The Army is sampling drinking water outlets in Army Family Housing (AFH) units for lead as a proactive measure to protect children's health. This effort began in 2013 and aims to test 20% of AFH units annually over five years. While Army installations meet regulatory water testing standards, routine tests do not require individual testing of all outlets. Testing specific outlets can help identify potential lead issues and inform policy. Elevated lead levels above 15 parts per billion will trigger corrective actions like providing alternative water or installing filters. The goal is to ensure children's safety through detailed information on housing unit water quality.
1. FREQUENTLY ASKED QUESTIONS
INSTALLATION MANAGEMENT COMMAND (IMCOM)
LEAD SAMPLING IN ARMY FAMILY HOUSING UNITS
Q. Why is the Army sampling the water for lead now?
A. This sampling effort is a continuation of the effort begun in 2013 to ensure that the
Army is being as protective as possible of the children in its care. The Army’s
installations are in compliance with regulations for testing for lead in drinking water.
However, the regular water sampling conducted at Army installations in accordance
with Federal, State, and Local standards does not require 100% sampling of Army
Family Housing (AFH) units. Because exposure to lead, even at low levels, may
cause developmental issues in children ages 6 years old and under, the Army is
proactively conducting this additional sampling in an abundance of caution.
This sampling effort will give the Army more detailed information about the status of
the drinking water in Army Family Housing, facilitate the correction of any issues that
are discovered, and guide policy discussions regarding whether or not to develop
additional testing standards.
Q. What prompted the Army to do this testing?
A. The Army began this effort in 2013 as a proactive response to information
suggesting water faucets used for drinking and food preparation at facilities where
children age six and under, who are a sensitive population, could receive a
significant amount of drinking water be tested individually for lead. Although the
Army’s installations are in compliance with regulations for testing for lead in drinking
water, the routine water sampling conducted in accordance with Federal, State, and
Local standards does not require additional site-specific testing at child development
centers, youth centers and schools. Based on the suggested safeguard for this
sensitive population, the Army surveyed its installations regarding their policies for
testing the facilities. Although the majority of the installations do test drinking water
at child development centers, youth centers and schools, the Army found that there
was no standard sampling procedure in place for these facilities and that records
were incomplete regarding sampling and response measures taken when lead in
drinking water was above the U.S. Environmental Protection Agency (EPA)
recommended level.
Recently, the Army made the decision to include AFH units in this ongoing sampling
effort. 100% of Army Family Housing (AFH) units will be sampled for the presence
of lead in drinking water over the next five years. The goal is to sample no less than
20% of AFH units each year.
2. Q. Is this sampling being done because of what has occurred in Flint, MI?
A. No. The Army’s installations are in compliance with regulations for testing for lead
and numerous other regulated contaminants in drinking water. Water sampling is
conducted regularly at Army installations and reported to water system users in
accordance with Federal, State, and Local standards. This sampling is a
continuation of an effort begun by the Army in 2013. At that time the Army realized
there were no specific drinking water requirements to sample CDCs, schools, and
youth centers; places where children spend a lot of their time and may consume a
significant amount of drinking water. The lack of requirements in current drinking
water regulations for routine sampling of lead in water at these locations calls for the
development and implementation of a routine sampling program for testing drinking
water outlets (sinks and fountains) primarily used for consumption in facilities used
by children age six and under. The Army intends to continue sampling these
facilities on a routine basis, and recently included AFH units in this sampling effort.
Q. What is the difference between testing a public water supply and testing at
specific water outlets in AFH units?
A. Lead testing for public water systems under the EPA’s Lead and Copper Rule is
aimed at identifying system-wide corrosion problems that could cause elevated
levels of lead in drinking water. For these tests samples are collected at many
locations known or likely to have leaded plumbing components such as older lead-
soldered copper plumbing (high-risk residences), throughout the public water
system. Results are analyzed for individual samples and if more than 10 percent of
all the samples exceed 15 ppb, system-wide corrosion control treatment may be
necessary.
For sampling of AFH units, the Army follows the EPA recommendation to collect
samples from any sinks used for food preparation or identified as a primary source
of drinking water. EPA recommends that any sink be taken out of service if the lead
level exceeds 20 ppb. However, based on recent research that identified drinking
water as an increasing contributor of lead exposure and more strongly links elevated
water lead levels to increased blood lead levels, the Army is using a more stringent
15 ppb lead level to determine if any water fountain or sink used for drinking or food
preparation will be taken out of service.
Both the 15 ppb action level for public water supply testing and the EPA
recommended level of 20 ppb (and the more stringent 15 ppb the Army is using) for
testing at child development centers, schools and AFH units are triggers for
treatment and/or corrective action to reduce lead levels in drinking water and to
prevent lead levels from elevating further.
3. Q. Is this testing different than regular drinking water testing?
A. Yes. This IMCOM lead testing initiative is a proactive Army effort and not required or
regulated by the EPA. The Army asked its experts at the U.S. Army Environmental
Command and the Army Public Health Center (Provisional) to develop the sampling
protocols. The sampling protocols are based on EPA recommendations and are
meant to target sinks and fountains where children get a large amount of their
drinking water. This will ensure that the samples accurately reflect the quality of the
water these children may actually consume.
Routine drinking water testing is typically conducted at many locations throughout
the water distribution system. Lead and Copper Rule testing samples high-risk
residences, but those do not usually include child development centers, youth
centers and schools and also do not include 100% of AFH units. Routine drinking
water testing and Lead and Copper Rule testing is required, as are the use of their
associated sampling protocols.
Q. If lead is found in the drinking water does that mean that the children in that
AFH unit are at risk?
A. Not necessarily, although the Army will take corrective action if lead levels exceed
15ppb in any of the samples taken. It is important to note that the EPA sets action
levels and recommended maximum levels for contaminants in drinking water with a
goal of identifying and correcting issues before negative health effects are
experienced. Exposure to lead above action levels can pose a potential health risk,
but whether or not an individual experiences any negative health effects depends on
many factors. If parents or guardians have any questions or concerns about
whether their children are experiencing negative health effects as a result of possible
lead exposure, they are encouraged to contact their child’s primary care provider.
Generally, clinics and pediatric providers follow the American Academy of Pediatrics
(AAP) recommendations for lead screening and testing in children and infants.
Providers also have the benefit of considering information about the child’s medical
history, current health, and potential for exposure to other sources of lead when
making medical decisions and recommendations.
Q. How does lead get into drinking water?
A. Measures taken during the last two decades have greatly reduced exposures to lead
in tap water. These measures include actions taken under the requirements of the
1986, 1996, and 2011 amendments to the Safe Drinking Water Act, the U.S.
Environmental Protection Agency’s (EPA’s) Lead and Copper Rule, and the
Department of Defense (DoD) Final Governing Standards (FGS), as applicable.
Even so, lead can enter the water through contact with the plumbing that carries it, a
process called leaching. Lead leaches into water through corrosion – a dissolving or
wearing-away of metal caused by a chemical reaction between water and plumbing
4. that contains lead. Lead can leach into water from pipes, solder, fixtures and
faucets (brass), and fittings. Lead can also be found in water in particulate (solid)
form that could become dislodged from pipes and be ingested. The amount of lead
in water also depends on factors such as the types and amounts of minerals in the
water, how long the water stays in the pipes, the amount of wear in the pipes, the
water’s acidity and its temperature.
Q. How do I know if tap water is contaminated with lead?
A. The only way to know whether tap water contains lead is to have it tested. You
cannot see, taste, or smell lead in drinking water.
Q. How do I learn more about the safety of drinking water?
A. The EPA and Army Regulation (AR) 200-1 require all community water systems to
prepare and deliver an annual consumer confidence report (CCR) (sometimes called
an annual water quality report) for their customers by July 1 of each year.
The CCR summarizes information regarding the sources of water used (i.e., rivers,
lakes, reservoirs, or aquifers), any detected contaminants, compliance and
educational information. Some water suppliers post their CCRs on the EPA’s web
site. If your water supplier does not, you may request a copy by contacting them
directly.
Recommend each installation provide a link to their water system’s most recent CCR
here, as applicable.
Q. What are the potential negative health effects of lead exposure?
A. High levels of lead in tap water can cause negative health effects if the lead in the
water enters the bloodstream and causes an elevated blood lead level.
Risk will vary, however, depending upon the individual, the circumstances, and the
amount of water consumed. For example, infants who drink formula prepared with
lead-contaminated water may be at a higher risk because of the large volume of
water they consume relative to their body size. Infants and children may be at a
higher risk of experiencing delays in their physical or mental development. Children
may show deficits in attention span and learning abilities. Adults who drink this water
over many years may develop kidney problems or high blood pressure. (This is not
a comprehensive list of the potential health effects of lead exposure, but includes the
most common effects.)
5. Q. What type of water sampling is currently performed on a regular basis?
A. Community water systems regularly conduct bacterial and chemical sampling,
including lead, to ensure they are in compliance with Safe Drinking Water Act
standards. Results showing exceedances during these samplings are included in
the consumer confidence report (CCR) each community water system is required to
publish annually.
Your water system is also sampled at multiple locations throughout the distribution
system to ensure that there is enough chlorine or disinfectant to sanitize the water
and to test for the presence of bacteria such as E.coli.
Q. If water sampling indicates an elevated level of lead in the water, what will be
done?
A. If lead is detected above 15 ppb in the drinking water from any sink or faucet
sampled in an AFH unit, occupants will either be provided with an alternate water
source for drinking and food preparation, or will have carbon filters installed at the
affected water outlet. Follow-up sampling will be conducted to identify the source of
the lead, appropriate corrective actions will be taken, and additional samples will be
collected to ensure that the corrective actions were successful.
Similarly, if a water system exceeds the 15 ppb action level under the Lead and
Copper Rule, the system must take corrective actions to reduce lead levels system-
wide. This usually involves installing or improving corrosion control treatment. It
takes about 2-3 weeks to receive validated results after the samples are collected.
Those results will be communicated in a timely manner to the staff and users of each
facility, whether or not there are any elevated lead levels.
If you have any questions about this water sampling effort, please contact {INSERT
garrison POC(s) (e.g., PAO, DPW/Environmental)} at (phone number) or (e-mail).
Please visit the following sites for additional information:
Basic Information about Lead in Drinking Water (EPA):
https://safewater.zendesk.com/hc/en-us/sections/202366328
http://www.epa.gov/lead/protect-your-family#water
http://www.epa.gov/dwreginfo/drinking-water-schools-and-child-care-facilities
Lead Home, Prevention Tips, Source of Lead, Water (Centers for Disease Control
and Prevention):
http://www.cdc.gov/nceh/lead/tips/water.htm