K-12 Education:

Lead Testing of School Drinking Water Would Benefit from Improved Federal Guidance

GAO-18-382: Published: Jul 5, 2018. Publicly Released: Jul 17, 2018.

Multimedia:

  • PODCAST: Lead Testing in School Water

    As awareness about lead in water systems has grown, so too has concern over lead exposure in our schools. We explore the federal government's role when it comes to testing schools' water systems for lead. Is there room for improvement?

    View the transcript

Additional Materials:

Contact:

Jacqueline M. Nowicki
(617) 788-0580
nowickij@gao.gov

 

J. Alfredo Gomez
(202) 512-3841
gomezj@gao.gov

 

Office of Public Affairs
(202) 512-4800
youngc1@gao.gov

We surveyed school districts across the country on testing for lead in drinking water in 2017. Based on our nationally generalizable survey, we estimate that:

41% of districts, serving 12 million students, had not tested for lead in the 12 months before completing our survey.

43% of districts, serving 35 million students, tested for lead. Of those, 37% found elevated levels and reduced or eliminated exposure.

16% did not know if they had tested.

At least 8 states require schools to test for lead, and many others assist with voluntary testing.

We made 7 recommendations to promote testing and improve guidance for school districts.

(We updated this text to clarify the number of states requiring testing or assisting with voluntary testing.)

New Water Fountain Installed to Replace One that was Leaching Lead

Photograph of a new water fountain

Photograph of a new water fountain

Multimedia:

  • PODCAST: Lead Testing in School Water

    As awareness about lead in water systems has grown, so too has concern over lead exposure in our schools. We explore the federal government's role when it comes to testing schools' water systems for lead. Is there room for improvement?

    View the transcript

Additional Materials:

Contact:

Jacqueline M. Nowicki
(617) 788-0580
nowickij@gao.gov

 

J. Alfredo Gomez
(202) 512-3841
gomezj@gao.gov

 

Office of Public Affairs
(202) 512-4800
youngc1@gao.gov

What GAO Found

An estimated 43 percent of school districts, serving 35 million students, tested for lead in school drinking water in 2016 or 2017, according to GAO's nationwide survey of school districts. An estimated 41 percent of school districts, serving 12 million students, had not tested for lead. GAO's survey showed that, among school districts that did test, an estimated 37 percent found elevated lead (lead at levels above their selected threshold for taking remedial action.) (See figure.) All school districts that found elevated lead in drinking water reported taking steps to reduce or eliminate exposure to lead, including replacing water fountains, installing filters or new fixtures, or providing bottled water.

Estimated Percentage of Public School Districts Reporting Lead Testing and Results for Drinking Water

Note: GAO's survey was administered from July to October 2017 and asked school districts to report information based on the 12 months prior to their completing the survey. Testing estimates have a plus or minus 7 percent margin of error; elevated lead estimates have a plus or minus 10 percent margin of error at a 95 percent confidence level. Elevated lead refers to levels of lead above the school district's threshold for taking remedial action.

According to the Environmental Protection Agency (EPA), at least 8 states have requirements that schools test for lead in drinking water as of 2017, and at least 13 additional states supported school districts' voluntary efforts with funding or in-kind support for testing and remediation. In addition, the five states GAO visited provided examples of technical assistance to support testing in schools.

EPA provides guidance and other resources to states and school districts regarding testing and remediating lead in drinking water, and the Department of Education (Education) provides some of this information on its websites. School district officials that used EPA's written guidance said they generally found it helpful. Although EPA guidance emphasizes the importance of addressing elevated lead levels, GAO found that some aspects of the guidance, such as the threshold for taking remedial action, were potentially misleading and unclear, which can put school districts at risk of making uninformed decisions. In addition, many school districts reported a lack of familiarity with EPA's guidance, and their familiarity varied by region of the country. Education and EPA do not regularly collaborate to support state and school district efforts on lead in drinking water, despite agreeing to do so in a 2005 memorandum of understanding. Such collaboration could encourage testing and ensure that more school districts will have the necessary information to limit student and staff exposure to lead.

Why GAO Did This Study

No federal law requires testing of drinking water for lead in schools that receive water from public water systems, although these systems are regulated by the EPA. Lead can leach into water from plumbing materials inside a school. The discovery of toxic levels of lead in water in Flint, Michigan, in 2015 has renewed awareness about the danger lead exposure poses to public health, especially for children.

GAO was asked to review school practices for lead testing and remediation. This report examines the extent to which (1) school districts are testing for, finding, and remediating lead in drinking water; (2) states are supporting these efforts; and (3) federal agencies are supporting state and school district efforts. GAO administered a web-based survey to a stratified, random sample of 549 school districts, the results of which are generalizable to all school districts. GAO visited or interviewed officials with 17 school districts with experience in lead testing, spread among 5 states, selected for geographic variation. GAO also interviewed federal and state officials and reviewed relevant laws and documents.

What GAO Recommends

GAO is making seven recommendations, including that EPA update its guidance on how schools should determine lead levels requiring action and for EPA and Education to collaborate to further disseminate guidance and encourage testing for lead. EPA and Education agreed with the recommendations.

For more information, contact Jacqueline M. Nowicki at (617) 788-0580 or nowickij@gao.gov or J. Alfredo Gomez at (202) 512-3841 or gomezj@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: EPA agreed with this recommendation. In June 2019, EPA officials indicated that it had announced allotments for the WIIN Act in April 2019 and plans to publish the grant manual and open grants.gov this summer. EPA will review state workplans and begin the process to award the funds by late summer/early fall. The agency also said that they will use the new congressional appropriation for lead testing in schools as a means to improve consistency in the agency's approach. However, at this time we have not yet seen evidence that they are addressing what has been a varied approach to communicating the importance of testing for lead in school drinking water by EPA regional offices.

    Recommendation: The Assistant Administrator for Water of EPA's Office of Water should promote further efforts to communicate the importance of testing for lead in school drinking water to address what has been a varied approach by regional offices. For example, the Assistant Administrator could direct those offices with limited involvement to build on the recent efforts of several regional offices to provide technical assistance and guidance, and other forms of support. (Recommendation 1)

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: EPA published the revised 3Ts guidance in October 2018. The document can be found on EPA's public website. It explains that the action level currently described in the "3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance" is not a health-based standard, and recommends prioritizing drinking water outlets with the highest lead levels for remediation.

    Recommendation: The Assistant Administrator for Water of EPA's Office of Water should provide interim or updated guidance to help schools choose an action level for lead remediation and more clearly explain that the action level currently described in the 3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance is not a health-based standard. (Recommendation 2)

    Agency Affected: Environmental Protection Agency

  3. Status: Open

    Priority recommendation

    Comments: EPA generally agreed with this recommendation. In June 2019, EPA stated that the Lead in Copper Rule (LCR) revisions have not been proposed at this time. When EPA has proposed these revisions and considered whether to develop a health-based action level that incorporates available scientific modeling regarding vulnerable population exposures and is consistent with the LCR, we will close the recommendation.

    Recommendation: The Assistant Administrator for Water of EPA's Office of Water should, following the agency's revisions to the Lead and Copper Rule (LCR), consider whether to develop a health-based level, to include in its guidance for school districts, that incorporates available scientific modeling regarding vulnerable population exposures and is consistent with the LCR. (Recommendation 3)

    Agency Affected: Environmental Protection Agency

  4. Status: Open

    Priority recommendation

    Comments: EPA agreed with this recommendation. As EPA told us in June 2019, EPA has provided information on schedules for testing and actions to take if lead is found in school drinking water, but the agency did not offer documentation on such costs. Specifically, an October 2018 update to EPA's 3Ts guidance explains that while frequency of testing is dependent on a variety of factors, "annual monitoring provides information on changes in the lead levels and the effectiveness of remediation or treatment efforts as well timely notice of lead levels that need to be addressed." The 3Ts guidance also provides information on short and long term actions that schools and districts can take if lead is found in drinking water. However, EPA has not yet provided specific information on school districts' costs of testing and remediation. When EPA provides information on specific costs scenarios for both testing and remediation (through the 3Ts or other guidance such as case studies), we will close the recommendation.

    Recommendation: The Assistant Administrator for Water of EPA's Office of Water should provide information to states and school districts concerning schedules for testing school drinking water for lead, actions to take if lead is found in the drinking water, and costs of testing and remediation. (Recommendation 4)

    Agency Affected: Environmental Protection Agency

  5. Status: Open

    Comments: The Department of Education agreed with this recommendation. The agency said it would identify and include an information portal dedicated to enhancing the usability of federal resources related to testing for and addressing lead in school drinking water. Also, Education said it is interested in increasing coordination across all levels of government and it shares the view expressed in our report that improved federal coordination, including with EPA, will better enhance collaboration to encourage testing for lead in school drinking water. In 2019, Education said it planned to complete work on this recommendation by January 1, 2020. We will consider closing this recommendation when these efforts are complete.

    Recommendation: The Assistant Secretary for Elementary and Secondary Education should improve the usability of Education's websites to ensure that the states and school districts can more easily find and access federal guidance to address lead in school drinking water, by taking actions such as clarifying which links contain guidance; highlighting new or important guidance; improving their websites' search function; and categorizing guidance. (Recommendation 5)

    Agency Affected: Department of Education

  6. Status: Open

    Comments: EPA agreed with this recommendation. In June 2019, EPA indicated that it expects to sign an MOU with the Department of Education this summer. EPA said the MOU will aim to provide a more meaningful coordinated approach to help schools and child care programs and that it will be done in conjunction with the recently revised 3Ts toolkit. When EPA provides evidence that the agencies are actively collaborating to encourage testing for lead in school drinking water, we will close the recommendation.

    Recommendation: The Assistant Administrator for Water of EPA's Office of Water and the Director of the Office of Children's Health Protection should collaborate with Education to encourage testing for lead in school drinking water. This effort could include further dissemination of EPA guidance related to lead testing and remediation in schools or sending letters to states to encourage testing in all school districts that have not yet done so. (Recommendation 6)

    Agency Affected: Environmental Protection Agency

  7. Status: Open

    Priority recommendation

    Comments: The Department of Education agreed with this recommendation. The agency said it would develop a plan for disseminating relevant resources to its key stakeholder groups and explore how best to coordinate with states to disseminate EPA's guidance on lead testing and remediation to school districts. In 2019, the agency reported that it anticipates disseminating relevant resources to its key stakeholder groups and exploring how best to coordinate with states to disseminate EPA's guidance to school districts by January 1, 2020. We will consider closing this recommendation when these efforts are complete.

    Recommendation: The Assistant Secretary for Elementary and Secondary Education should collaborate with EPA to encourage testing for lead in school drinking water. This effort could include disseminating EPA guidance related to lead testing and remediation in schools or sending letters to states to encourage testing in all school districts that have not yet done so. (Recommendation 7)

    Agency Affected: Department of Education

 

Explore the full database of GAO's Open Recommendations »

Oct 24, 2019

Oct 22, 2019

Oct 18, 2019

Oct 16, 2019

Sep 25, 2019

Sep 24, 2019

Sep 18, 2019

Jul 29, 2019

Looking for more? Browse all our products here