follow any directions provided by the laboratory and consider the following best
practices for shipping:

¦ Ship your sample as soon as possible, preferably the same day after sampling is
conducted. Prepare ahead of time and avoid shipping on Fridays, around
holidays and long weekends, or during other times when shipping services may
be delayed.

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Results

This section will cover the steps you can take after you receive the lead sample results from your
selected laboratory. The steps include receiving and interpreting your results, taking action to address
problem fixtures, and sharing the results with your school or child care community.

~ Receiving Results

The laboratory will provide you with an estimated time frame that you will receive the results.

• Use the 3Ts Sampling eTrackers to record your lead sample results for each fixture.

Interactive Tool: EPA 3Ts Sampling eTrackers

The 3Ts Sampling eTrackers were developed to assist schools and child care facilities to track and document
sampling event information (i.e., inventory, results, actions). For WIIN grant recipients it also includes the date
elements needed to report to your state. You can access the eTrackers here: 3Ts Sampling eTrackers.

Common Lead Concentration Units

• Use this table to convert units of
measurement. Different units of
measurements are often used
between programs or documents.

~ Interpreting Results

Once you receive your lead sample results, you will need to determine which fixtures or plumbing
material need immediate, short term and/or permanent actions.

Results from one outlet should not be used to generalize the lead levels at other outlets in the facility
nor to determine the overall quality of your drinking water throughout the building.

•	Lead contamination can occur from fixtures, building plumbing, and/or lead service lines (i.e.,
the pipe that connects a water main to a user's premises). Refer to Module 4 in 3Ts Toolkit for
more details on "Do You Have a Lead Service Line?"

•	A sample result is a snapshot of the lead level taken at the time it was collected.

Prior low or non-detected lead levels should not be used to assume that an outlet or
facility is lead-free.

•	Lead levels at an outlet or within a building have been shown to vary over time whether it
be from usage frequency, seasonal variations, new or aging fixtures, or changes made by
your public water system.

Unit	Conversion

Parts per billion (ppb)

1 ppb = 1 ng/L = .001 ppm = .001 mg/L

Parts per million (ppm)

1 ppm = 1 mg/L = 1000 ppb = 1000 ng/L

Microgram per liter ([ig/'L)

1 |jg/L = 1 ppb = .001 mg/L = .001 ppm

Milligram per liter (mg/L)

1 mg/L = 1 ppm = 1000 ng/L = 1000 ppb

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It is important to establish a program that includes routine testing and evaluations to limit lead
contamination, as well as routine practices to ensure that you are providing safe drinking water to
students and staff.

Make sure you know your 3Ts Program Remediation Trigger (PRT) or level of concern before you
receive the lead sample results.

•	Contact your appropriate state agency and discuss your state's requirements.

S If you are a recipient of funding from your state's Water Infrastructure Improvements
for the Nation (WIIN) Act, the state will provide the PRT, unless you choose a lower
level.

¦ Visit EPA's WIIN 2107: Lead Testing in School and Child Care Program Drinking
Water State Grant Program Contacts to find your state program.

The numeric value for taking action is determined by you or your state. If that lead level
of concern or PRT is detected in your sample results, you should take immediate action
to reduce the lead exposure for that source.

Review your plan (which you prepared before sampling) to determine the action(s) you will take when
lead is detected.

•	The 3Ts program recommends taking immediate action (e.g., within 24 hours) for sample results
with "elevated lead levels" based on the 3Ts PRT or level of concern you selected.

~ Taking Action

Remember, there is no safe blood lead level in children. The 3Ts program recommends that you take
appropriate action on each drinking water outlet with a detected lead level; starting with the results
that exceed your level of concern or PRT.

•	Solutions to lead problems typically should be addressed on both a short-term and a long-term
basis.

When selecting a remediation solution, you should engage the local health
department, public water system, and other available resources to ensure the
organization performing remediation is qualified and reputable.

S Ask vendors for information on the schedule, health precautions that must be taken
during and following remediation and request regular status updates on their progress
prior to agreeing to work with any particular organization. Refer to Module 6 in the 31 s
Toolkit for more details.

•	It's important to remember that each result is intended to identify a specific source of lead. It's
not an indication of the lead levels throughout the entire building or the water system.

•	[Figure 21 shows some steps you can take to address fixtures that you have been tested for lead.

S There are immediate, short term (i.e., temporary), and permanent actions you can take
to prevent lead exposure. Refer to Module 6 in the 3Ts Toolkit, which includes
information on follow-up sampling, best practices for flushing, and remediation options
and considerations.

•	Ask your state program or local water system for tangible recommendations regarding your
specific lead sampling results.

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•	An elevated result that exceeds your PRT or state action level will require follow-up sampling,
which could include flush samples, service line flush samples (further discussed in the [Collectl
section), or a detailed fixture evaluation to pinpoint which part of the outlet or plumbing is
adding lead to your drinking water (discussed in more detail in the Detailed Fixture Evaluation in

Module 5 of the 3Ts Toolkit).

•	Note: Use the 3Ts Sampling eTrackers to track whether follow-up, remediation, and/or
replacement actions have been taken for each of the outlets sampled.

If your lead sample results detected lead levels that exceed your PRT or state action level, the 3Ts

program recommends taking immediate action (for example, within 24 hours) and use the remediation
options (i.e., short or long-term control measures) that you put in~place to reduce exposure.

•	See recommendations in [Figure 21 and refer to Module 6 in the 3Ts Toolkit for more details.

If your lead sample results detected lead levels below your PRT or state action level, the 3Ts program
recommends taking action to further minimize potential exposure.

•	Actions may include posting a sign at the fixture to inform that lead was found, installing filters,
implementing routine flushing, removing the fixtures from service, or replacing drinking water
fountains. See recommendations in fFrigure 21.

•	Next, start preparing for the next round of testing. Lead testing is an iterative process that
requires continuous efforts to help provide safer drinking water for your community and to
contribute to a healthy school or child care environment for all.

o At a minimum, EPA encourages annual sampling even when a sample result is non-
detect or low. Lead in drinking water can vary widely in space and in time (i.e., between
buildings, within buildings and even at the same fixture over time), as the combined
result of water chemistry, hydraulics, lead plumbing sources and water consumption
patterns. Refer to Module 6 in the 3Ts Toolkit, which includes remediation options and
routine practices.

~ Sharing Results and Actions

Regardless of the sample results, maintaining records is important for future sampling and remediation
efforts, schedules for upkeep and maintenance, and communicating with your school community and
partners and contacts that assisted you.

It is critical that you share your results and actions you took to reduce lead exposure with your
community members, including students, parents, staff, and anyone else who uses the building.

•	You can use resources from the 3Ts Toolkit to prepare your communication plan. Module 1 of
the 3Ts Toolkit includes newsletter templates, a parent letter template, a postcard template, a
customizable poster, and other guidance to help you communicate your testing program along
with the lead sample results and actions taken. It is important to be transparent in your
communications and to keep your community updated about past, ongoing, and upcoming
efforts.

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Figure 2. Steps to Consider After Receiving Your Sampling Results.

Taking Action After Receiving Your Sampling Results

Did the results exceed your 3Ts
Program Remediation Trigger?

What was the sample result?

f

Immediate Response

-	Use your actions as determined in your 3Ts plan

-	Use actions recommended in 3Ts Module 6

o Shut off problem fixtures
o Post "Not for Consumption" signs at

problem fixtures
o Reach out to your water system for
guidance

o Share test results with stakeholders (see

templates)

o Increase awareness and public education
(see josters/factsheets)

Non-detect

Below the Program
Remediation Trigger

Recommended Measures

-	Use your actions as determined in your 3Ts plan

-	Continue the testing, monitoring, and routine maintenance
measures in your 3Ts plan to ensure there is not lead in the
plumbing system

-	Consider implementing additional 3Ts routine maintenance,
flushing procedure, and aerator cleaning options

-	Share test results with stakeholders (see templates)

Conduct further
sampling and
implement control

measures.

Short Term Control Measures

-	Provide and maintain point of use
(POU) filters. See list of certified
filters at - A Consumer Tool for
Identifying Point of Use (POU)
Drinking Water Filters Certified to
Reduce Lead

•• Flush fixtures prior to use

-	Provide bottled water

-	Reach out to your water system for
guidance

Permanent Control Measures

-	Replace problem pipes or
fixtures

-	Provide and maintain filters
at problem fixtures

-	Replace any other plumbing
containing lead

-	Reconfigure plumbing

1

Follow-Up Sampling

-	Ensure additional samples are taken before
facility opens or water is used

-	Sample fixtures that have been replaced or
reconfigured piping

-	Compare results to original samples to see if
remediation efforts were successful

Recommended Measures to
Minimize Exposure

-	Use your actions as determined in
your 3Ts plan

-	Continue the testing, monitoring,
and/or routine maintenance options in
your 3Ts plan to minimize exposure to
lead in drinking water

-	Consider implementing additional 3Ts
routine maintenance, flushing
procedure, and aerator cleaning
options

-	Implement short-term and permanent
remediation action plans accordingly

-	Provide and maintain point of use
(POU) filters. See list of certified filters

at - A Consumer Tool for Identifying
Point of Use (POU) Drinking Water
Filters Certified to Reduce Lead

-	Post a sign at the fixture to inform that
lead was found and any action the
user should take

-	Share test results with stakeholders
(see templates)

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Helpful Resources

This Lead Sampling Collection Field Guide builds on EPA's continued efforts to provide proactive steps to protect children's health. Specific to lead testing and
water quality, EPA develops tools and materials for schools and child care facilities to use.

Visit the accompanying Lead Sample Collection Video: https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water

•	3Ts Revised Manual for Reducing Lead in Drinking Water in Schools and Child Care Facilities:

https://nepis.epa.gov/Exe/ZyPDF.cgi/P100VLI2.PDF?Dockev=P100VLI2.PDF

•	3Ts Toolkit: https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water

•	3Ts Sampling eTrackers: https://www.epa.gOv/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water#mod7

•	List of EPA Certified Labs: https://www.epa.gov/dwlabcert/contact-information-certification-programs-and-certified-laboratories-drinking-water

•	Lead Testing in School and Child Care Program Drinking Water Grant Contact Information: https://www.epa.gov/dwcapacitv/wiin-2107-lead-testing-
school-and-child-care-program-drinking-water-state-grant-program

•	EPA's Website on Certification of Laboratories: https://www.epa.gov/dwlabcert

•	EPA's National Accredited Laboratory List: https://www.epa.gov/lead/national-lead-laboratorv-accreditation-program-list

•	EPA's Website on Lead in Drinking Water in Schools and Childcare Facilities: https://www.epa.gov/dwreginfo/lead-drinking-water-schools-and-
childcare-facilities

•	EPA's Information on Maintaining or Restoring Water Quality in Buildings with Low or No Use: https://www.epa.gov/coronavirus/information-
maintaining-or-restoring-water-quality-buildings-low-or-no-use

•	EPA's Consumer Tool for Identifying POU Drinking Water Filters Certified to Reduce Lead: https://www.epa.gov/water-research/consumer-tool-
identifving-pou-drinking-water-filters-certified-reduce-lead

•	EPA's Water Infrastructure Improvements for the Nation Act Lead Testing in School and Child Care Program Grant:
http://www.epa.gov/safewater/grants

•	3Ts Child Care Poster: https://www.epa.gov/ground-water-and-drinking-water/3ts-child-care

•	EPA's Extended Closure Factsheets for Child Care Facilities and Schools: https://www.epa.gov/ground-water-and-drinking-water/audience-factsheets

•	EPA's Sample Collection Guide for Child Care Facilities Comic Strip: https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-
drinking-water#mod5

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