Independent Environmental Consulting

School drinking water

Lead testing for school and child care drinking water

We inventory every outlet used for drinking or cooking, collect first-draw samples on the required schedule, and deliver results in the format your state agency expects.

NYS Public Health Law §111010 NYCRR Subpart 67-4N.J.A.C. 6A:26-12.4EPA 3Ts
2-114-DF 250mL FIRST-DRAW SAMPLE8–18 h stagnationNo flushing beforeChain of custody to lab
Every outlet gets an ID that follows it through sampling, lab results and retests.

What we do

Sampling programs, start to finish

  • Outlet inventoryEvery fountain, bottle filler, kitchen and classroom sink used for drinking or cooking, mapped and given a permanent ID.
  • Sampling planSchedule built around the required stagnation period, plus the Quality Assurance Project Plan New Jersey requires.
  • First-draw sampling250 mL first-draw samples with labeling and chain of custody to a state-certified laboratory.
  • Results and notificationOutlet-by-outlet results, exceedance lists, and draft notification letters for parents and staff.
  • Flush samples and retestingFlush samples paired with each first-draw sample to tell whether lead comes from the fixture or the plumbing behind it, and retesting after repairs.

Requirements

Lead action levels compared

051015µg/L (ppb) lead, first-draw sampleAAP recommendationSchool fountains, 20161 ppbNew York State10 NYCRR Subpart 67-45 ppbNew JerseyN.J.A.C. 6A:26-12.415 ppb
An outlet at or above the action level must be taken out of service. NYS lowered its level from 15 to 5 ppb in 2022. The AAP figure is a health recommendation, not a regulation.

New York State

Who
Public school districts and BOCES, for every outlet used for drinking or cooking.
How often
Every three years, and when the Commissioner of Health requires.
Sample
250 mL first-draw sample after 8 to 18 hours of stagnation.
Action level
5 ppb. The outlet comes out of service until remediation and a passing retest.

New Jersey

Who
Public, charter and renaissance schools, among others covered by N.J.A.C. 6A:26-12.4.
How often
Every three years on the state cycle, and after outlet replacement or plumbing changes.
Lab
Analysis by a certified laboratory under a Quality Assurance Project Plan.
Action level
15 ppb. Stop use immediately, notify parents, staff and NJDOE, and post the letter on the school website.

Sample types

First-draw and flush samples

Many sampling programs collect two samples at each outlet: a first draw and a flush sample. Depending on the applicable requirements and the sampling plan, the flush sample is collected in the same visit or as a follow-up. Comparing the two shows where the lead is coming from, so the fix goes to the right place.

Sample
First draw
When
The first water out of the outlet after 8 to 18 hours of no use, before anyone drinks from it or flushes it.
Volume
250 mL
Represents
Water that sat in the fixture, valve and nearby fittings overnight.
Purpose
Required compliance sample in New York and New Jersey.
Sample
Flush
When
Collected right after the first-draw sample at the same outlet, once the water has run for about 30 seconds.
Volume
250 mL
Represents
Water from the plumbing behind the wall, past the fixture.
Purpose
Shows lead contributed by the plumbing behind the fixture. It does not replace or cancel a high first-draw result.
First drawFlushLikely sourceTypical next step
Above action levelBelow action levelThe fixture or its fittingsReplace the fountain, faucet or valve, then retest
Above action levelAbove action levelPlumbing or service line behind the outletInvestigate upstream piping before replacing fixtures
Below action levelAbove action levelPlumbing behind the outletInvestigate upstream piping and review flushing practices
Below action levelBelow action levelNo exceedanceKeep in service and retest on the regular cycle

An outlet with a first-draw result at or above the action level stays out of service and must be reported even if its flush sample is below the action level. New Jersey states this explicitly in its school testing guidance.

Process

How a school sampling program runs

  1. Inventory

    We walk the building with facilities staff and tag every outlet in scope.

  2. Stagnation

    Water sits unused 8 to 18 hours before sampling, usually overnight or over a weekend.

  3. Collection

    First-draw samples before any use, logged by outlet ID with chain of custody.

  4. Results

    Lab results compared with the state action level, with exceedances flagged the day they arrive.

  5. Retest

    After fixtures or piping are replaced, affected outlets are resampled before returning to service.

FAQ

Common questions

Why first-draw samples?

Water that sits in a fixture overnight picks up the most lead. A first-draw sample shows the worst case a child could drink in the morning.

What is a flush sample for?

A flush sample is taken after running the outlet for about 30 seconds. Comparing it with the first-draw result shows whether the lead is coming from the fixture or from the plumbing behind it.

What if an outlet is over the action level?

It must be taken out of service right away and stay out until it is fixed and a retest passes. We provide the list and draft notices the same day.

Do child care programs need testing too?

Many do, depending on the state program and license type. Tell us your facility type and we will confirm which rule applies.

Next step

Testing cycle coming up?

Send the number of buildings and an estimate of outlets. We will quote the full program, including the plan and reporting.