K-12 Education: Lead Testing of School Drinking Water Would Benefit from Improved Federal Guidance
Released: 2018-07-17T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: 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.

section_title: What GAO Found
paragraphs: 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.

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.

section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: The discovery of toxic levels of lead in drinking water in Flint, Michigan in  2015 has renewed awareness about the risks that lead poses to public  health. Exposure to lead can result in elevated blood lead levels and  negative health effects. Children are at particular risk, because their  growing bodies absorb more lead than adults, so protecting them from  lead is important to lifelong good health. According to the Centers for  Disease Control and Prevention (CDC), elevated blood lead levels have  been linked to anemia, kidney and brain damage, learning disabilities,  and decreased growth. As a result of widespread human use, lead is  prevalent in the environment; for example, it can be found in paint and  soil, and can leach into drinking water from lead-containing plumbing  materials, such as faucets and drinking fountains.

Lead in school drinking water is a concern because it is a daily source of  water for over 50 million children enrolled in public schools. The pattern of  school schedules—including time off over weekends, holidays, and  extended breaks—can contribute to standing water in the school’s  plumbing system. If there is lead in the plumbing system, the potential for  it to leach into water can increase the longer the water remains in contact  with the plumbing. Other factors also influence the extent to which lead  enters the water, such as the chemistry of the water, the amount of lead  that comes into contact with the water, and the presence of protective  scales or coatings inside plumbing materials.

While there is no federal law requiring testing of drinking water for lead in  schools that receive water from public water systems, these water  systems themselves are regulated by the Environmental Protection  Agency (EPA) under the Lead and Copper Rule (LCR), as required by the  Safe Drinking Water Act (SDWA). Because the LCR regulates public  water systems, it does not directly address individual schools that are  served by a public water system. The federal government—including  EPA, the Department of Education (Education), and CDC—has a limited  role in addressing lead in school drinking water. These agencies, along  with other organizations, signed a memorandum of understanding in 2005  encouraging lead testing and remediation in schools, and they provide  information and guidance to stakeholders, such as state officials and  school districts. Several states and school districts have taken steps to  test for lead in school drinking water. States and school districts that  choose to test generally set their own threshold, or “action level,” of lead  found in drinking water that requires action, such as replacing a water  fountain or installing a filter. We use the term elevated lead in this report  to mean lead at levels above a selected action level.

You asked us to study the testing and remediation practices used to  protect children from lead. This report builds upon a separate 2017 review  that addresses schools with their own water source that are therefore  subject to federal requirements for lead testing and remediation under the  LCR. In this review, our objectives were to examine (1) the extent to  which school districts are testing for, finding, and remediating lead in  school drinking water; (2) the extent to which states require or support  testing for and remediating lead in school drinking water by school  districts; and (3) the extent to which federal agencies are supporting state  and school district efforts to test for and remediate lead.

To address our first objective, we drew a stratified, random sample of 549  school districts, administered a web-based survey from July to October  2017 asking whether they had tested for, found, or remediated lead in the  past 12 months, and achieved a 68 percent response rate. Based on the  design and response rate, estimates generated from these survey results  are generalizable to the population of public school districts. We also  conducted site visits to or interviewed officials with 17 school districts with  experience testing for lead in drinking water and selected to vary in  population density. These districts were located in five states—Georgia,  Illinois, Massachusetts, Oregon, and Texas—which were selected to vary  in geographic location and because they varied in the extent to which  they required school-based lead testing and remediation. To address our  second and third objectives, we used site visit information, requested  information about state requirements from selected state officials, and  interviewed officials in EPA’s headquarters and in all 10 regional offices,  and at Education and CDC. We reviewed relevant documents, such as  the 2005 memorandum of understanding and EPA guidance, as well as  relevant federal and state laws and regulations. For the states with testing  requirements, we reviewed relevant laws, regulations and policy  documents and confirmed our understanding of state testing  requirements with state officials. We provided the information about state  requirements to appropriate state officials for their review and  confirmation. We evaluated federal efforts to support lead testing and  remediation in schools against the actions prescribed in the memorandum  and federal standards for internal control, which call for agencies to  provide effective communication to external parties, among other things.  Appendix I contains a more detailed description of our objectives, scope,  and methodology.

We conducted this performance audit from October 2016 to July 2018 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: Elementary and Secondary Education School Facilities
paragraphs: According to Education, 50.3 million students were enrolled in more than  98,000 public elementary and secondary schools nationwide in the 2014- 2015 school year. These individual public schools are overseen by  approximately 16,000 local educational agencies (referred to in this report  as school districts) which are, in turn, overseen and supported by state  educational agencies. School districts can range in size from one school  (for example, in rural areas) to hundreds of schools in large urban and  suburban areas. For example, the 100 largest districts in the United  States together have approximately 16,000 schools and enroll about 11  million students. In addition, charter schools are public schools created to  achieve a number of goals, such as encouraging innovation in public  education. Oversight of charter schools can vary, with some states  establishing charter schools as their own school district and other states  allowing charter schools to be either a distinct school district in  themselves or part of a larger district. Charter schools are often  responsible for their own facilities; these may be located in non-traditional  school buildings, and may lease part or all of their space.

Typically, state educational agencies are responsible for administering  state and federal education laws, disbursing state and federal funds, and  providing guidance to school districts and schools across the state. State  educational agencies frequently provide funds for capital improvements to  school facilities, which school districts may use to address issues related  to lead in school drinking water, among other things. Different state  agencies, including agencies for education, health, and environmental  protection, may provide school districts with guidance on testing and  remediation of lead in school drinking water. Within a school district,  responsibility for water management may be held by individuals in  different positions, such as facilities managers or environmental  specialists.

section_title: Health Effects of Lead
paragraphs: Lead is a neurotoxin that can accumulate in the body over time with long- lasting effects, particularly for children. According to the CDC, lead in  drinking water can cause health effects if it enters the bloodstream and  causes an elevated blood lead level. Lead in a child’s body can slow  down growth and development, damage hearing and speech, and lead to  learning disabilities. For adults, lead can have detrimental effects on  cardiovascular, renal, and reproductive systems and can prompt memory  loss. In pregnant women, lead stored in bones (due to lead exposure prior  to and during pregnancy) can be released as maternal calcium used to  form the bones of the fetus, reduce fetal growth, and increase risk of  miscarriage and stillbirth. The presence of lead in the bloodstream can  disappear relatively quickly, but bones can retain the toxin for decades.  Lead in bones may be released into the blood, re-exposing organ  systems long after the original exposure. The concentration of lead, total  amount consumed, and duration of exposure influence the severity of  health effects. The health consequences of lead exposure can differ from  person to person and are affected by the cumulative dose of lead and the  vulnerability of the individual person regardless of whether the lead  exposure is from food, water, soil, dust, or air. Although there are medical  therapies to remove lead from the body, they cannot undo the damage it  has already caused. For these reasons, EPA, CDC, and others  recommend the prevention of lead exposure to the extent possible,  recognizing that lead is widespread in the environment.

section_title: The Safe Drinking Water Act
paragraphs: The SDWA authorizes EPA to set standards for drinking water  contaminants in public water systems. For a given contaminant the act  requires EPA to first establish a maximum contaminant level goal, which  is the level at which no known or anticipated adverse effects on the health  of persons occur and which allows an adequate margin of safety. EPA  must then set an enforceable maximum contaminant level as close to the  maximum contaminant level goal as is feasible, or require water systems  to use a treatment technique to prevent known or anticipated adverse  effects on the health of persons to the extent feasible. Feasible means  the level is achievable using the best available technology or treatment  technique.

In 1991 EPA issued the LCR, which it revised in 2000 and 2007,  establishing regulations for water systems covered by the SDWA. Lead  concentration in water is typically measured in micrograms of lead per  liter of water (also referred to as “parts per billion” or ppb). The rule  established a maximum contaminant level goal of zero, because EPA  concluded that there was no established safe level of lead exposure. EPA  decided not to establish an enforceable maximum contaminant level,  concluding that any level reasonably close to the goal would result in  widespread noncompliance, and therefore was not feasible. Instead, the  rule established an “action level” of 15 micrograms of lead per liter (15  ppb) in a one liter sample of tap water, a level that EPA believed was  generally representative of what could be feasibly achieved at the tap.  The action level is a screening tool for determining when certain follow-up  actions are needed, which may include corrosion control treatment, public  education, and lead service line replacement. Sample results that exceed  the lead action level do not by themselves constitute violations of the rule.  If the lead action level is exceeded in more than 10 percent of tap water  samples collected during any monitoring period (that is, if the 90th  percentile level is greater than the action level), a water system must take  actions to reduce exposure.

Several amendments to the SDWA are relevant to testing for lead in  school drinking water. In 1988, the SDWA was amended by the Lead  Contamination Control Act (LCCA), which banned the manufacture and  sale of drinking water coolers with lead-lined tanks containing more than  8 percent lead; the statute defined a drinking water cooler as containing 8  percent lead or less as “lead-free.” The LCCA also required states to  establish testing and remediation programs for schools. However, in  1996 a federal circuit court held that this requirement was  unconstitutional. In 2011, Congress passed the Reduction of Lead in  Drinking Water Act, which amended the SDWA by lowering the maximum  allowable lead content in “lead-free” plumbing materials such as pipes.  This provision became effective on January 4, 2014. In 2016, Congress  passed the Water Infrastructure Improvements for the Nation Act which,  among other things, amended the SDWA, to establish a grant program for  states to assist school districts in voluntary testing for lead contamination  in drinking water at schools. As a condition of receiving funds, school  districts are required to test for lead using standards that are at least as  stringent as those in federal guidance for schools. In March 2018,  Congress appropriated $20 million to EPA for this grant program.

section_title: Lead in School Drinking Water
paragraphs: Lead can enter drinking water when service lines or plumbing fixtures that  contain lead corrode, especially where the water has high acidity or low  mineral content. According to EPA, lead typically enters school drinking  water as a result of interaction with lead-containing plumbing materials  and fixtures within the building. Although lead pipes and lead solder  were not commonly used after 1986, water fountains and other fixtures  were allowed to have up to 8 percent lead until 2014, as previously  mentioned. Consequently, both older and newer school buildings can  have lead in drinking water. Some water in a school building is not for consumption, such as water from a janitorial sink or garden hose, so lead  in these water sources presents less risk to students. (See fig. 1.) The  best way to know if a school’s water is contaminated with lead is to test  the water after it has gone through a school’s pipes, faucets, and other  fixtures.

section_title: EPA Guidance for Schools
paragraphs: To facilitate testing efforts, EPA suggests that schools implement  programs for reducing lead in drinking water and developed the 3Ts for  Reducing Lead in Drinking Water in Schools: Revised Technical  Guidance (3Ts guidance) in 2006, which provides information on:  (1) training school officials about the potential causes and health  effects of lead in drinking water;  (2) testing drinking water in schools to identify potential problems  and take corrective actions as necessary; and  (3) telling students, parents, staff, and the larger community about  monitoring programs, potential risks, the results of testing, and  remediation actions.

The purpose of the 3Ts guidance is to help schools minimize students’  and staffs’ exposure to lead in drinking water. The guidance provides  recommendations and suggestions for how to address lead in school  drinking water, but does not establish requirements for schools to follow.  According to the guidance, if school districts follow the procedures  described in guidance, they will be assured their facilities do not have  elevated levels of lead in their drinking water. The guidance recommends  taking 250 milliliter samples of water from every drinking water source in  a school building and having the samples analyzed by an accredited  laboratory. Based on the test results of the samples, the guidance  recommends remedial action if the samples are found to have an  elevated concentration of lead, which is identified by using an action level.  While school districts may have discretion to set their own action level,  the 3Ts guidance strongly recommends taking remedial action if a school  district finds lead at or above 20 ppb in a 250 milliliter sample of water.

School districts can take a variety of actions including replacing pipes,  replacing fixtures, running water through the system before consumption  (known as flushing), or providing bottled water. However, since the  amount of lead in school drinking water may change over time for a  variety of reasons—for example, the natural aging of plumbing materials  or a disturbance nearby, such as construction—the results obtained by  one test are not necessarily indicative of results which may be obtained in  the future.

section_title: Roles and Responsibilities of Federal Agencies
paragraphs: With no federal law requiring testing for lead in school drinking water,  federal agencies play a limited role:

Education’s mission includes fostering educational excellence and  promoting student achievement, and the agency disseminates  guidance to states and school districts about lead in school drinking  water, but does not administer any related grants.

EPA’s Office of Ground Water and Drinking Water provides voluntary  guidance to schools on how to test for and remediate lead in school  drinking water, as part of EPA’s mission to inform the public about  environmental risks. In addition, EPA’s Office of Children’s Health  Protection is responsible for working with EPA’s 10 regional offices via  their healthy schools coordinators, who communicate with schools  and help to disseminate the 3Ts guidance.

CDC administers the School Health Policies and Practices Study, a  periodic survey to monitor national health objectives that pertain to  schools and school districts. The 2016 data, the most recent  available, provide information on the number of school districts that  periodically test for lead in their drinking water.

Under the 2005 memorandum signed by these three agencies to  encourage lead testing and remediation in schools, Education’s role  includes working with EPA and other groups to encourage testing, and  disseminating materials to schools. EPA agreed to update guidance for  schools, and provide tools to facilitate testing for lead in school drinking  water. CDC’s role includes identifying public health organizations to work  with and facilitating dissemination of materials to state health  organizations.

section_title: An Estimated 43 Percent of School Districts Reported Testing for Lead in Drinking Water and About a Third of These Districts Reported Finding Elevated Levels of Lead
paragraphs: Lead in School Drinking Water Survey Results at a Glance

An estimated 43 percent of school districts tested for lead in  school drinking water, but 41 percent did not, and 16 percent did  not know.  o  Some districts tested drinking water in all sources of  consumable water in all of their schools, while other  school districts tested only some sources.  o  Among the reasons for not testing, school districts said  they either did not identify a need to test or were not  required to do so.

Of those that tested, an estimated 37 percent of school districts  found elevated  lead levels—levels of lead above the district’s  threshold for taking remedial action—in school drinking water.  o  School districts varied in terms of the threshold they used,  with some using 15 ppb or 20 ppb and others using a  lower threshold.

School districts varied in whether they tested for lead in school  drinking water and whether they discovered elevated levels of  lead. For example, an estimated 88 percent of the largest 100  school districts tested compared with 42 percent of other school  districts.

All school districts that found elevated lead reported taking steps  to reduce or eliminate the lead, including replacing water  fountains or providing bottled water.
subsections: section_title: An Estimated 43 Percent of School Districts Reported Testing for Lead in Drinking Water in the Last 12 Months, but 41 Percent Have Not Tested
paragraphs: Nationwide, school districts vary in terms of whether they have tested for  lead in school drinking water, with many not testing. According to our  survey of school districts, an estimated 43 percent tested for lead in  school drinking water in at least one school in the last 12 months, while  41 percent had not tested. An estimated 35 million students were  enrolled in districts that tested as compared with 12 million students in  districts that did not test. An estimated 16 percent of school districts,  enrolling about 6 million students, reported that they did not know whether  they had tested or not. (See fig. 2.)

Of school districts that tested for lead in school drinking water, some  tested all consumable water sources in all of their schools, while others  may have only tested some sources in all schools or all sources in some  schools. Among the reasons provided by survey respondents for not  testing in all schools, some said the age of the building was the primary  consideration. For example, an official in one school district we visited  told us they began testing in buildings constructed before 1989, but after  receiving results that some water sources had elevated lead levels, the  district decided to test all of their school buildings. Other reasons reported  for testing some, but not all, schools included testing schools only when a  complaint about discolored water was received or testing only new  schools or schools that were renovated. In addition, school districts varied  in whether they sampled from every consumable water source, or just  some of the sources, in their schools. For example, one district official  told us they took one sample from each type of water fountain in each  school, assuming that, if a sampled fountain was found to have an  elevated level of lead, then all of the other fountains of that type would  also have elevated lead levels. However, EPA’s 3Ts guidance  recommends that every water source that is regularly used for drinking or  cooking be sampled. Further, stakeholders and environmental and  educational officials we interviewed said that results from one water  fountain, faucet, or any other consumable water source cannot be used to  predict whether lead will be found in other sources.
subsections: section_title: Cost of Testing
paragraphs: In our survey, the median amount spent by school districts to test for lead  in school drinking water during the past 12 months varied substantially,  depending on the number of schools in which tests were conducted (see  table 1). School districts may have paid for services such as collecting  water samples, analyzing and reporting results, and consultants. For  example, an official in a small, rural school district—with three schools  housed in one building—told us his district spent $180 to test all eight  fixtures. In contrast, officials in a large, urban school district told us they  spent about $2.1 million to test over 11,000 fixtures in over 500 schools.  Some school districts, especially larger ones, incurred costs to hire  consultants to advise them and help design a plan to take samples,  among other things.

EPA’s 3Ts guidance recommends determining how to communicate  information about lead testing programs with parents, governing officials,  and other stakeholders before testing. Of school districts that reported  testing for lead in school drinking water in our survey, an estimated 76  percent informed their local school board and 59 percent informed  parents about their plans to test; similar percentages provided information  about the testing results. We identified a range of approaches to  communicating testing efforts in the 17 school districts we interviewed.  Some school districts reported issuing press releases, putting letters in  multiple languages in students’ backpacks, sending emails to parents,  holding public meetings, and releasing information through social media.  Before testing, one district created a website with a list of dates when it  planned to test the drinking water in every one of its schools. In contrast,  other school districts communicated with parents and the press only upon  request. Officials in one district we visited said they did not post lead  testing results on their website, because they wanted to avoid causing  undue concern, adding that “more information isn’t necessarily better,  especially when tests showed just trace amounts of lead.”

section_title: Plans to Conduct Testing on a Recurring Basis
paragraphs: School districts generally have discretion to determine how frequently  they test for lead in school drinking water except when prescribed in state  law, and most school districts responding to our survey had no specific  schedule for recurring testing. Specifically, an estimated:

27 percent of school districts plan to test “as needed,”

25 percent have no schedule to conduct recurring tests, and

15 percent do not know.

The remaining school districts reported a range of frequencies for  conducting additional tests or said they were developing a schedule to  conduct tests on a recurring basis. School district officials and  stakeholders we interviewed told us that it is important to test for lead in  drinking water on a recurring basis, because lead can leach into school  drinking water at any time.

section_title: Reasons School Districts Reported for Not Testing
paragraphs: In our survey, we asked school districts reporting that they had not tested  for lead in school drinking water in the last 12 months (41 percent of  districts) to provide us with one or more reasons why they had not  tested. Of these school districts, an estimated 53 percent reported that  they did not identify a need to test and 53 percent reported they were not  required to test (see fig. 3).

section_title: An Estimated 37 Percent of School Districts That Reported Testing Found Elevated Levels of Lead in Drinking Water
paragraphs: Of school districts that reported testing for lead in school drinking water,  an estimated 37 percent of districts found elevated levels of lead in school  drinking water, while 57 percent of districts did not find lead (see fig. 4).  Of those that found lead in drinking water, most found lead above their  selected action level in some of their schools, while some districts found  lead above their action level in all of their schools. For example, officials  in one large school district told us they tested over 10,000 sources of  water, including drinking fountains and food preparation fixtures, and  found that over 3,600 water sources had lead at or above the district’s  action level of 15 parts per billion (ppb). The findings resulted in extensive  remediation efforts, officials said.

Further, district officials reported different action levels they used to  determine when to take steps such as replacing a water fountain or  installing a filter. School districts generally may select their own action  level, resulting in different action levels between districts. Of school  districts that reported testing for lead in school drinking water, an  estimated 44 percent set an action level between 15 ppb and 19 ppb.  The action levels chosen by the rest of the school districts ranged from a  low of 1 ppb whereby action would be taken if any lead at all was  detected to a high 20 ppb where action would be taken if lead was found  at or above 20 ppb. (See appendix II for the estimated percentage of  school districts that set other action levels.)

section_title: School Districts’ Lead Testing Efforts and Discovery of Elevated Lead Levels Varied Based on the Size, Population Density, and Location of the District
paragraphs: Though fewer than half of school districts reported testing for lead in  school drinking water, our analysis of school districts’ survey responses  shows that these estimates varied depending on the size and population  density of the district as well as its geographic location. For example,  among the largest 100 school districts, an estimated 88 percent reported  they had tested for lead in school drinking water in at least one school in  the last 12 months compared with 42 percent of all other districts  nationwide. An estimated 59 percent of the largest 100 school districts  that tested discovered elevated levels of lead compared to 36 percent of  all other districts that tested (see table 2).

In addition, an estimated 86 percent of school districts in the Northeast  region of the United States tested for lead in school drinking water,  compared to less than half of school districts in other geographic regions.  Similarly, about half of school districts in the Northeast and about 8  percent in the South found elevated levels of lead, compared to their  selected action level. (See fig. 5.)

section_title: All School Districts with Elevated Lead in Drinking Water Reported Taking Action, Such as Replacing Water Fountains or Flushing Pipes
paragraphs: In our survey, every school district that reported finding lead in school  drinking water above their selected action level reported taking steps to  reduce or eliminate the lead. For example, an estimated 71 percent said  they replaced water fountains, 63 percent took water fountains out of  service without replacing them, and 62 percent flushed the school’s water  system (see fig. 6).

School districts officials we interviewed told us they took a range of  remedial actions generally consistent with those reported to us in our  survey. For example, an official in one district told us that 129 of the 608  fixtures tested above the district’s action level of “any detectable level.”  He said they installed filters on all of the 106 sink faucets with elevated  lead and replaced all of the 23 drinking fountains with elevated lead.  The district official explained that they re-tested fixtures after the filters  and new fountains were installed, and did not detect any lead in their  drinking water. Officials in another school district told us that  approximately 3,600 of their fixtures were found to have lead above their  action level of 15 ppb. They told us the district turned off the water at the  affected fixtures as an interim measure and provided bottled water to  students and staff. Though they had not yet finalized their plans at the  time of our interview, they said they were planning to replace the fixtures  and replace old pipes with new pipes. District officials said they plan to  pay for their remediation efforts using local capital improvement funds  from a recently-approved bond initiative.

Similar to the cost of testing, the median amount spent by school districts  to remediate lead in school drinking water during the past 12 months  varied substantially, depending on the number of schools in which a  district took action to remediate lead (see table 3). The median  expenditure for school districts taking action in one to four schools was  $4,000 compared to a median expenditure for school districts taking  action in 51 or more schools of $278,000.

section_title: Several States Require School Districts to Test for Lead in Drinking Water and Additional States Provide Funding and Technical Assistance
subsections: section_title: At Least Eight States Require School Districts to Test for Lead as of 2017, According to EPA
paragraphs: EPA regional officials provided examples of eight states that have  requirements for schools to test for lead in drinking water as of  September 2017: California, Illinois, Maryland, Minnesota, New Jersey,  New York, Virginia, and the District of Columbia. State requirements  differ in terms of which schools are included, testing protocols,  communicating results, and funding. (See fig. 7.) (For a list of testing  components for the eight states, see appendix IV.)

According to stakeholders we interviewed, most state legislation on  testing for lead in school drinking water has been introduced in the past 2  years. Of the eight states, three states have completed one round of  required testing, while other states are in the early stages of  implementation or have not yet begun, according to state officials. School  districts in Illinois, New Jersey, and New York completed a round of  testing for lead in school drinking water by December 2017. Testing in the  District of Columbia was in progress as of April 2018. Minnesota requires  school districts to develop a plan to test by July 2018 and California  requires that water systems sample all covered public schools in their  service area by July 2019. According to state officials, schools in  Maryland must test by July 2020. In Virginia, no timeline for testing is  indicated in the requirement.

In addition, requirements in these eight states vary in terms of covered  schools and frequency of testing. For example, in Maryland, all schools,  including charter and private schools, are required to test their water for  lead by July 2020 and must re-test every 3 years. After regulations were  approved in July 2016, New Jersey required testing within a year in all  traditional public schools, charter schools, and certain private schools,  and re-testing every 6 years, according to state officials. Illinois’  requirement is for public and private elementary schools constructed  before 2000 to test their drinking water for lead, and does not mandate re- testing. Seven of the eight states include at least some charter schools in  their testing requirements (New York does not).

State testing requirements also differ in terms of action level, sample  sizes, and number of samples, according to state documents. States can  choose their own lead threshold or action level for remediation, and the  eight states have chosen levels ranging from any detectable level in  Illinois to 20 ppb in Maryland. Six of the eight states have chosen to use  250 milliliter samples of water, while California is using a one liter sample  size, and Virginia delegates to school districts to choose their action level  and sample size. Some states specify that all drinking water sources in  a building must be tested, such as in New York and New Jersey, or allow  a smaller number of samples to be tested, such as in California, which  recommends that water systems take between one and five samples per  school. To implement its testing requirement, the District of Columbia has  installed filters in all school drinking water sources, and plans to test the  filtered water from each fixture for elevated lead annually.

The responsibility for the costs of testing and remediation also differ by  state. According to state officials, in Minnesota, the costs of testing may  be eligible for reimbursement from the state, and in the District of  Columbia, the Department of General Services is responsible for the  cost. California requires that public water systems cover the cost of testing for all public schools in their jurisdiction. In all other states we  looked at, schools or school districts are at least partially responsible for  the costs of testing. Additionally, most schools or school districts are  responsible for the costs of remediation, although Minnesota, New York,  and the District of Columbia will provide funds to help with the costs of  remediation as well.

Seven of the eight state requirements have a provision for communicating  the results of lead sampling and testing in schools. For example,  Minnesota requires all test results be made public and New York requires  that results be communicated to students’ families. Maryland and New  Jersey require that results above the action level be reported to the  responsible state agency, such as the Department of the Environment or  the Department of Education, and that sample results that find elevated  levels of lead be communicated to students’ families. Illinois requires that  all results be made available to families and that individual letters to  families also be sent if lead levels over 5 ppb are found. In contrast,  Virginia does not include a provision to communicate testing results in its  testing requirement for schools.

According to stakeholders and state officials we interviewed, states have  several other common issues to consider in implementing a state testing  and remediation program. First, states need to ensure that their efforts,  which can be significant given the thousands of schools that operate in  each state, can be completed with limited resources and by a legislated  deadline. Second, coordination between relevant state agencies, which  will vary by state, may be challenging. Because of the nature of testing for  lead in school drinking water, multiple government agencies may be  involved, necessitating a balance of responsibilities and information- sharing between these state agencies. Finally, state officials told us that  imposing requirements without providing funding to implement them may  be a challenge for schools in complying with testing and remediation  requirements.

section_title: Additional States Provided Funding and Technical Assistance to Support School District Efforts to Test for and Remediate Lead
paragraphs: Apart from the states with requirements to test for lead in school drinking  water discussed in this report, at least 13 additional states had also  provided funding or in-kind support to school districts to assist with  voluntary lead testing and remediation, according to EPA regional offices.  Those states are Arizona, Colorado, Idaho, Indiana, Maine,  Massachusetts, Michigan, New Mexico, Ohio, Oregon, Rhode Island,  Vermont, and Washington. In Massachusetts, for example, officials told  us the state used $2.8 million from the state Clean Water Trust to fund a  voluntary program for sampling and testing for all participating public  schools in 2016 and 2017. Massachusetts contracted with a state  university to assist schools with testing for lead in drinking water. When  the program completed its first round of testing in February 2017, 818  schools throughout the state had participated, and the state has begun a  second round of sampling with remaining funds from the Clean Water  Trust.  In Oregon, officials told us the state legislature provided funding  for matching grants of up to $8 million to larger school districts for  facilities improvements, and made $5 million of emergency funds  available to reimburse school districts for laboratory fees associated with  drinking water testing as part of the state’s efforts to address student  safety.

States can also provide technical assistance to support school districts in  their efforts to test for and remediate lead in drinking water. The five  states we visited provided a range of technical assistance to school  districts. For example, to implement the voluntary assistance program in  Massachusetts, the contracted university told us they hired 15 additional  staff and assisted schools in designing sampling plans, taking samples,  and sending them for testing. University officials told us they oversaw the  sampling of all drinking water sources in each participating school and  sent the sample to state certified laboratories for analysis. State officials  encouraged schools to shut off all fixtures in which water tested at or  above the action level of 15 ppb and provided guidance on actions to  take, such as removing and replacing fixtures, using signage to indicate  fixtures not to be used for drinking water, and implementing a flushing  program. The state developed an online reporting tool so that all test  results could be publicly posted. State officials also supported schools in  communicating lead testing results to parents and the community.

Other states we visited provided technical assistance to school districts  through webinars, guidance documents, in-person presentations, and  responding to inquiries. In Oregon, the state Department of Education  and the state Health Authority collaborated in 2016 to provide guidance to  schools on addressing lead in drinking water. The Governor issued a  directive requesting all school districts test for lead in their buildings and  the Health Authority requested that districts send them the results. In  Texas, officials at the Commission for Environmental Quality have made  presentations to schools on water sampling protocols and provided  templates for school districts to communicate results. Officials told us that  an increased number of school districts have contacted them in the past  year seeking guidance, and, in response, they directed districts to EPA’s  3Ts guidance and a list of accredited laboratories. In Illinois, state officials  partnered with the state chapter of the American Water Works  Association to provide a guidance document for drinking water sampling  and testing to assist schools in complying with new testing requirements.  In Georgia, officials at the Department of Natural Resources told us they  promote the 3Ts guidance on their website and have offered themselves  as a resource on school testing at presentations with local water  associations.

section_title: EPA Provides Several Resources on Lead, but EPA and Education Should Provide More Information to Support States and School Districts and Improve Collaboration
subsections: section_title: EPA Provides Guidance, Training, and Technical Assistance on Lead Testing and Remediation, but States and School Districts Need Updated Guidance
paragraphs: EPA provides several voluntary resources, such as guidance, training,  and technical assistance, to states and school districts regarding testing  for and remediation of lead in school drinking water, but some school  districts we surveyed and officials we interviewed said more information  would be helpful. The Lead Contamination Control Act of 1988 (LCCA)  required EPA to publish a guidance document and testing protocol to  assist schools in their testing and remediation efforts. EPA’s Office of  Ground Water and Drinking Water issued its 3Ts guidance which  provides information on training school officials, testing drinking water in  schools, and telling the school and broader community about these  efforts. Of the school districts that reported in our survey using the 3Ts  guidance to inform their lead testing efforts, an estimated 68 percent  found the guidance extremely or very helpful for conducting tests. The  Office of Ground Water and Drinking Water also developed an additional  online resource—known as the 3Ts guidance toolkit—to further assist  states and school districts with their lead in drinking water prevention  programs by providing fact sheets and brochures for community  members, among other things. Some states have used the 3Ts  guidance as a resource for their state programs, according to EPA  officials. For example, a New York regulation directs schools to use the  3Ts guidance as a technical reference when implementing their state- required lead testing and remediation programs.

The Office of Ground Water and Drinking Water provides training to  support states and school districts with their lead testing and remediation  programs. In June 2017, EPA started a quarterly webinar series to  highlight school district efforts to test for lead. These webinars include  presentations from school officials and key partners that conducted lead  testing and remediation. For example, on June 21, 2017, officials from  Denver Public Schools and Denver Water presented on their efforts to  test for lead in the public school system.

EPA’s approach to providing guidance and technical assistance to states  and school districts is determined by each of the 10 EPA regional offices.  Some EPA regional offices provide the 3Ts guidance to school districts  upon request and others conduct outreach to share the guidance,  typically through their healthy schools coordinator when discussing other  topics, such as indoor air quality and managing chemicals. EPA regional  offices also provide technical assistance by request, typically through  phone consultations with school districts that have questions regarding  the 3Ts guidance, according to EPA headquarters officials. Officials also  indicated that the agency has received more requests for technical  assistance from schools over the past few years regarding lead in  drinking water. Officials in EPA Regions 1 in Boston and 2 in New York  City told us they provided technical assistance to school districts by  conducting lead testing and analysis in school facilities and Region 9 in  San Francisco provided technical assistance by reviewing school district  testing protocols. For example, EPA Region 2 officials said between  2002 and 2016 they worked with one to two school districts per year to  assist with their lead testing efforts. As part of this effort, the regional  office provided funding for sampling and analysis. Officials said they  prioritized school districts based on population size and whether the  community had elevated blood lead levels. Other EPA regional office  approaches included identifying resources and guidance for relevant state  agencies and facilitating information sharing by connecting districts that  have tested for lead with districts that are interested in doing so.  However, most EPA regional offices do not provide technical assistance  in the form of testing, analysis, or remediation to school districts, and  some do little or no outreach to communicate the importance of testing for  and remediating lead in school drinking water. According to federal  standards for internal control, management should externally  communicate the necessary quality information to achieve the entity’s  objectives.

Each EPA regional office’s approach to providing resources to states and  school districts varies based on differing regional priorities and available  resources, according to EPA headquarters officials. Additionally, officials  said that this decentralized model of providing support and technical  assistance related to lead testing and remediation in schools is  appropriate because of the number of schools across the United States.  However, based on our survey we found school district familiarity with the  3Ts guidance varied by geographic area (see fig. 8). An estimated 54  percent of school districts in the Northeast reported familiarity with the  3Ts guidance, compared with 17 percent of districts in the South.  Furthermore, the Northeast was the only geographic area with more  school districts reporting that they were familiar with the 3Ts guidance  than not. This awareness corresponds with the efforts made by the state  of Massachusetts and EPA’s regional offices in the Northeast to distribute  the 3Ts guidance and conduct lead testing and remediation in school  districts.

By promoting further efforts to communicate the importance of lead  testing to schools to help ensure that their lead testing programs are in  line with good practices included in the 3Ts guidance, EPA regional  offices that have not focused on this issue could leverage the recent  efforts of other regional offices to provide technical assistance and  guidance, and other forms of support.

EPA’s 3Ts guidance emphasizes the importance of taking action to  remediate elevated lead in school drinking water, but the agency’s  guidance on a recommended action level for states and school districts is  not current and contains elements that could be misleading. Although the  guidance recommends that school districts prioritize taking action if lead  levels from water fountains and other outlets used for consumption  exceed 20 ppb (based on a 250 milliliter water sample), EPA officials told  us when the guidance was originally developed in response to the 1988  LCCA requirement, the agency did not have information available to  recommend an action level specifically designed for schools.  Furthermore, EPA officials told us that the action level in the 3Ts  guidance is not a health-based standard. However, there are statements  in the guidance that appear to suggest otherwise. For example, the  guidance states that EPA strongly recommends that all water outlets in all  schools that provide water for drinking or cooking meet a “standard” of 20  ppb lead or less and that school officials who follow the steps included in  the document, including using a 20 ppb action level, will be “assured” that  school facilities do not have elevated lead in the drinking water. The use  of the terms “standard” and “assured” are potentially misleading and  could suggest that the 20 ppb action level is protective of health.

Further, state and school district officials may be familiar with the 15 ppb  action level (based on a 1 liter water sample) for public water systems  aimed at identifying system-wide problems under the LCR, which may  also create confusion around the 20 ppb action level included in the 3Ts  guidance. According to our survey, an estimated 67 percent of school  districts reported using an action level less than the 20 ppb recommended  in the 3Ts guidance. We found that nearly half of school districts used  action levels between 15 ppb and 19 ppb. Although these action levels— the 20 ppb from the 3Ts guidance and the 15 ppb from the LCR—are  intended for different purposes, the difference creates confusion for some  state and school district officials. Also, according to our survey, an  estimated 56 percent of school districts reported they would find it helpful  to have clearer guidance on what level of lead to use as the action level  for deciding to take steps to remediate lead in drinking water. In  addition, officials we interviewed in four of the five states we visited said  there is a need for clearer guidance on the action level. EPA officials  agreed that the difference between the two action levels creates  confusion for states and school districts.

In addition to wanting clearer guidance on choosing lead action levels,  about half of the school districts we surveyed said they would also like  additional information to help inform their lead testing and remediation  programs. Specifically, school districts reported that they want information  on a recommended schedule for lead testing, how to remediate elevated  lead levels, and information associated with testing and remediation costs  (see fig. 9). For example, an estimated 54 percent of school districts  responded that they would like additional information on a testing  schedule, as did officials in 10 of the 17 school districts and one of the  five states we interviewed. EPA’s 3Ts guidance does not include  information to help school districts determine a schedule for retesting their  schools. Officials in one school district told us they need information for  determining retesting schedules for lead in their school drinking water,  and that—without guidance—they chose to retest every 5 years,  acknowledging that this decision was made without a clear rationale.  Further, an estimated 62 percent of school districts reported wanting  additional information on remedial actions to take to address elevated  lead. For example, officials from the Massachusetts Department of  Environmental Protection told us that they would like additional guidance  on evaluating remedial actions to address elevated lead in the fixtures or  the plumbing system. Officials with EPA’s Office of Ground Water and  Drinking Water hold quarterly meetings with regional officials to obtain  input on potential improvements to the 3Ts guidance, but have not made  any revisions.

EPA has not substantially updated the 3Ts guidance since October 2006  and does not have firm plans or time frames for providing additional  information, including on the action level and other key topics such as a  recommended schedule for testing. EPA officials said that they may  update the 3Ts guidance before the LCR is updated, but did not provide a  specific time frame for doing so.  EPA has efforts underway to reconsider  the action level for the LCR, which may include a change in the action  level from one that is based on technical feasibility, to one that also  considers lead exposure in vulnerable populations such as infants and  young children, which EPA refers to as a health-based benchmark. EPA  anticipates issuing comprehensive revisions to the LCR by February  2020. While the 3Ts guidance is not contingent on the LCR, EPA officials  told us they would consider updates to the 3Ts guidance, including the 20  ppb action level, as they consider revisions to the LCR. By updating the 3Ts guidance to include an action level for school districts that  incorporates available scientific modeling regarding vulnerable population  exposures, EPA could have greater assurance that school districts are  able to limit children’s exposure to lead.

EPA has emphasized the importance of addressing elevated lead levels  in school drinking water through its 3Ts guidance, but has not  communicated necessary information about action levels and other key  topics consistent with the external communication standard under federal  standards for internal control. According to EPA, CDC, and others,  eliminating sources of lead before exposure can occur is considered the  best strategy to protect children from potential adverse health outcomes.  EPA officials also told us that clear guidance is important because testing  for lead in drinking water requires technical expertise. But without  providing interim or updated guidance to help school districts choose an  action level for lead remediation EPA will continue to provide schools with  confusing information regarding whether to remediate, which may not  adequately limit potential lead exposure to students and staff.  Furthermore, without important information on key topics, such as a  recommended schedule for lead testing, how to remediate elevated lead  levels, and information associated with testing and remediation costs  school districts are at risk of making misinformed decisions regarding  their lead testing and remediation efforts.

section_title: Education Has Not Played a Significant Role in Lead Testing and Remediation in Schools or Collaborated with EPA on These Efforts
paragraphs: Education has not played a significant role in supporting state and school  districts efforts to test for and remediate lead in school drinking water, and  there has been limited collaboration between Education and EPA,  according to officials. In 2005, Education, EPA, CDC, and other entities  involved with drinking water signed the Memorandum of Understanding  on Reducing Lead Levels in Drinking Water in Schools and Child Care  Facilities (the memorandum) to encourage and support schools’ efforts to  test for lead in drinking water and to support actions to reduce children’s  exposure to lead. According to the memorandum, Education’s role is to  identify the appropriate school organizations with which to work and  facilitate dissemination of materials and tools to schools in collaboration  with EPA. In addition, EPA’s role is to update relevant guidance  documents for school districts—resulting in the production of the 3Ts guidance in 2006—raising awareness, and collaborating with other  federal agencies and associations, among other things. Education  officials told us that the agency does not have any ongoing efforts related  to implementing the memorandum. However, Education and EPA officials  were not aware of the memorandum being terminated by either agency  and told us the memorandum remains in effect.

Although Education does not have any ongoing efforts related to  implementing the memorandum, the agency’s websites, including the  Readiness and Emergency Management for Schools Technical  Assistance Center (REMS TA Center) website, and the Green Strides  portal, provide links to EPA guidance and webinars on lead testing and  remediation. The REMS TA Center website, which is largely focused on  emergency management planning, includes a link to EPA’s 3Ts guidance  and other resources on lead exposure and children, but does not provide  information regarding the importance of testing for lead in school drinking  water. Education’s Green Strides portal includes a link to a number of  EPA’s webinars on lead in school drinking water, but does not include all  of the quarterly webinars started in June 2017 to highlight school district  efforts to test for lead. An Education official told us that these EPA  webinars are identified by Education without coordinating with EPA  officials. Further, when searching on Education’s website for lead in  school drinking water, the 3Ts guidance does not show up. Education  officials acknowledged that information regarding lead testing and  remediation is difficult to find on Education’s website and they could take  steps to make federal guidance on lead in school drinking water more  accessible.

The federal government has developed guidelines to help federal  agencies improve their experience with customers through websites. One  such resource is Guidelines for Improving Digital Services developed by  the federal Digital Services Advisory Group. It states that federal  agencies should take steps to make guidance easy to find and  accessible. Making guidance easy to find and accessible such as by  clarifying which links contain guidance; highlighting new or important  guidance; improving their websites’ search function; and categorizing  guidance on Education’s websites could help raise school district  awareness of the guidance, which is currently low in most areas of the  country.

Many school districts are not familiar with EPA guidance related to lead  testing and remediation. Specifically, an estimated 60 percent of school  districts reported in our survey that they were not familiar with the EPA’s  3Ts guidance. Most school district officials from our site visits told us they  did not have contact with EPA prior to or during their lead testing and  some said they would not have thought to go to EPA for guidance.  Likewise, EPA officials reported they had received feedback from school  district officials indicating that they do not know where to go for  information about testing for and remediating lead in drinking water.  Rather, school district officials may look to their state educational agency  or Education for guidance on lead testing and remediation, as they might  do when looking for guidance on other topics.

Education and EPA do not regularly collaborate to support state and  school districts’ efforts related to lead in school drinking water, according  to EPA and Education officials. Education officials said the agency does  not have a role in ensuring safe drinking water in schools, and that the mitigation of environmental health concerns in school facilities is a state  and local function. Therefore, the agency does not collaborate with EPA  to disseminate the 3Ts guidance beyond posting links to related guidance  on their websites and newsletters. EPA officials told us they do not know  which office they should collaborate with at Education. EPA regional  officials also said they do not collaborate with Education to disseminate  the guidance to states and school districts. However, in the 2005  memorandum, EPA and Education agreed to work together to encourage  school districts to test drinking water for lead; disseminate results to  parents, students, staff, and other interested stakeholders; and take  appropriate actions to correct elevated lead levels.

There are many school districts that have not tested for lead in school  drinking water, and some conducted testing without the assistance of  federal guidance—although the large majority (68 percent) of school  districts who use the guidance reported finding it helpful. Officials in 11 of  17 school districts we interviewed that had conducted lead testing told us  they were familiar with the 3Ts guidance and 9 of those districts said they  found it helpful for designing their lead testing programs. Increased  encouragement and dissemination of EPA resources about lead in school  drinking water by Education and EPA could help school districts test for  and remediate lead in drinking water using good practices and reduce the  potential risk of exposure for students and staff.

section_title: Conclusions
paragraphs: Children are particularly at risk of experiencing the adverse effects of lead  exposure from a variety of sources, including drinking water. While there  is no federal law requiring lead testing for drinking water in most schools,  some states and school districts have decided to test for lead in the  drinking water to help protect students. However, there are a number of  school districts that have not tested for lead and some that do not know if  they have tested for lead in their drinking water, according to our  nationwide survey. Even in states and school districts that have opted to  test, officials may choose different action levels to identify elevated lead  and may choose different testing protocols that do not test all fixtures in  all schools.

EPA has developed helpful guidance—3Ts—and webinars for states and  school districts to support efforts to test and remediate lead in school  drinking water. However, some EPA regional offices have not  communicated the importance of testing for and remediating lead to  states and school districts. By promoting further efforts to communicate  the importance of lead testing to school districts to help ensure that their  lead testing programs are in line with good practices, including the 3Ts  guidance, regional offices that have not focused on this issue could build  on the recent efforts of other regional offices to provide technical  assistance and guidance and other forms of support.

State and school district officials can use EPA’s 3Ts guidance to help  ensure that their drinking water testing and remediation efforts are in line  with good practices and said that it has been helpful for establishing their  programs. However, statements in the guidance—which has not been  updated in over a decade—that suggest the action level described will  ensure that school facilities do not have elevated lead in their drinking  water are misleading. In addition, state and school district officials told us  that additional guidance—including information on a recommended  schedule for retesting as well as on costs associated with testing and  remediation—could help school districts make more informed decisions  regarding their testing and remediation efforts. Without providing interim  or updated guidance, EPA is providing schools with confusing and out of  date information, which can increase the risk of school districts making  uninformed decisions. EPA officials said they would consider updates to  the 3Ts action level while the revisions to the LCR are being completed.  However, the longer school districts are without the additional information  they need to conduct their efforts in line with good practices and continue  to rely on confusing and misleading information, the more challenges they  will face in trying to limit children’s exposure to lead. After EPA revises  the LCR, the agency would have greater assurance that school districts  are limiting children’s exposure to lead by considering whether to  develop, as part of its guidance, a health-based level for schools that  incorporates available scientific modeling regarding vulnerable population  exposures.

Finally, although Education provides information to states and school  districts on lead testing and remediation through the agency’s websites,  that information is difficult to find. Further, Education’s website does not  include all of EPA’s quarterly webinars to highlight school district efforts to  test for lead. By making guidance accessible, Education could improve  school district awareness of EPA resources about lead in school drinking  water. In addition, EPA and Education should improve their collaboration  to encourage and support lead testing and remediation efforts by states  and school districts. EPA has the expertise to develop guidance and  provide technical assistance to states and school districts, while  Education, based on its mission to promote student achievement, should  collaborate with EPA to disseminate guidance and raise awareness of  lead in drinking water as an issue that could impact student success.  Although over one-third of districts that tested found elevated levels of  lead, many districts have still not been tested. Unless EPA and Education  encourage additional school districts to test for lead, many students and  school staff may be at risk of lead exposure.

section_title: Recommendations for Executive Action
paragraphs: We are making a total of seven recommendations, including five to EPA  and two to Education:

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)

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 guidance is not a health-based  standard. (Recommendation 2)

The Assistant Administrator for Water of EPA’s Office of Water  should, following the agency’s revisions to the 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)

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)

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)

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)

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)

section_title: Agency Comments
paragraphs: We provided a draft of this report to EPA, Education, and CDC for review  and comment. EPA and Education provided written comments that are  reproduced in appendixes VII and VIII respectively. EPA also provided  technical comments, which we incorporated as appropriate. CDC did not  provide comments. We also provided relevant excerpts to selected states  and incorporated their technical comments as appropriate.

In its written comments, EPA stated that it agreed with our  recommendations and noted a number of actions it plans to take to  implement them. For example, EPA said its Office of Ground Water and  Drinking Water is holding regular meetings with regional offices and other  EPA offices to obtain input on improving the 3Ts guidance. Potential  revisions include updates to implementation practices, the sampling  protocol, and the action level, including clarifying descriptions of different  action levels and standards. Also, EPA said that while it has not yet  determined the role of a health-based benchmark for lead in drinking  water in the revised LCR, 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. EPA said it would continue to reach out to states and  schools to provide information, technical assistance, and training and will  continue to make the 3Ts guidance available. EPA also said it would work  with Education to ensure that school districts and other stakeholders are  aware of additional resources EPA is developing.

In its written comments, Education stated that it agreed with our  recommendations and noted a number of actions it plans to take to  implement them. In response to our recommendation to improve  Education’s websites, Education 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. Education 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.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to interested congressional  committees, the Administrator of the Environmental Protection Agency,  the Secretary of Education, the Director of the Centers for Disease  Control and Prevention, and other interested parties. In addition, the  report will be available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  us at (617) 788-0580 or nowickij@gao.gov or (202) 512-3841 or  gomezj@gao.gov. Contact points for our Offices of Congressional  Relations and Public Affairs may be found on the last page of this report.

GAO staff who made key contributions to this report are listed in appendix  IX.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: In this report, we examined three objectives: (1) the extent to which  school districts are testing for, finding, and remediating lead in school  drinking water; (2) the extent to which states require or support testing for  and remediating lead in school drinking water by school districts; and (3)  the extent to which federal agencies are supporting state and school  district efforts to test for and remediate lead. To address these objectives,  we conducted a web-based survey of school districts, interviews with  selected state and school district officials, a review of applicable  requirements in selected states, a review of relevant federal laws and  regulations, and interviews with federal agency officials and  representatives of stakeholder organizations.

We conducted this performance audit from October 2016 through July  2018 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Web-based Survey of School Districts
paragraphs: To examine the extent to which school districts are testing for and  remediating lead in school drinking water, we designed and administered  a generalizable survey of a stratified random sample of U.S. local  educational agencies (LEA), which we refer to as school districts  throughout the report. The survey included questions about school  district efforts to test for lead in school drinking water, such as the number  of schools in which tests were conducted, the costs of testing, and  whether parents or others were notified about the testing efforts. We also  asked questions about remediation efforts, such as whether lead was  discovered in school drinking water, the specific remediation efforts that  were implemented, and whether parents or others were notified about the  remediation efforts. Further, we asked about officials’ familiarity with the  Environmental Protection Agency’s (EPA) guidance entitled 3Ts for  Reducing Lead in Drinking Water in Schools, (3Ts guidance) whether the  guidance was used, and the extent to which it was helpful in conducting  tests, remediating lead, and communicating with parents and others. We  directed the survey to school district superintendents or other cognizant  officials, such as facilities directors. See appendix II which includes the  survey questions and estimates.

We defined our target population to be all school districts in the 50 U.S.  states and the District of Columbia that are not under the jurisdiction of  the Department of Defense or Bureau of Indian Education. We used the  LEA Universe database from Department of Education’s (Education)  Common Core of Data (CCD) for the 2014-2015 school year to our  sampling frame. For the purpose of our survey, our sample was limited to  school districts that: were located in the District of Columbia or the 50 states; had a LEA type code of 1, 2, 4, 5, 7, and 8; had one or more schools and one or more students; and were not closed according to the 2014-2015 School Year.

The resulting sample frame included 16,452 school districts and we  selected a stratified random sample of 549 school districts. We stratified  the sampling frame into 13 mutually exclusive strata based on urban  classification and poverty classification. We further stratified the school  districts classified as being in a city by charter status. We selected the  largest 100 school districts with certainty. We determined the minimum  sample size needed to achieve precision levels of plus or minus 12  percentage points or fewer, at the 95 percent confidence level. We then  increased the sample size within each stratum for an expected response  rate of 70 percent.

We defined the three urban classifications based on the National Center  for Education Statistics (NCES) urban-centric locale code. To build a  general measure of the poverty level for each school district we used the  proportion of students eligible for free or reduced-price lunch (FRPL) as  indicated in the CCD data and classified these into the following three  groups:

High-poverty – More than 75 percent of students in the school district  were eligible for FRPL;

Mid-poverty – Between 25.1 and 75.0 percent of students in the  school district were eligible for FRPL; and

Low-poverty – 25 percent or fewer students in the school district were  eligible for FRPL.

We assessed the reliability of the CCD data by reviewing existing  documentation about the data and performing electronic testing on  required data elements and determined they were sufficiently reliable for  the purpose of our report.

We administered the survey from July to October 2017 (the survey asked  school districts to report information based on the 12 months prior to their  completing the survey.) To obtain the maximum number of responses to  our survey, we sent reminder emails to nonrespondents and contacted  nonrespondents over the telephone. We identified that four of the 549  sampled school districts were closed and one was a “cyber-school” with  no building, so these were removed from the sample. Of the remaining  544 eligible sampled school districts, we received valid responses from  373, resulting in an unweighted response rate of 68 percent.

We conducted an analysis of our survey results to identify potential  sources of nonresponse bias using a multivariate logistic regression  model. We examined the response propensity of the sampled school  districts by several demographic characteristics. These characteristics  included poverty, urbanicity, and charter status. We did not find any other  population characteristics significantly affected survey response  propensity except those used in stratification (charter schools and the  largest 100 school districts). Based on the response bias analysis and the  68 percent response rate across stratum, we determined that estimates  based on adjusted weights reflecting the response rate are generalizable  to the population of eligible school districts and are sufficiently reliable for  the purposes of this report.

We took steps to minimize non-sampling errors, including pretesting draft  instruments and using a web-based administration system. As we began  to develop the survey, we met with officials from seven school districts to  explore the feasibility of responding to the survey questions. We then  pretested the draft instrument from April to June 2017 with officials in  eight school districts—including one charter school district—in cities and  suburbs in different states. In the pretests, we asked about the clarity of  the questions and the flow and layout of the survey. The EPA also  reviewed and provided us comments on a draft version of the survey.  Based on feedback from the pretests and EPA’s review, we made  revisions to the survey instrument. To further minimize non-sampling  errors, we used a web-based survey, which allowed respondents to enter  their responses directly into an electronic instrument. Using this method  automatically created a record for each respondent and eliminated the  errors associated with a manual data entry process.

We express the precision of our particular sample’s results as a 95  percent confidence interval (for example, plus or minus 10 percentage  points). This is the interval that would contain the actual population value  for 95 percent of the samples we could have drawn. As a result, we are  95 percent confident that each of the confidence intervals in this report  will include the true values in the study population.

To analyze differences in the percentages of school districts that reported  they tested for lead in school drinking water and those that discovered  lead, we compared weighted survey estimates generated for school  districts in different levels of the following subgroups:

Poverty: low poverty, mid poverty, and high poverty;

Racial composition: majority-minority and majority white;

Region: Northeast, South, Midwest, and West;

Population density: urban, suburban, and rural/town;

Urban charter school: in urban areas, charter district and non-charter

Largest 100: largest 100 districts (based on student enrollment) and  all other districts.

For each subgroup, we produced percentage estimates and standard  errors for each level and used these results to confirm the significance of  the differences between weighted survey estimates.

section_title: Site Visits to School Districts and Interviews with State and School District Officials
paragraphs: To examine school districts’ testing and remediation efforts and state  support of those efforts, we conducted site visits in five states—Georgia,  Illinois, Massachusetts, Oregon, and Texas—from February to October  2017. We selected these states because they varied in the extent to  which they required testing of school drinking water for lead and they are  located in geographic areas covered by different EPA regional offices.  Within these states, we selected 17 school districts that had tested for  lead in school drinking water and to achieve variation in the size and  population density (urban, suburban, and rural) of the district as well as  including one charter school district.

Site visits generally consisted of interviews with officials in state agencies  and school districts and officials in the local EPA regional office:

State interviews: We interviewed officials in state environment,  education, and health agencies, depending on whether they had  information related to school district testing for lead in school drinking  water in their state. The topics we discussed were the agencies’ roles  and responsibilities related to testing for and remediation of lead in  school drinking water, any related state requirements, policies, and  guidance, communication and public notification about testing and  remediation efforts and, as appropriate, coordination among multiple  state agencies. We also discussed similar topics related to lead-based  paint. In Massachusetts, we interviewed representatives with the  University of Massachusetts, because of their role in implementing the  state’s program to support school district efforts to test for lead in  school drinking water.

School Districts: Within the five site visit states, we interviewed  officials in 14 school districts in person and in three school districts by  phone (because we were not able to meet with them in person). We  also selected one charter school that functions as its own school  district which had conducted tests for lead in school drinking water.  Similar to our school district survey, the interview topics we discussed  with district officials included testing for and remediation of lead in  school drinking water, use of guidance (such as the 3Ts guidance)  and efforts to communicate or coordinate with any federal, state, or  local agencies, including any other school districts. Within 13 of the  school districts, we visited at least one school in which the district had  tested for lead in drinking water and, as needed, took remedial action  in order to gain an in-depth understanding of their testing and  remediation efforts.

EPA Regional Offices: We interviewed officials in all 10 EPA Regional  offices. We met in-person with officials in the regional offices 1, 4, 5,  and 6 and conducted phone interviews with officials in regional offices  2, 3, 7, 8, 9, and 10. We generally discussed EPA officials’ roles and  responsibilities related to testing for lead in school drinking water and  paint and efforts in states and school districts in their region.

Information we gathered from these interviews, while not generalizable,  represents the conditions present in the states and school districts at the  time of our interviews and may be illustrative of efforts in other states and  school districts.

section_title: Review of State Requirements
paragraphs: As part of our effort to examine school districts’ testing and remediation  efforts and state support of those efforts, we reviewed related state  requirements. To determine whether states had related requirements, we  asked all EPA regional offices if states in their region had requirements  related to testing for lead in school drinking water. EPA provided  examples of eight states (California, Illinois, Maryland, Minnesota, New  Jersey, New York, Virginia, and the District of Columbia that had such  requirements. We reviewed relevant laws, regulations, and policy  documents for these states. We then confirmed the details of the related  requirements with the appropriate state officials via structured  questionnaires. Also, we used available documentation to corroborate  and verify the testing requirements of the states that EPA identified. GAO  did not conduct an independent search of state laws.

section_title: Review of Federal Laws and Regulations, and Interviews with Federal Agency Officials
paragraphs: To examine the extent to which federal agencies have collaborated in  supporting state and school district efforts to test for and remediate lead,  we reviewed relevant federal laws, including the Water Infrastructure  Improvements for the Nation Act of 2016, Reduction of Lead in Drinking  Water Act of 2011, the Safe Drinking Water Act of 1974, as amended,  and the Lead Contamination Control Act of 1988; regulations, such as the  Lead and Copper Rule; and guidance, such as the 3Ts guidance. We  also reviewed documentation including the

Memorandum of Understanding on Reducing Lead Levels in Drinking  Water in Schools and Child Care Facilities signed in 2005 by EPA,  Education and the Centers for Disease Control and Prevention (CDC);

Federal Partners in School Health Charter;

EPA training webinar information; and other relevant guidance including the 3Ts guidance tool kit.

We interviewed officials from EPA’s Office of Ground Water and Drinking  Water and Office of Children’s Health Protection and officials in all 10 of  EPA regional offices regarding their approach to providing support to  states and school district on lead testing and remediation. We interviewed  officials from Education’s Office of Safe and Healthy Students and  officials from the CDC. During these interviews, we interviewed officials  about the Memorandum of Understanding and about the Federal Partners  in School Health initiative, both of which represent collaborative efforts  that address lead in school drinking water, among other topics.

We evaluated federal efforts to collaborate and support lead testing and  remediation in schools against federal standards for internal control,  which call for agencies to communicate quality information to external  parties, among other things. We also evaluated federal efforts against  the Memorandum of Understanding, in which EPA, Education, and CDC  agreed to encourage testing drinking water for lead and communicate  with key stakeholders, among other things.

section_title: Interviews with Stakeholder Organizations
paragraphs: To inform all of our research objectives, we interviewed representatives  with the National Conference of State Legislatures, National Center for  Healthy Housing, National Alliance of Public Charter Schools, the DC  Public Charter School Board, and the 21st Century School Fund. We also  attended a workshop entitled “Eliminating Lead Risks in Schools and  Child Care Facilities” in December 2017.

section_title: Appendix II: Survey of Lead Testing and Remediation Efforts
paragraphs: The questions we asked in our survey of local educational agencies  (referred to in this report as school districts) are shown below. Our survey  was comprised of closed- and open-ended questions. In this appendix,  we include all survey questions and aggregate results of responses to the  closed-ended questions; we do not provide information on responses  provided to the open-ended questions. Estimates noted with superscript  “a” are based on 20 or fewer responses and were not included in our  findings. For a more detailed discussion of our survey methodology, see  appendix I.  1. Do any schools in your local educational agency (LEA) obtain  drinking water from a public water system such as a city or  municipal water plant? (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

No (Skip to 20)

Don’t know (Skip to  20)

Section B: Testing for Lead in School Drinking Water  2. Is there a requirement that the drinking water in your LEA’s  schools be tested for lead? (Please answer “Yes” regardless of  whether that requirement comes from your state, municipality, local  educational agency or any other governmental entity.) (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

3. Regardless of whether your LEA is required to test for lead in  school drinking water, have tests been conducted for lead in the  drinking water in at least one of your schools in the past 12 months?  (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

If yes to 3:  3A. What is the number of schools in which tests were conducted in  the past 12 months?

Estimated Number  (Mean)

95 percent  confidence interval –  lower bound  (number)

95 percent  confidence interval –  upper bound  (number) (Respondent reported  number)

3B. About how many samples were taken from sources of drinking  water such as water fountains and sinks in each school? (Check  one.)

95 percent  confidence interval –  lower bound  (percentage)

3C. Did any of the following develop the sampling plan, draw the  samples of water, and analyze the samples? (Check all that apply.)

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

3D. What size samples were taken? (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

If ‘other’ to 3D: What sample size was used?  3E: To the best of your knowledge, did the personnel drawing or  analyzing samples follow a testing protocol that offers guidance on  developing the sampling plan, drawing samples of water, or  analyzing samples? (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

No (Skip to 3F)

Don’t know (Skip to 3F)

If ‘yes’ to 3E: a. To the best of your knowledge, were any of the  following entities involved in developing the protocol? (Check one  per row.)

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

Contractor / water  testing company  EPA or another  federal government  agency  A local government  agency (aside from  your LEA)

If ‘other’ to 3Eh: What other entities were involved in developing the  protocol?  3F. If tests were conducted in some schools in your LEA in the past  12 months—but were not conducted in every school—how was it  determined which schools would be tested?  (Check one per row.)

Not applicable: tests were conducted in every school (Skip to 3G)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

If ‘other’ to 3Fe: In what other ways did your LEA use to determine  which schools would be tested?  3G. How much do you estimate your LEA has spent on testing for  lead in school drinking water in the past 12 months? (Please answer  this question for lead testing only; the survey asks about  expenditures to address concerns identified through testing later.  Also, please include materials, labor, and any other expenditures  related to lead testing in your estimate.)

Estimated Number  (Median)

95 percent  confidence interval –  lower bound  (number)

95 percent  confidence interval –  upper bound  (number) (Respondent reported  number)

3H. Did your LEA use any of the following sources of funding for the  testing in the past 12 months? (Check one per row).

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

If ‘other’ to 3H: What other sources of funding did your LEA use?  3I. In the past 12 months, did your LEA notify the following groups  that it was planning to test for lead in school drinking water before  conducting the tests? (Check one per row).

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

General public (e.g.,  media)

If ‘other’ to 3I: What other groups did your LEA notify that it was  planning to test for lead in school drinking water before conducting  the tests?  3J. In the past 12 months, did your LEA report the testing results to  the following groups after completing the tests? (Check one per  row).

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

General public (e.g.,  media)

If ‘other’ to 3J: To what other groups did your LEA report the testing  results?  3K. If ‘no’ to 3: Were any of the following a reason your LEA did not  conduct any tests in any schools in the last 12 months? (Check one  per row).

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

If ‘other’ to 3K: For what other reasons did your LEA not conduct  any tests in any schools in the last 12 months?  4. Does your LEA have a schedule for recurring tests to determine  the amount of lead in the drinking water in your schools within any  of the following time frames? (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

Section C: Remediation of Lead in School Drinking Water  5. Has your LEA discovered any level of lead in the drinking water of  any of your schools (as a result of testing) in the last 12 months?  (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

5A. What lead concentration (measured in “parts per billion” or  “ppb”) did your LEA use to initiate remedial action? (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

If ‘other’ to 5A: What lead concentration did your LEA use to initiate  remedial action?  5B. In the last 12 months, how many schools had at least one test  result–including as few as one sample in one school–greater than  the lead level your LEA used to initiate action? (Please answer  regardless of whether these results were discovered in the first of  multiple rounds of testing.)  5C.To address lead discovered in school drinking water, has your  LEA taken any of the following actions in any of your schools in the  past 12 months?

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

5D. If ‘no’ to every item in 5C: What are the reasons why your LEA  has not taken actions in any of your schools in the past 12 months?  5E. If ‘yes’ to any item in 5C: How much do you estimate your LEA  has spent on taking actions in the past 12 months? (Please include  materials, labor, and any other expenditures related to lead  remediation in your estimate.)

Estimated Number  (Median)

95 percent  confidence interval –  lower bound  (number)

95 percent  confidence interval –  upper bound  (number) (Respondent reported  number)

5F. Did your LEA use any of the following sources of funding to take  actions in the past 12 months? (Check one per row).

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

If ‘other’ to 5F: What other sources of funding did your LEA use to  take actions in the past 12 months?  5G. Did your LEA notify the following groups about its actions in the  past 12 months? (Check one per row).

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

General public (e.g.,  media)

If ‘other’ to 5G: What other groups has your LEA notified about its  remedial actions in the past 12 months?  6. Does your LEA have a schedule to flush the water system as a  result of concerns about lead in drinking water in at least one of  your schools within any of the following time frames? (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

7. Does your LEA have plans to take actions to eliminate or reduce  lead in school drinking water (for example, replace drinking water  fountains, replace pipes) in at least one of your schools? (Check  one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

If ‘according to a schedule’ to 7: how would you describe the  schedule that your LEA has developed?

Section D: Guidance Regarding Lead Testing and Remediation  8. Prior to receiving this survey, were you familiar with guidance  issued by the U.S. Environmental Protection Agency entitled “3Ts  for Reducing Lead in Drinking Water in Schools”? (Please answer  “Yes” if you had read or used the”3Ts” prior to receiving this  survey.) (Check one.)

95 percent confidence  interval – lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

If ‘yes’ to 8: did your LEA (or a contractor working on behalf of your  LEA) follow or refer to “3Ts” during your efforts to test for or  remediate lead in school drinking water? (Check one.)

95 percent confidence  interval – lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

If ‘yes’ to 8A: How helpful was 3Ts for conducting tests for lead in  your schools’ drinking water? (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

If ‘yes’ to 8A: How helpful was 3Ts for remediating lead in your  schools’ drinking water? (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

If ‘yes’ to 8A: How helpful was 3Ts for communicating with parents  and other stakeholders about lead in your schools’ drinking water?  (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

What else, if anything, would make 3Ts more helpful?  9. Did your LEA (or a contractor working on behalf of your LEA) use  any other guidance (for example, best practices, manuals, protocols,  webinars) in your LEA’s efforts to test for lead in your schools’  drinking water, take remedial actions, or for notification purposes?  (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

95 percent  confidence interval –  upper bound  (percentage)

What other guidance was used?  10. Would your LEA find any of the following helpful? (Check one  per row).

95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

Clearer guidance on  a level of lead in  school drinking  water at which we  should take action  Additional guidance  on determining a  schedule for  41  95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage) regularly testing for  lead in school  drinking water  Additional guidance  on actions to take if  lead is found in  school drinking  water  Information on the  costs of testing for  lead in school  drinking  water  Information on the  costs of remediating  lead in school  drinking water  18  95 percent  confidence  interval – lower  bound  (percentage)

95 percent  confidence  interval – upper  bound  (percentage)

If ‘other guidance or information’ to 10: What other guidance or  information would be helpful?

Section E: Inspecting Schools for Lead Based Paint  Section F: Remediation of Lead Based Paint in Schools  Section G: Other Questions  16. How many schools are owned or operated by your LEA?

Estimated Number  (Mean)

95 percent  confidence interval –  lower bound  (number)

95 percent  confidence interval –  upper bound  (number) (Respondent reported  number)

17. How many schools in your LEA were built before 1986? (If a  building has additions, we mean the original structure/the original  part of the building.)

Estimated Number  (Mean)

95 percent  confidence interval –  lower bound  (number)

95 percent  confidence interval –  upper bound  (number) (Respondent reported  number)

18. How many schools in your LEA were built before 1978? (If a  building has additions, we mean the original structure/the original  part of the building.)

Estimated Number  (Mean)

95 percent  confidence interval –  lower bound  (number)

95 percent  confidence interval –  upper bound  (number) (Respondent reported  number)

19. Is there anything else you would like to share with us regarding  lead testing, inspection, or remediation efforts in your school or LEA  (drinking water or paint)?  20. What is the name, title, e-mail address, and telephone number of  the person responsible for completing this survey?

Section H: Completion  21. Please check one of the options below. Clicking on “Completed”  indicates that your answers are official and final. Your answers will  not be used unless you have done this. (Check one.)

95 percent  confidence interval –  lower bound  (percentage)

section_title: Appendix III: Lead Testing and Remediation in Charter School Districts
paragraphs: Charter schools comprise a small but growing group of public schools. In  contrast to most traditional public schools, many charter schools are  responsible for financing their own buildings and other facilities. As a  result, charters schools vary in terms of whether they own their own  building or pay rent, and whether they operate in buildings originally  designed as a school or in buildings which have been redesigned for  educational purposes. Sometimes charter schools may also share space  in their building with others, such as non-profit organizations. In addition  to differences in facility access and finance, charter school governance  also varies. In some states, charter schools function as their own school  district, while in other states, charter schools have the option to choose  between being a distinct school district or part of a larger school district.

To determine the extent to which charter school districts were testing for  lead in school drinking water and finding and remediating lead, our survey  included charter school districts in two ways: our sampling design  included three strata specifically for charter school districts in urban  areas; in addition, charter school districts were retained in the sampling  population, such that they could be randomly selected in our other strata.  While we generally received too few responses from charter school  districts to report their data separately, we are able to estimate that about  36 percent of charter school districts tested for lead in school drinking  water.

To learn more about experiences of charter schools, we visited one  charter school district and interviewed representatives of the DC Public  Charter School Board (DC PCSB).

The charter school district we visited consisted of one charter school  in a building it leased. The school had 10 sources of consumable  water, all of which were tested in 2016 and were found to have lead  below the district’s selected action level of 15 parts per billion. Before  testing, district officials met with the building owner who agreed to  cover the cost of any remediation.

Officials with the DC PCSB told us that it paid to have tests conducted  in every charter school in the District of Columbia. According to DC  PCSB officials, between March and June 2016, 95 charter schools  were tested, and lead above their action level of 15 parts per billion  was discovered in 20 schools. Officials estimated their testing costs to  be about $100,000, which was subsequently reimbursed by the  District of Columbia’s Office of State Superintendent of Education.  They also said that charter schools were responsible for taking steps  to remediate the lead and recommended schools flush their water  systems and use filters.

section_title: Appendix IV: Testing Components for Eight States That Require School Districts to Test for Lead in Drinking Water
subsections: section_title: Action level and sample size Not specified
paragraphs: Communication  of results  Not specified 5 ppb in a 250  ml sample  (from filtered  fixture)

section_title: Appendix V: EPA Guidance to the Public on Reducing Lead in Drinking Water
paragraphs: The Environmental Protection Agency (EPA) provides information on its  website for the public on lead in drinking water. EPA’s website includes,  among other documents, a December 2005 brochure for the public and  school districts entitled “3Ts for Reducing Lead in Drinking Water in  Schools” (see fig.10).

section_title: Appendix VI: Memorandum of Understanding between EPA, Education, CDC, and Related Associations on Reducing Lead in School Drinking Water Effective June 2005

section_title: Appendix VII: Comments from the Environmental Protection Agency

section_title: Appendix VIII: Comments from the Department of Education

section_title: Appendix IX: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts

section_title: Staff Acknowledgments
paragraphs: In addition to the individuals named above, Diane Raynes (Assistant  Director), Scott Spicer (Assistant Director), Jason Palmer (Analyst-in- Charge), Amanda K. Goolden, Rich Johnson, Grant Mallie, Jean  McSween, Dae Park, James Rebbe, Sarah M. Sheehan, and Alexandra  Squitieri made significant contributions to this report. Also contributing to  this report were Susan Aschoff, David Blanding, Mimi Nguyen, Tahra  Nichols, Dan C. Royer, Kiki Theodoropoulos, and Kim Yamane.

section_title: Related GAO Products
paragraphs: Lead Paint in Housing: HUD Should Strengthen Grant Processes,  Compliance Monitoring, and Performance Assessment. GAO-18-394.  Washington, D.C.: June 19, 2018.

Drinking Water: Additional Data and Statistical Analysis May Enhance  EPA’s Oversight of the Lead and Copper Rule. GAO-17-424.  Washington, D.C.: September 1, 2017.

Environmental Health: EPA Has Made Substantial Progress but Could  Improve Processes for Considering Children’s Health. GAO-13-254.  Washington, D.C.: August 12, 2013.

Lead in Tap Water: CDC Public Health Communications Need  Improvement. GAO-11-279. Washington, D.C.: March 14, 2011.

Environmental Health: High-level Strategy and Leadership Needed to  Continue Progress toward Protecting Children from Environmental  Threats. GAO-10-205. Washington, D.C.: January 28, 2010.

Drinking Water: EPA Should Strengthen Ongoing Efforts to Ensure That  Consumers Are Protected from Lead Contamination. GAO-06-148.  Washington, D.C.: January 4, 2006.

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.)

Question-summary annotations: questions: question: How prevalent is lead in school drinking water?
answer: 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.
child_questions: question: Is this potentially dangerous to students?
answer: 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.)

question: How are districts with lead contaminated water rectifying the problem?
answer: 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.

questions: question: What resources do school districts have for supplying safe drinking water?
answer: 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.
child_questions: question: Is this resource considered helpful?
answer: School district officials that used EPA's written guidance said they generally found it helpful.

question: What is GAO's assessment of this resource?
answer: 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.

question: Is this guidance used throughout the country?
answer: In addition, many school districts reported a lack of familiarity with EPA's guidance, and their familiarity varied by region of the country.

question: How does Education and EPA work together?
answer: 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.

questions: question: What federal requirements are there for school drinking water?
answer: 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.

question: How does lead get into drinking water?
answer: Lead can leach into water from plumbing materials inside a school.

question: What has driven awareness of unsafe drinking water?
answer: 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.

questions: question: What was GAO asked to do?
answer: GAO was asked to review school practices for lead testing and remediation.

question: What does the report examine?
answer: 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.
child_questions: question: How did GAO conduct their research?
answer: 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.