Take the fountain out of service at 10 ppb or more, post a sign, and let follow-up sampling find the source. Then replace the fountain valve or faucet, replace the cooler, or cap the line if the outlet is not needed. Use lead-free certified parts, flush and resample the new fixture, and keep records.
What do you do first when a fountain tests high?
Take it out of service the same day. ADHS says that for results at or above 10 ppb, the facility should "Stop using the water source immediately" and post a sign over the fixture saying not to use it for cooking and drinking. Use bottled water or another lead-free tap until the problem is resolved.
If the tap is only used for handwashing, the rule is simpler. ADHS says posting a handwashing-only sign is an acceptable solution and retesting or remediation is not required, as long as the sign is "appropriate for the ages of the children, so they understand not to drink from the tap."
EPA's 3Ts module adds a communication step. It says to "Post test results in your facility" and on a public website, and to "Notify staff, parents, and students of test results and actions you are taking." The school can also contact its water utility to share results.
How does a school find where the lead is coming from?
Through follow-up sampling. ADHS describes it as "sequential sampling and a detailed fixture evaluation to pinpoint where lead is getting into the drinking water." That work separates the fixture, the fountain's internal parts, the valves and solder behind it, and the building's pipes.
It matters because the repair differs. A lead-bearing fountain valve is a parts swap. Lead in the piping behind the wall is a bigger job. ADHS also tells facilities to "Contact your water system to see if your facility is connected to a lead service line."
What are the permanent fixes?
ADHS lists three remediation options:
- Replace the faucet or fixture that is contributing to the elevated lead.
- Replace water fountains and water coolers that are not performing properly.
- Remove the tap from service. If it is not needed for drinking or cooking, it "can be permanently shut off (by capping the water supply line) or physically removed/uninstalled."
EPA's module explains the logic. After the sources are identified, "replacing these identified outlets and any identified upstream plumbing components (e.g., valves, leaded solder) permanently address the problem, compared with other solutions that have long-term costs and risks." If a school needs several of the same part, EPA suggests buying one or two first and sampling after installation to verify, because satisfactory results make it "reasonably certain that the product would perform well at other locations."
Pipe is a separate category. EPA notes that "You may be responsible for replacing the portion of a lead service line that is on school or childcare property, rather than under the jurisdiction of the public water system." The utility can say where its responsibility ends.
What does "lead-free" mean for replacement parts?
It has a legal definition. Under 42 U.S.C. 300g-6(d), "lead free" means "not more than a weighted average of 0.25 percent lead when used with respect to the wetted surfaces of pipes, pipe fittings, plumbing fittings, and fixtures," and "not containing more than 0.2 percent lead when used with respect to solder and flux." The statute also makes it unlawful to introduce into commerce a plumbing fitting or fixture that is not lead free, with exemptions that include products used exclusively for nonpotable services.
ADHS tells schools to "choose plumbing materials labeled lead-free or NSF/ANSI 372 certified." EPA's identification guide explains how to read the certification marks. EPA's module also says to make sure any plumber doing repair or replacement work on the facility's plumbing uses only lead-free solders and other materials. Fixture swaps in a school should be done by a licensed plumber who is working to that standard.
Can flushing, filters or bottled water be the fix?
They are bridges, not cures. EPA's module says flushing "may also represent a short-term solution" but "unless you can ensure lead levels remain low throughout the day, flushing just once a day or once a week is not recommended." For fountains, EPA's 3Ts flushing directions say to let refrigerated fountains run for 15 minutes, and add that because routine flushing of them may not be feasible, replacing them with lead-free NSF-approved devices may be more economical. The same directions state "Flushing is not recommended as a practical remedy for water coolers."
Filters work if they are the right kind and maintained. EPA says to check that a point-of-use filter was "tested and certified against NSF/ANSI Standard 53 (for lead removal)," and that filters "need routine maintenance." It also warns about a different device: a point-of-entry treatment unit on the whole building "could lead to your facility being identified as a public water system" and "is not effective" against lead from the building's own plumbing. Check with the state drinking water office before considering one.
Bottled water is a stopgap too. EPA notes bottled water is regulated by the FDA and recommends getting a written statement from the distributor that it meets FDA and state standards.
How does a school confirm the fix worked?
By testing again. ADHS says: "Flush the new fixture (typically 5 minutes) and have it resampled to confirm that the lead levels are below 10 ppb." If a fixture is permanently turned off or removed, "no additional testing is required because it is no longer used as a source of drinking water."
Funding exists for some of this. ADHS says public school districts with results above 10 ppb "should contact the Schools Facilities Board (SFB) and apply for a Building Renewal Grant," and that for other facilities ADHS "intends to use WIIN Grant funding to cover the cost of remediation." Funding availability can change, so confirm with ADHS.
Keep the records. EPA says to "Record remediation efforts, schedules for upkeep and maintenance, and partners and contacts that assisted in your efforts." For the background on whether testing is required, see whether Arizona schools have to test drinking water for lead, and for how child care sites enroll, free lead testing for child care facilities. The fixture side of a school restroom or fountain also connects to commercial drinking fountain and bottle filler code.
