In June of 1988, a ban on lead in drinking water components was passed in the U.S., making it illegal to use lead solder or lead piping in distribution systems....

What did that mean to my facility?

It meant that if your facility was a nontransient noncommunity water supply and was built prior to 1988, you have been required to test the water for lead and copper.  If the facility was built after 1988, it was considered a "lead-ban" site, and was not usually required to test for those contaminants.

What has changed since then?

Recent revisions of the National Primary Drinking Water Regulations for Lead and Copper were published in the Federal Register on Wednesday January 12, 2000.  These "minor" revisions now required that ALL nontransient noncommunity water supplies must test for lead and copper, regardless of when the system was constructed.

Why is this?

It has been determined over years of testing various facilities that many components installed after 1988, labeled as "lead-free", still may contain small amounts of lead.  If the water in a supply is of a certain quality, it may cause this lead to leach out, exposing people to elevated lead levels through consumption of the drinking water.

Michigan's rules

Certain parts of the Federal rule were to be implemented by April 11, 2000.  However; Michigan has primacy for implementation of the Safe Drinking Water Act, and as part of its implementation agreement, the state advised the U.S. EPA that it would begin in the six-month monitoring period starting January 1, 2001.

Who is affected?

Those nontransient supplies not previously required to sample for lead and copper are now being identified and notified of the new requirements by the local health departments with jurisdiction.   There are 296 of these water supplies statewide. They are also notifying those supplies that either have a discontinued or an incorrect lead copper sampling frequency in the state database.  There are 76 of these water supplies statewide.

What do I have to do now?

If your facility previously was considered a "lead-ban" site, it now will need to collect the first lead copper samples within the first 6-month monitoring period that begins January 1, 2001 and ends June 30, 2001 (see enclosed instructions and form to report sample results). If the first set of samples is satisfactory, another set is required during the second six months beginning July 1, 2001. If results remain satisfactory, sampling can be reduced to annual or less in some cases.

How many samples are required of my facility?

The required number of lead/copper samples are assessed according to the  population served, as shown in Table 1 below.  For example, if the facility were a school with 450 students and teachers, it would be required to take 10 samples from different sampling taps during the first six-month sampling period. These samples are used to determine if results are above the action level for lead (0.15 mg/l) and copper (1.3 mg/l).

Table 1

Where do I take the samples?

Sample only fixtures where cold water is typically drawn for consumption such as kitchen or break room faucets, or drinking fountains. (Normally, faucets on bathroom sinks, janitor sinks or hose bibbs are not routinely used for drinking).

Sampling if you have one building:

• Sample drinking water fixtures in the building up to the chart number. 
• If you have more than the chart number of drinking water fixtures, select ones that represent the water distribution system, i.e. one in each building wing or on each floor. Or, you can collect more than the minimum number of samples.

• If you have fewer drinking water fixtures than the chart requires, sample the ones you have and note on the sample log sheet you have sampled all drinking water fixtures.

Sampling if you have more than one building

• For large facilities collect at least one sample per building until you get the number of samples required for the population served by the water supply (Table 1). 
• Again, If you have more than the chart number of drinking water fixtures, select ones that represent the water distribution system, i.e. one in each building wing or on each floor. Or, you can collect more than the minimum number of samples.

• If you have a only a few buildings, split the samples among them as best you can according to where the water is being consumed.

What if my facility has been testing for lead and copper all along?

For other systems already conducting lead/copper sampling, the number of samples collected shall be adjusted per these new regulations at the next routine monitoring period as notified by the local health department.

What happens if my first two sampling periods show very low results for lead and copper?  Will I have to continue to sample?

A nontransient water supply with two consecutive six-month samples less than or equal to .005 mg/l lead and .65 mg/l copper may go directly to monitoring once every three years (skipping the two annual sampling sets).

If you have questions, please contact the Noncommunity staff person for your local health department.

There are forms available that can be used for recording and reporting the lead/copper sampling results to the local health department.  The following form requires Adobe Acrobat Reader 5.0 

Lead/Copper sampling reporting form