A+ Strategies for LCRR School and Childcare Sampling Compliance

• Reconciling LCRR-required sampling with any existing school or childcare sampling programs
• Addressing the prevalence of lead in sampling results
• Inter­pret­ing results – what concen­tra­tion is considered elevated or an exceedance
• Developing and managing a new and complex sampling program

The LCRR require­ments call for water systems to compile a list of all public and private schools (though grade 12) and licensed childcare facilities they provide water to by the official compliance date of October 16, 2024. This requirement applies across the board to all water systems in the country, regardless of the service line material serving a facility or if there are lead service lines in the system. These sampling require­ments exempt facilities constructed after January 1, 2014, or a state’s effective standard change related to the definition of lead-free fixtures. 

Water systems must educate all schools and childcare facilities about lead in drinking water, following LCRR-mandated language. Required to be sent yearly, public education materials must include language explaining health effects, sources of lead, and steps to reduce exposure. 

The EPA is already working on LCRR updates, or the Lead and Copper Rule Improve­ments (LCRI). While the LCRI may change certain aspects of the LCRR require­ments, CDM Smith does not expect any major changes to school and childcare sampling components, and any updates are forecasted to be very limited. Thus, now is the time to start thinking about school and childcare sampling. 

Another component to the LCRR is to notify facilities of sampling require­ments, differing depending on the facility type. Elementary schools are defined as containing any or all grades up to and including 8th grade, and secondary schools are 9th grade and above. For elementary schools and childcare facilities, water systems must notify of sampling require­ments and provide a proposed schedule, including information about sampling consistent with the EPA’s 3Ts guidance document. For secondary schools, or high schools, the water system must simply provide information on how to request that sampling be conducted. 

If the water system notifies the school of require­ments twice without response, then they can document this as a refusal and report it in their annual report to the State. Also, the water system is also allowed to have school or childcare staff take the samples themselves, provided instruc­tions are given.

The LCRR also has specific require­ments for sampling timelines and schedules. At a minimum, water systems must collect samples from at least 20% of elementary schools and childcare facilities every year starting in 2025. Following that, the water system must sample an additional 20% of the total facilities in each category every year. So, all elementary and childcare facilities will be sampled at least once by October 16, 2029. Water systems do have the option to complete a rolling sampling average of at least 20% per year (so if the they sample all 100% of facilities in year 1, years 2-5 can be 0%). High school facilities can request water systems to sample their water, as well. For this requested sampling, there is a 20% per year “limit” that the water system may employ. If more than 20% of high schools request to be sampled any year, the remaining can be “rolled-over” to the following year. Also, the water system is only required to sample each school 1 time in the 5-year cycle.

In schools, at least five samples of 250 milliliters (mL) must be collected. In childcare facilities, at least two samples of 250 mL must be collected. The water in the collected samples must have been motionless in the pipes (or in a “stagnation” period) for between 8 and 18 hours. The LCRR requires water systems provide a facility their results within 30 days of receiving the results from the lab with information regarding possible remediation activities.

The scope of the new LCRR sampling programs is likely larger than current sampling plans, which can be daunting for water systems. Adapting innovative approaches, like drop-ship sampling, to meet new regulatory needs is crucial to coordinate staffing and integrate multiple program schedules. Using platforms to order sample kits and manage results can offer automation and efficiency benefits for water systems. For example, Trinnex’s leadCAST allows you to order sampling kits, view sample results, and track your sampling progress at the ease of your computer.

The sampling process is really a joint effort between water systems and school and childcare facility staff. Keeping an open line of proactive commu­ni­ca­tion is key for a successful sampling program. Before any sampling is required, water systems can reach out to school board and childcare asso­ci­a­tions, helping them understand how to improve water quality in general. Providing visual fact sheets with step-by-step information is an efficient way to communicate water quality information. 

Helping the education community be more aware of water quality in general will make the sampling process feel less daunting. This also facilitates a supportive “team effort” mentality instead of the water system handing off results with an attitude of “good luck.” An atmosphere of shared purpose is beneficial to helping school and childcare staff take respon­si­bil­ity for maintaining the water quality of their buildings. 

Water systems can also use LCRR-required commu­ni­ca­tions to increase public trust, if approached thought­fully. The required annual public education – in this case, the “public” is school and childcare facilities – is a chance to explain the importance of getting lead out. While the LCRR only technically requires commu­ni­ca­tion from the water system directly to the schools and childcare facilities, systems should be prepared to talk about the program to the general public, as communities are often tuned into school-related endeavors. 

There are four other commu­ni­ca­tions touchpoints you can use to create a positive view of the sampling program: when you introduce the idea, pre-sampling, during-sampling, and when you report the results. Clearly commu­ni­cat­ing to the audience that receives each piece of information is key to correct sample collection and public under­stand­ing. An audience’s education level may determine if a text-based letter will work, or if a highly visual document with plain language steps is more appropriate. Meeting the audience where they are, whether that be commu­ni­cat­ing in other languages or with instruc­tional visuals, is crucial to ensure communities understand the programs taking place. 

At the end of the day, water system, school, and childcare facility staff are on the same team. They all have the same goal: protect our kids. Each entity can play a role in increasing public trust through a sampling program. By getting the child-oriented community on board with protecting water quality through simple commu­ni­ca­tion tailored to the audience, water systems and schools can unite in the mutual purpose to protect public health. 

Trevor McProud has 13 years of technical and regulatory experience in developing and imple­ment­ing the complex regulatory frameworks which water suppliers and other clients must navigate to provide their services and public resources. He led the oversight of the New York City Department of Health School Sampling Program for four years. 

Rose Hanson has 8 years of experience helping the public understand complicated technical and policy-related topics in the archi­tec­tural/engineering industry. Her experience includes leading public outreach and education efforts for lead service line inventories and replacement programs across the US.