LEAD IN DRINKING WATER IN PRIORITY AREAS

NMCFHPC Website Alert:

SAMPLING AND TESTING FOR LEAD IN DRINKING WATER IN PRIORITY AREAS

Current Navy policy requires Navy installations worldwide to sample and test for lead in drinking water in “Priority Areas”.

Priority Areas are defined as:

• Primary and secondary schools
• Child Development Centers (CDCs)
• Navy operated 24/7 Group Homes
• Youth Centers

This policy does not extend to on or off-base residences (e.g., Child Development Homes (CDHs) or Family Child Care Homes (FCCs)) used for child care purposes under Navy's Child Development Home Program, or schools that are not owned or managed by the Navy or DoD.

Background: Because children are most susceptible to the effects of lead, it is Navy policy to meet U.S. Environmental Protection Agency (EPA) guidelines for testing and sampling of water from drinking water fountains, faucets, and other outlets from which children may drink, including schools and child care facilities. Recent events have prompted an examination of current policy on sampling and testing drinking water in these facilities to ensure that we have a uniform, consistent, and effective Navy worldwide program.

Of note, this revised policy requires that a copy of all test results be made available to the Local Preventive Medicine Service/Medical Treatment Facility, all schools, CDCs, Navy operated 24/7 Group Homes, youth centers, where testing was conducted.

At a minimum, availability of testing results shall be provided to the parents or legal guardians of children attending the schools, CDCs, Navy operated 24/7 Group Homes, and youth centers. Direct notification of results shall be conducted for any lead detection greater than 20 ppb during a sampling event.

Notification requirements and procedures shall be coordinated with Public Affairs staff, local Navy Preventive Medicine Service/Medical Treatment Facility, legal department, and shall be conducted in accordance with any other installation, regional or command guidance if applicable. All records of sampling and testing of drinking water in priority areas shall be retained for 12 years.

Purpose: This website is intended as a resource to increase awareness for Navy and Marine Corps medical department personnel (e.g., health care providers, public health, environmental, facilities, etc.,) who have duties and responsibilities for:

• BUMED’Ss Pediatric Lead Poisoning Prevention (PLPP) Program )
• BUMED’s Occupational Medical Surveillance and Certification Program
• BUMED’s responsibilities under the Navy’s Child Youth Programs (CYP)

Other interested stakeholders may also include Commander Naval Installations Command (CNIC) region and installation environmental and facilities personnel involved in sampling and testing of lead in drinking water in priority areas at Navy and Marine Corps installations worldwide, employees working in those priority areas, and parents and children who use priority areas.

While there is no federal law requiring schools or child care facilities to test drinking water for lead unless the school/facility is a public water system, the Navy and Marine Corps have proactively required sampling and testing in these "priority areas."

Because children are most susceptible to the effects of lead, it is Navy policy to meet U.S. Environmental Protection Agency (EPA) guidelines for testing and sampling of water from drinking water fountains, faucets, and other outlets from which children may drink, including schools and child care facilities.

Lead most frequently gets into drinking water by leaching from plumbing materials and fixtures as water moves through the facility’s distribution system. Even though drinking water received from the water supplier may meet federal, state, local and/or overseas standards for lead, the facility may have elevated lead due to plumbing materials, water chemistry, and water use patterns. The best way to determine if a facility might have elevated lead levels in its drinking water is by testing the water at the tap.

The Lead Contamination and Control Act of 1988 amended the Safe Drinking Water Act (SDWA, 42 USC 300f-300j) to require EPA to publish a guidance document and testing protocol to assist schools in the U.S. in determining the source and degree of lead contamination in school drinking water supplies and in remedying such contamination. EPA has published guidance for both schools and day care centers (provided below) that includes recommendations in developing a sampling plan, interpreting results to pinpoint specific outlets that require corrective action (e.g. water cooler replacement), short and long term remedies, and communicating sampling results.

Successful implementation of this policy requires a coordinated team approach between medical, environmental and facilities personnel before testing, during testing and after test results are available for notification to parents, legal guardians and staff members of the sampled facility.

Navy and Marine Corps Force Health Protection Center is available for occupational medicine, risk communication, and epidemiologic consultation and services upon request.