Annex_A_FY2018_HRF_Initial_Sampling_Protocol.pdf

U.S. Arm y Publ ic Heal th Center

Protocol for Sampling Lead in Drinking Water at Child Development Centers, Elementary Schools, and Youth Centers

General Medical: 500A

Approved for public release; distribution unlimited

September 2017

Annex A (Protocol for Sampling Lead in Drinking Water at Child Development Centers, Elementary Schools, and Youth Centers) to OPERATIONS ORDER 18-109: Sampling for Lead in Drinking Water at High Risk Facilities and Army Family Housing (U)

Use of trademarked name(s) does not imply endorsement by the U.S. Army but is intended only to assist in identification of a specific product.

PROTOCOL FOR SAMPLING LEAD IN DRINKING WATER

AT HIGH RISK FACILITIES

1. PURPOSE. To provide a standardized protocol for sampling drinking water from sinks and drinking fountains primarily used for human consumption in high risk facilities in order to characterize lead exposure from drinking water under normal operations and water usage patterns.

2. SCOPE. This protocol supports U.S. Army Installation Management Command (IMCOM) Operations Order (OPORD) 16-080 and subsequent Fragmentary Orders (FRAGOs). This protocol explains, in a 6-step process, how to conduct sampling for lead in drinking water from sinks and drinking fountains used for consumption (i.e., primary drinking water outlets) in high risk facilities (HRF) - defined as child development centers, elementary schools, and youth centers. Proper sampling IAW this protocol requires sample collection from high risk facilities as follows:

Collect only a single 250-milliliter (mL) first draw sample from sinks and bubbler-type (non-refrigerating) drinking fountains.

Collect 250-mL first draw, 30-second flushed, and 2-minute flushed samples (i.e., a 3-sample set) from water cooler-type (refrigerating) drinking fountains

Collect a 3-sample set from 10 percent of total primary drinking water outlets sampled per HRF. For an HRF with fewer than 10 primary drinking water outlets, collect a 3-sample set from at least one primary drinking water outlet.

This protocol is largely based upon guidance contained in these documents:

3Ts for Reducing Lead in Drinking Water in Child Care Facilities: Revised Guidance, U.S. Environmental Protection Agency (EPA) 816-R-05-001, Dec

3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance, EPA 816-B-05-008, Oct 06.

Michigan Department of Environmental Quality Guidance on Drinking Water

Sampling for Lead and Copper at Schools and Daycares on Community Water Supplies, Michigan Department of Environmental Quality, Aug 16.

This sampling is not for regulatory or compliance purposes and is not related to the Lead and Copper Rule (LCR) sampling.

Protocol for Sampling Lead in Drinking Water at High Risk Facilities FY2018

3. BACKGROUND

Appendix A provides the history and reasoning for the sampling procedures outlined in this protocol.

4. STEP 1: LABORATORY COORDINATION

Laboratories at U.S. Army Public Health Center (APHC), U.S Army Public Health Command-Europe (PHC-E), and U.S. Army Public Health Command–Pacific (PHC-P) will provide analytical support. The following is contact information for the laboratories:

Continental U.S. Installations contact the APHC Laboratory at:

APHC Client Services Division

Email: usarmy.apg.medcom-phc.list.org-ls-ls@mail.mil

Telephone: 410-436-2208

DSN: 584-2208

Overseas Installations contact Public Health Command Laboratories at:

PHC-P Division of Laboratory Sciences

Email: usarmy.zama.medcom-jpn.list.phcr-pacific-cmd@mail.mil

Telephone: 011-81-46-407-5615/8421

DSN: (315) 263-5615/8421

PHC-E Laboratory Sciences

Email: usarmy.landstuhl.medcom-ph-e.mbx.ls-hotline@mail.mil

Telephone:

06371-9464-9710 (within Germany) (+49) 6371-9464-9710 (from outside Germany)

DSN: (314) 590-9710

Samples must be collected in 250-mL plastic sample containers. Laboratories will provide “wide mouth” plastic sample containers. The sample container openings should be wide enough to allow collection of samples from a fully open sink faucet. This is representative sampling at a flow rate resembling the way someone would usually fill a glass of water or a pot for cooking. In addition, laboratories will provide any other supplies needed such as chain of custody forms and seals, and shipping containers.

Lead samples in drinking water require preservation with nitric acid (HNO3). Due to safety concerns and to help expedite sampling by installation personnel, sample preservation will be done by the laboratory immediately upon receipt of the samples.

The sample can be held up to 14 days prior to acidification without loss of lead through absorption, but EPA recommends sample preservation as soon as possible. To ensure preservation occurs within 14 days of collection, samples must be received by the laboratory within 8-10 days of collection to ensure accurate data.

5. STEP 2: DETERMINING WHEN TO SAMPLE.

Samples must be collected after water has sat in contact with building plumbing for a period of time and before any water is used in the building. In HRFs, each outlet to be sampled must sit unused for at least 8–18 hours. The purpose of the minimum time periods is to be representative of typical overnight stagnation (i.e., normal usage patterns).

To achieve a minimum of 8–18 hours of stagnation outlets should be prepared at the end of a business/school day and samples collected the following day before the facility opens and before any water is used in the facility. It is acceptable to conduct sampling after longer periods of non-usage (for example over a weekend), but it is not recommended to conduct sampling after extended periods of non-usage (e.g., summer break).

Do not conduct sampling if cleaning crews are working during the designated non-usage period. When planning your sampling event, determine when cleaning crews will not be working in the facility during the period outlets are to sit unused.

6. STEP 3: CHOOSING AND PREPARING OUTLETS FOR SAMPLING.

All primary drinking water outlets must be sampled. Primary drinking water outlets are those sinks and fountains that typically and routinely provide water for consumption to infants and children up to and including 6 years of age. Water for consumption includes water used for drinking and in food, beverage, and infant formula preparation. Primary drinking water outlets include, but are not limited to—

Drinking water fountains Kitchen sinks Break room/lounge sinks Cafeteria sinks Food preparation sinks

For HRFs, most primary outlets will be obvious; however, consultation with facility staff should also be conducted to identify outlets not typically considered as primary drinking water outlets but are being used on a routine or consistent basis by children. For example, there may be classroom sinks in a building where children routinely get drinks of water or the sinks are used daily to prepare beverages. Do not sample sinks equipped with automatic/sensor faucets and thermostatic mixing valves as these sinks are not intended to be used as primary drinking water outlets because they do not provide cold water. These sinks are designed to provide a mix of hot and cold water intended to produce consistently tepid water. Hot water by itself or mixed with cold water should never be used for drinking, or food/beverage/formula preparation because hot water will dissolve lead more quickly than cold water and will likely contain increased lead levels. If these sinks are present in any of the buildings in the sampling program, discuss with facility staff and ensure they are not being used for consumptive purposes.

Special consideration should be given to sampling water cooler-type drinking fountains (fountains that chill the water). This protocol recommends a 3-sample set be collected from these fountains. However, certain water cooler designs and configurations will allow fewer samples to be collected. For example, in many bi-level water coolers both bubbler heads are supplied by a single chilled water storage tank. Figure 1 shows a bi-level water cooler with the water line serving the higher bubbler head supplied from the same, single chilled water storage tank supplying the lower bubbler head. Therefore, it is only necessary to collect a 3-sample set from one bubbler head first and then collect only a first draw sample from the other bubbler head for a total of four samples collected.

Figure 1. Bi-Level Water Cooler-Type Drinking Fountain

Similarly, the bi-level water cooler in Figure 2 has a water bottle filler outlet and all three outlets are supplied by a single chilled water storage tank. For this water cooler a 3-sample set should be collected from the bottle filter outlet first and then only first draw samples are needed from the bubbler heads. A total of five samples would be collected from the water cooler drinking fountain shown in Figure 2. Before applying this sampling approach verify a fountain’s plumbing configuration. This sampling approach can also be applied to other combination outlets such as a sink and bubbler head combination unit. In all cases, the 3-sample set should be collected first.

Figure 2. Bi-Level Water Cooler-Type Drinking Fountain with Bottle Filler

Preparing outlets for sampling may require them to be labeled or identified in such a way to prevent the drinking water outlet from being used or disturbed. This could be accomplished by placing a bag over the drinking water outlet and attaching a tag identifying the outlet as a sample site. Appendix B provides example tags.

Do not close any shut-off valves to fountains or sinks to prevent their use prior to sample collection. Closing valves may produce minute scrapings from the valves that could cause inaccurate, non-representative results showing higher than actual lead levels in the water.

For HRFs that are in operation (not closed for an extended period), DO NOT flush outlets in preparation for sampling because this would not be representative of normal usage patterns.

DO NOT remove or clean a sink faucet aerator in preparation for sampling because this would also not be representative of normal usage patterns.

While sampling HRFs in operation is the best approach for characterizing lead exposure from drinking water in these facilities, it may be necessary to sample closed facilities. In the event that sampling of HRFs that are closed for an extended period (e.g., summer break) must be conducted, the building plumbing must be flushed prior to allowing water to sit unused before sampling. The purpose of this flushing is to simulate typical water quality that would be provided to children if HRFs were in operation. The quality of drinking water that has sat unused in building plumbing for several weeks or months will likely be significantly degraded and would not be representative of typical water quality provided. Therefore, it’s necessary to thoroughly flush building plumbing prior to sampling. The following guidance should be used for flushing. Note that flushing building plumbing any time after HRFs have been closed for extended periods is an excellent best management practice to employ prior to opening/occupying these facilities.

Flush Closed High Risk Facilities in the Following Manner:

Flushing closed HRFs involves a two-step process – flushing building plumbing followed by flushing primary drinking water outlets.

First, locate sinks that are furthest away from the building service connection and from piping branches or runs in each wing or floor of an HRF. Figure 3 shows examples of sinks to flush. Flush these sinks for 10 minutes. These sinks don’t have to be primary drinking water outlets. The intent of this step is to flush out the very stagnant water from the building plumbing.

Figure 3. Choosing Sinks in Closed HRFs to Flush Building Plumbing

Next, flush all primary drinking water outlets. In no particular order, flush sinks and bubbler-type drinking fountains for at least 30 seconds and flush water cooler-type drinking fountains for at least 2 minutes.

= Sink

Building service connection

Pipe riser

Closest

Furthest

Single story building Floor in multi-story building with single pipe riser

Floor in multi-story building with multiple pipe risers

Choose any of these sinks that are equidistant from multiple risers to maximize the amount of plumbing flushed

Flush this sink

Flush this sink

Protocol for Sampling Lead in Drinking Water at High Risk Facilities FY 2018

7. STEP 4: LABELING SAMPLE CONTAINERS.

Prior to collecting samples from a primary outlet, fill out the sample container labels using a permanent marker with a unique sample identifier (e.g., 1a) and the date and time the sample is collected.

Please use a unique sample identifier (ID) for each sample collected at an installation.

One option is to use a numbering system that identifies a unique outlet followed by alphabetical lowercase letters that identifies sample(s) collected from the outlet. As an example, the first outlet sampled at an HRF on an installation is a water cooler-type drinking fountain and is identified as “1”. The three samples collected from this outlet will be identified as: “1a” (first draw); “1b” (30-sec flush); and “1c” (2-min flush). No other outlets sampled for this effort at this installation should be identified as “1”.

Subsequent samples collected at other outlets in the same building as well as outlets in other buildings at the same installation will have their own unique sample IDs. For example, the second outlet sampled at an HRF at the same installation is a kitchen sink and will be identified as “2”. Only a first draw sample will be collected from this sink and will be identified as “2a”.

8. STEP 5: COLLECTING SAMPLES

Collect only a single first draw sample from sinks and bubbler-type drinking fountains.

Collect first draw, 30-second flushed, and 2-minute flushed samples (i.e., a 3-sample set) from water cooler-type drinking fountains (figure 4). Note the special considerations for sampling water cooler-type fountains in Section 6 Step 3.

Figure 4. 3-Sample Set.

Collect a 3-sample set from 10 percent of total primary drinking water outlets sampled per HRF. For an HRF with fewer than 10 primary drinking water outlets, collect a 3-sample set from at least one primary drinking water outlet. These outlets should be spread out and located throughout an HRF to ensure samples collected are representative of water in contact with building plumbing. Sinks instead of drinking fountains should be chosen for this sampling.

Ensure sample containers are kept sealed until collection of the samples.

Collect samples after water has sat unused for a minimum of 8-18 hours and before any water is used in the facility. Do not run any drinking water outlets or flush toilets elsewhere in the facility before collecting samples.

Collect Samples in HRFs in the Following Manner:

Start collecting samples beginning with the primary drinking water outlet located closest to the service connection and moving away towards the furthest outlets from the service connection, sampling primary drinking water outlets along the way.

For sinks and bubbler-type drinking fountains where only a first draw sample is collected:

o For sinks use only the cold water tap.

o Fill sample containers mostly full to allow room for addition of several milliliters of acid by the laboratory.

o Place the properly labeled sample container (the container labeled with the correct location, outlet, and sample type) under the faucet or positioned to capture water from the fountain. Do not allow the sample container to touch the faucet or fountain. Fully open the faucet/operate the fountain and immediately collect the water without allowing any water to go to waste. Turn off the water and cap and seal the container.

For water cooler-type drinking fountains where a 3-sample set will be collected, use the following sample procedure:

o If collecting samples from multiple outlets associated with a water cooler fountain (e.g., a bi-level fountain) as described in Section 6, Step 3, always collect the 3-sample set first.

o First draw sample collection. Position the 250-mL labeled sample container (e.g., labeled ‘a’) to capture water immediately after operating the fountain without allowing any water to go to waste. Fully open the fountain’s operating valve (i.e., run the fountain) and fill the container mostly full. Set the container aside, continue to run the fountain, and begin timing.

o 30-second flush-sample collection. Continue to run the fountain for 30 seconds. After 30 seconds, while the water is still flowing, position the 30-second flush-labeled sample container (e.g., labeled ‘b’) in the flow and fill the container mostly full. Continue to run the fountain and continue timing.

Set the container aside.

o 2-minute flush-sample collection. After 2 minutes has passed with the fountain running, position the 2-minute flush-labeled sample container (e.g., labeled ‘c’) in the flow and fill the container mostly full. Turn off the fountain and cap and seal all sample containers.

For sinks chosen for a 3-sample set collection use the following sample procedure:

o Use only the cold water tap.

o Collect samples without shutting off the water.

o Fill sample containers mostly full to allow room for addition of several milliliters of acid by the laboratory.

o First draw sample collection. Place the sample container (e.g., the container with ‘a’ on the label) under the faucet. Do not allow the sample container to touch the faucet. Fully open the faucet. Collect water immediately after opening the faucet without allowing any water to go to waste. With the water still running set the sample container aside and begin timing for collection of the 30-second and 2-minute flushed samples.

o 30-second flush sample collection. After 30 seconds with the water still running, quickly place the 30-second flush-labeled sample container (e.g., labeled ‘b’) under the faucet and fill the container mostly full. Set the sample container aside and allow the water to continue running. Continue timing.

o 2-minute flush sample collection. After the water has continued to flow for

2 minutes, quickly place the 2-minute flush-labeled sample container (e.g., labeled ‘c’) under the faucet and fill the container mostly full. Turn off the water and cap and seal all containers.

9. STEP 5: SHIPPING SAMPLES

Ship or deliver samples to arrive at the laboratory as soon as practical but within 8-10 days of collection.

Samples must be acid-preserved by the laboratory within 14 days of collection.

To facilitate sample handling, processing, and preservation by acidification:

Confirm the proper shipping address for the laboratory.

Ship samples using the provided coolers and shipping return labels.

Fill out the chain-of-custody form, and include with the samples. Please fill out the chain of custody as completely and accurately as possible. Contact the laboratory if you have any questions about completing these forms.

Pack the samples in the cooler; ice is not necessary. Secure the samples in the cooler/shipping container so they don’t move around to avoid potential leaking from caps jarred loose. Packing material such as wadded paper or pieces of cardboard could be used. Bubble wrap is not necessary.

Seal the cooler using packing tape, and place a provided cooler seal on the cooler, applying the seal to both the cooler body, and cover of the cooler.

Notify the laboratory at least 1 day prior to shipping or delivering the samples.

If shipping via FedEx®, drop the cooler at the nearest pickup site and ship via “Priority Overnight” service. Please do not ship via “First Overnight” service.

10. FACILITY AND SAMPLE FIELD DATA SHEETS.

Fill out the facility and sample field data sheets and provide electronic copies to the APHC point of contact listed in the most recent FRAGO to IMCOM OPORD 16-080.

The data sheets are located on HQ IMCOM’s sharepoint website for this sampling effort.

The Facility Field Data Sheet (Figure 5) is a fillable pdf document intended to obtain information on potential sources of lead in facility/building plumbing where samples are collected. It may be necessary need to contact plumbing personnel and personnel in the real property office to complete this sheet.

Figure 5. Facility Field Data Sheet, FFDS

The Sample Field Data Sheet, SFDS is an Excel® file and is intended to document sample information from all facilities at an installation (Figure 6).

Figure 6. Sample Field Data Sheet

Room # / Housing Unit

Address

Room/sample location description (classroom, cafeteria, kitchen)

1a 123 A14 cafeteria S = Sink 17-Mar-16 0545 O = Occupied 1b 123 A14 cafeteria S 17-Mar-16 0546 O 1c 123 A14 cafeteria S 17-Mar-16 0548 O

2a 123 - outside playground

WC = Water cooler fountain 17-Mar-16 0550 O

2b 123 - outside playground WC 17-Mar-16 0551 O

2c 123 - outside playground WC 17-Mar-16 0553 O

3a 8877 - entry hallway WB = Bubbler fountain 18-Mar-16 0705 V = Vacant

EXAMPLE

Is Facility Vacant or Occupied?

Sample Collection

Date

Sample Collection

Time

Sample ID (Number)

Facility/ Building #

Sample Location

Outlet type

11. POINT OF CONTACT. For questions about these procedures, please contact the APHC POC listed in the most recent FRAGO to IMCOM OPORD 16-080; or contact the Drinking Water Branch of the APHC at: DSN 584-3919, commercial (410) 436-3919, or email:

usarmy.apg.medcom-phc.mbx.dehe-water-supply@mail.mil.

A-1

APPENDIX A

BACKGROUND

A-2

A1. THE ORIGINAL PROTOCOL. The original protocol was developed in fiscal year (FY) 2013 in support of U.S. Installation Management Command (IMCOM) Operations Order (OPORD) 13-363 which required sampling in high risk facilities identified as child development centers, elementary schools, and youth centers. At that time, the protocol was closely based on current U.S. Environmental Protection Agency (EPA) guidance requiring a single first draw sample or a first draw sample followed by a 30 second flush sample from an outlet (see references in section 2). Additionally, at that time this protocol adopted the EPA recommended 20 parts per billion (ppb) criteria for taking corrective action at an individual outlet.

A2. FISCAL YEAR 2016 UPDATE. In FY 2016, this protocol was updated in support of IMCOM OPORD 16-080. The sampling procedure and criteria were changed to incorporate recent research on lead corrosion in drinking water. Research suggested that sources of elevated lead may be found deeper in a facility’s supply plumbing and/or service line, and higher flowrates may entrain or mobilize lead-containing particulates which could result in higher lead levels at an outlet. The sampling procedure was changed to require collection of a set of three samples (a first draw and two flushed samples) at the highest flowrate possible (e.g., fully open cold water tap) at each identified outlet. Also, the criteria for taking action at an individual outlet was revised to 15 ppb (from EPA’s recommended 20 ppb criteria) based on research that identifies drinking water as an increasing contributor of lead exposure and more strongly links elevated water lead levels to increased blood lead levels. Lastly, the protocol was updated to include sampling procedures for Army Family Housing (AFH).

A3. FISCAL YEAR 2017 UPDATE. In early FY 2017 this protocol was updated again and distributed with IMCOM Fragmentation Order (FRAGO) 02 to IMCOM OPORD 16-

080. The major changes to the protocol included:

In HRFs, use of a sampling sequence beginning with outlets closest to the building service connection and ending with outlets furthest from the service connection (see section 8); and

Flushing guidance when sampling vacant AFH units or HRFs that have not been in use for an extended period of time (see section 6); and

The use of a sampling sequence in HRFs – starting at the outlet closest to the service connection and moving away - could help minimize the chance of unintentionally flushing stagnant water from an upstream outlet if first collecting samples at a downstream outlet (i.e., an outlet located further away from the building service connection).

While sampling occupied AFH residences and HRFs in operation is the best approach

A-3 for characterizing lead exposure from drinking water in these facilities, it may be necessary in some circumstances to sample vacant or closed facilities. In the event that sampling of vacant AFH residences or HRFs that are closed for an extended period (e.g., AFH residences vacant for weeks or months, and HRFs closed for weeks/months over summer break) must be conducted, the building plumbing must be flushed prior to allowing water to sit unused before sampling. The purpose of this flushing is to simulate typical water quality that would be provided to families and children if AFH residences were occupied or HRFs were in operation. The quality of drinking water that has sat unused in building plumbing for several weeks or months will likely be significantly degraded and would not be representative of typical water quality provided. Therefore, it’s necessary to thoroughly flush building plumbing prior to sampling. Note that flushing building plumbing any time after AFH residences or HRFs have been vacant or closed for extended periods is an excellent best management practice to employ prior to opening/occupying these facilities.

A4. FISCAL YEAR 2018 UPDATE. This current protocol version contains the following changes:

A modified sample protocol that better balances the sample burden while still maintains a rigorous sample scheme that seeks to accurately characterize lead exposure from drinking water; and

Separation of HRF and AFH initial sample protocols.

After a review of available results from the FY16 and FY17 sampling effort, the HRF initial sample protocol was modified to reduce the sampling burden on Garrison personnel and maintain an effective sample approach that can accurately characterize lead exposure from drinking water (at the time of sampling). In FY16 and FY17 6,028 samples were collected from 1,997 outlets in 110 HRFs. There were 58 outlets that had at least one sample result greater than 15 ppb lead. The figure shows which samples for those 58 outlets had elevated lead levels. The majority of the outlets (76 percent) had only a first draw sample result greater than 15 ppb lead while approximately 25 percent of the outlets had an elevated 30-second and/or 2-minute flushed sample result either with an elevated first draw sample result (10 percent) or without an elevated first draw sample result (14 percent). Additionally, the majority of the outlets with an elevated flushed sample result (57 percent) were identified as drinking fountains and most of those were reportedly water cooler-type fountains. These results suggest that the sample protocol could reduce, but not completely eliminate collection of flushed samples. Thus, collecting only first draw samples from the majority of outlets in an HRF and collecting a 3-sample set (first draw, 30-second flush, and 2-minute flush samples) from a small percentage of representative outlets throughout an HRF would still be effective in characterizing lead exposure from drinking water in an HRF (at the time of

A-4 sampling). Furthermore, results suggest that a 3-sample set should continue to be collected from water cooler-type drinking fountains/

Figure. Evaluation of FY16 & FY17 lead sample results > 15 ppb n = 58 outlets

B-1

APPENDIX B

EXAMPLE OUTLET SAMPLE TAGS

B-2

DO NOT USE. DO NOT DISTURB.

Drinking Water Sampling in Progress.

Point of Contact:

Name:

Phone Number:

DO NOT USE. DO NOT DISTURB.

Drinking Water Sampling in Progress.

Point of Contact:

Name:

Phone Number: