K-12 Education: Lead Testing of School Drinking Water Would Benefit from Improved Federal Guidance
Fast Facts
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
Highlights
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.
Recommendations
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.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Environmental Protection Agency | 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) |
EPA has implemented this recommendation by taking several actions to communicate the importance of testing for lead in school drinking water. Specifically, as of June 2020, EPA awarded about $39 million to 48 states and the District of Columbia to support lead testing efforts and planned to make grant awards to the remaining states. In October 2019, EPA proposed an update to its Lead and Copper Rule to require water systems to test drinking water in schools and child care facilities upon request. EPA partnered with multiple federal agencies and other stakeholders who have agreed to communicate the importance of lead testing.
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| Environmental Protection Agency | 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) |
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.
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| Environmental Protection Agency |
Priority Rec.
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) |
EPA has implemented this recommendation by considering the role of a health-based benchmark for lead in drinking water. Specifically, EPA has proposed revisions to the Lead and Copper Rule. While the revisions do not specify a health-based benchmark, they do include proposed actions that could reduce lead exposure in drinking water. For example, the revisions include a provision for water systems to assist with testing drinking water in schools and child care facilities for lead. EPA also states that it sees value in providing states, drinking water systems, and the public with a greater understanding of the potential health implications for vulnerable populations of specific levels of lead in drinking water.
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| Environmental Protection Agency |
Priority Rec.
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) |
An October 2019 update to EPA's 3Ts guidance explains that while frequency of testing depends 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 the costs of testing as well as actions that schools and districts can take if lead is found in drinking water. EPA has provided information about costs of and funding issues associated with lead testing through a fact sheet on the Drinking Water State Revolving Fund as well as a webinar, developed with the Department of Education, for personnel involved in school emergency management planning.
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| Department of Education | 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) |
Education has taken steps to implement this recommendation. Specifically, Education has improved its technical assistance website and search functions, so that guidance on lead in school drinking water is appropriately categorized and easy to find. For example, the first items returned by searching 'lead' direct the user to the EPA's guidance on lead in school drinking water, also known as the 3Ts guidance.
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| Environmental Protection Agency | 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) |
EPA collaborated with the Department of Education (ED) by presenting information about lead testing and remediation in a webinar for school professionals through ED's Readiness and Emergency Management for Schools Technical Assistance Center and providing input through the Center's mobile app. ED also promoted EPA's webinars on the 3Ts through a departmental listserv and social media. As of July 2020, EPA reports that the agencies continue to collaborate and identify opportunities to conduct outreach related to lead in school drinking water.
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| Department of Education |
Priority Rec.
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) |
Education has implemented this recommendation by taking a number of steps to collaborate with EPA to encourage testing for lead in school drinking water. For example, Education collaborated with EPA to provide information about lead in school drinking water on a departmental technical assistance website and to hold a webinar for school safety officials on how to incorporate lead testing and remediation into school emergency planning. They are also collaborating to provide information about lead in school drinking water through a mobile app for school safety officials.
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