Lead in Drinking Water Plan
© 2018 Resource Training & Solutions
This plan is designed to help the St Cloud School District comply with the requirement of the Minnesota Department of Education with regard to protecting the health and safety of students and staff.
Reducing Lead in Drinking Water: A Manual for Minnesota Schools published by the Minnesota Department of Health, Section of Drinking Water Protection is the reference material used to develop this plan.
As written, this Plan is intended to guide the St Cloud School District in its efforts to provide a safe and healthy environment in which to learn, but will need to be reviewed and modified on a regular basis. The district is responsible for the enforcement and updating of the Plan. Actual use of this Plan is limited to Resource Training and Solutions and to the St Cloud School District which it represents.
Plan Review and Updated Report
Lead in Drinking Water Management Review & Update Report
Program review and changes are documented below. Documented reviews indicate that the plan continues to meet the needs of the District, or has been modified to do so more effectively.
Date Updates/Notes Reviewer 4-8-16 Removed reference in introduction page referring to attachment 4 Wayne Warzecha
Overview of Lead in Water Issues
Lead is an extremely toxic substance that is known to be harmful if ingested or inhaled. It is a potentially serious health issue. Lead in the body is damaging to organs, i.e., kidneys, brain, affects the nervous system and red blood cells. In children lead is especially harmful because they are developing so quickly that lead has been associated with impaired mental and physical development as well as hearing problems. In addition, given their size, children inhale greater quantities of air, water and food associated with lead contamination. Blood lead levels as low as 10 micrograms per deciliters are toxic and have been associated with harmful effects on the ability of children to learn and has a negative impact on their behavior. Exposure to these doses of lead have been related to delayed mental development, lower IQ, hearing deficits, speech and language handicaps and reduced attention span in children.
The goal schools commonly try to achieve is that of being "lead free". Since 1986 only "lead free" pipe, solder or flux may be used in the installation or repair of water systems providing water for human consumption in schools. Lead free only addresses the amount of lead that will leach into drinking water.
NSF Standard 61 is a voluntary standard that takes the amount of lead leaching into drinking water into account. Taps meeting NSF Standard 61 should not leach more than 11 ppb of lead.
Through the recognition of the impact of lead on children, this Plan is designed to help the St Cloud School District identify drinking taps of concern and implement remedial action to eliminate or significantly reduce the risk to students.
First Draw Sample - the first water drawn from a drinking tap that has been unused for a period of at least 8 hours. It is recommended that the first draw be taken after the tap has been unused over night.
Flush - running water to clear a tap from water standing in the piping
Flush Sample - a sample collected following the flushing of a drinking tap
Lead Free - defined by The Safe Drinking Water Act (SDWA) as:
- For solders and flux: does not contain more than 0.2% lead.
- For pipes, pipe fittings and well pumps: does not contain more than 8% lead.
Parts per Billion (ppb) - a unit of measure equal to one microgram per liter
Tap - point where people commonly obtain water for drinking or cooking. It can be a fixture, faucet, drinking fountain or water cooler.
The St Cloud School District has designated Mike Machacek or appointed personnel as the person responsible for carrying out the requirements of the Plan. Responsibilities for this position include, but are not limited to:
- Ensure that policies and procedures are followed in the daily activities of the school;
- Complete an inventory identifying the location of all drinking, cooking taps in the St Cloud School District for each building;
- Develop and implement a testing schedule for each building and designating a person in each building responsible for making the first draw ensuring that water is tested in each building at least every five (5) years or more frequently depending upon the results of sampling;
- Maintain a log of sampling activity;
- Provide all record keeping activities; and,
- Review plan regularly and at least annually recommend updates or changes to the plan forwarding the Plan with recommendations to the Administration for review by the St Cloud School Board.
General Requirements for Sampling in Preventing Lead in Water
1. Water Tap Locations
A water tap inventory is located in Appendix C identify the location of all water taps used for food preparation or drinking. Each tap and location has been assigned a number to facilitate the water sampling process.
2. Flush Taps
Most lead can be removed from taps by running them for 2 - 3 minutes eliminating the water that has been sitting in the line in direct contact with the lead containing plumbing materials. This method is lengthier when flushing refrigerated water coolers and may take up to 15 minutes to be effective.
3. Test Taps
Using the "first draw" process, a sample is drawn from the tap after the tap has not been used for at least 8 hours using only cold water. Resource Training and Solutions will provide the bottles and use field test kits to analyze the results. If the result is at or below 20 ppb no flushing is required and can continue to be used for drinking water. It should be retested every 5 years.
Using the sampling processes described above, water samples will be drawn at least every five years and recorded as a part of this management plan. A sample log can be found in Appendix D.
5. Flushing and Retesting
If the results exceed 20 ppb, flushing is required before school begins and must be retested during the school day prior to the lunch period. If the tap continues at or below 20 ppb, it will need to be flushed twice per day for a minimum of 10 minutes after being flushed twice per day, a treatment method will need to be required to reduce the amount of lead in the tap which may include replacing the tap. Retesting is necessary to ensure the new tap is free from lead.
All water tap location maps and testing results will be maintained by the designated person and stored in the St Cloud School District office.
The Superintendent or designated person shall present a summary of this program to the School Board for review and approval on at annual basis.
Appendix A: Compliance Checklist
The following checklist serves as a quick reference for the St Cloud School District to evaluate their level of compliance.
- Identify designated person
- Sample water at least every five years
Note: This checklist is not intended to be comprehensive in nature. The St Cloud School District should refer to their respective Exposure Control Plan which further outlines general compliance requirements.
Appendix B: Reducing Lead in Drinking Water: A Manual for Minnesota's Schools
Appendix D: Testing Results
Appendix E: Lead in Paint
Paint made prior to 1978 often contains significant amounts of lead. Paint containing 0.5% lead by weight (5000 ppm) is considered lead containing.
- In compliance with OSHA's Lead in Construction Standard (1926.62) and OSHA's General Industry Lead Standard (1910.1025), the St Cloud School District will ensure that testing is done in any area painted or varnished prior to 1978 that will undergo renovation or remodeling in a way that may expose school employees to lead exceeding the permissible exposure limit. A Minnesota certified inspector will do all sampling.
- The St Cloud School District will keep loose paint and dust from accumulating. Areas where loose paint and dust may build up will be cleaned with a HEP A vacuum and with soap and water often.
- Only certified lead abatements workers will remove lead based paint.
Appendix F: Lead in Soil and Dust
Lead can be found in soil from a variety of sources. It can contain chipped paint from nearby structures or structures that have been torn down on the site. When cars still used leaded gasoline, they released exhaust containing lead into the air, which then settled into the soil.
To avoid exposure to lead from soil, the St Cloud School District will do the following:
- Locate play areas away from structures with possible chipping or peeling paint and high traffic areas.
- Remove play structures with chipping or peeling paint determined to be lead containing.
- Keep all bare areas of soil covered with grass or other ground cover.
- Keep all areas in and around play equipment covered with clean fall-protecting materials such as pea gravel, sand, or wood chips.
- Not allow students to eat on the playground.
- Keep rugs at all school entrances to capture dust and soil from shoes as students and staff enter the building.
- Keep the building as dust-free as possible.
- Encourage students and staff to wash hands before eating.