School Water Lead Reduction – Testing

TESTING for Lead in Drinking Water at Tribal Schools and Child Care Facilities

ITCA will assist with the implementation of local 3Ts (training, testing, and taking action) lead reduction programs for schools and child care facilities at federally-recognized tribes located in Arizona, California, Nevada, and New Mexico, including Navajo Nation. As part of this work, ITCA will collect non-regulatory drinking water samples at participating schools and child care facilities and arrange for the samples to be analyzed for lead concentration by certified laboratories. All costs associated with testing through this project will be covered by ITCA under its grant from USEPA.

Participation Process: The following are steps that tribal communities, schools, and child care facilities can take to participate in the free water testing services of this project.

  1. Contact ITCA.
  2. Select participation goals
  3. Obtain consensus from governing body (local education administration, board, or council)
  4. Schedule site visit from ITCA Project representatives

Selecting Participation Goals
Tribal schools and child care facilities that participate in the free water testing services will select their own individual action level and public notification procedures.

  • Action Level – There is no safe level of lead exposure for children. Participation in ITCA project services of free testing of school drinking water for lead follows the USEPA 3Ts program and is, therefore, purely voluntary and non-regulatory. As part of the intake process, each individual participating Tribal school or child care facility will need to select a level of lead concentration that, if measured in drinking water during the testing process, would result in the need to take action to identify sources and take action to prevent lead exposure. Participating Tribal schools and child care facilities will have the ability to choose an action level that is a number between 1 and 15 parts per billion (ppb or ug/L).

    [By way of comparison, drinking water utilities that are defined as public water systems under the Safe Drinking Water Act use the federal action level of 15 ppb for regulatory compliance purposes.]
  • Public Notification Procedures – As a condition of participating in the ITCA free testing services, results of water testing must be provided to community stakeholders of the participating Tribal school or child care facility. This ITCA project supports Tribal data sovereignty. Therefore, as part of the intake process, each individual participating Tribal school or child care facility will need to specify how they want to handle providing drinking water test results to their community’s stakeholders (e.g., parents, faculty, local education administrators, board, and council).

ITCA anticipates this work will begin in the summer of 2023 and continue through the spring of 2024. ITCA anticipates approximately 6,400 samples will be analyzed from up to 320 schools and child care facilities; although since participation is voluntary, these are only estimates. ITCA anticipates participation and quantity of samples to be distributed across five (5) geographic areas as listed in the below table.

Geographic Distribution of Anticipated Participation and Forecasted Number of Samples

Geographic Area in which participating Tribal school and child care facilities are located Estimated Number of participating Tribal schools and child care facilities Estimated Number of Drinking Water Samples [10 fixtures per facility, each sampled twice**]
1 Tribal lands in Arizona 100 2,000
2 Navajo Nation 100 2,000
3 Tribal lands in New Mexico 70 1,400
4 Tribal lands in California 30 600
5 Tribal lands in Nevada 20 400

** Two samples per fixture – a first draw sample and flush sample. First draw to identify potential lead source in fixture. Flush sample to identify potential lead source in pluming behind fixture.

Back to the School Water Lead Reduction & 3Ts page.