FULTON, NY – Staff at Fulton City School District is hurriedly collecting water samples from all outlets throughout the district to satisfy new lead testing regulations in New York State.
Signed into law by NYS Governor Andrew Cuomo on September 6, 2016, legislation Subpart 67-4 sets new regulations for all public schools grades Pre-K – 12 across the state in regards to lead testing of drinking water within school buildings.
At a NYS Department of Health and State Education Department joint briefing, Fulton City School District officials were brought up to speed on these new regulations and procedures.
Jerry Seguin, director of facilities, operation and transportation for the district updated the board of education at Tuesday’s (Sept 27) regular meeting.
The first step in the new testing process involves monitoring all drinking or ingesting water outlets throughout the Fulton School District, which remains up to school officials to determine which outlets are accessible.
For example, any outlet that may result in ingestion of water such as a hose bib at the athletic complex used to fill water jugs and even ice machines, “things that you don’t normally think about” must be sampled, Seguin said.
After learning of the details of the new regulations on September 16, FCSD is required to submit the first draw samples for all water outlets for grades pre-kindergarten through fifth grade by September 30.
With a two week turn around, Seguin said Fulton is fortunate to have been ahead in the process.
FCSD completed roughly 18-20% of the district’s water sampling in April 2016 of which a few fountains that were tested were found to be in excess levels, all which have since been repaired.
“Luckily, Fulton City Schools has been out in front of this. As a group, we’ve come together and we’ve done some sampling following the EPA 3Ts guidelines which was the recommended practice at the time. They’re still recommending it even though they’ve gotten more stringent,” Seguin said.
The Environmental Protection Agency had used a 3T’s technical guidance manual as a guide to monitor the amount of lead in school’s drinking water as a suggestion based on the agency’s fear of elevated lead intake in children. This is the guideline FCSD followed when sampling water for lead testing in April 2016.
Under the new legislation, prior sampling can be accepted as long as it fits new guidelines including that the samples were completed after January 1, 2015, that the draws are consistent with new regulations in Subpart 67-4, and that the analysis was completed by an ELAP (Environmental Laboratory Accreditation Program) approved lab.
Seguin said the prior testing by FCSD done in April meets this criteria.
However, also changed in the new legislation is the response to test results.
Under new procedure, the action level has changed from the EPA 3Ts previously set action level of 20 parts per billion (ppb) to an action level of 15ppb.
This means, any water outlet that tests higher than 15ppb requires action from the school district.
In the case of an exceeded action level, school officials must prohibit use of the outlet, ensure there is an adequate amount of drinkable water available, and notify staff and parents within ten business days of the test results.
Seguin said all outlets that were previously tested have been reviewed and passed both the 20ppb action level as set by the EPA 3Ts as well as the new 15ppb action level as set by Subpart 67-4, with the exception of one outlet at the Fulton Junior High School that exceeded the new action level (15ppb.)
All response steps have been started for that water outlet, he added.
Water outlets that are considered not potable, such as restroom and science lab sinks may be labeled as “non-potable water” with appropriate signage.
However, these outlets must still be tested prior to labeling, despite their non-potable description.
Once the sampling draw results are completed, they must be reported to the NYS Department of Health, the State Education Department and newly, the Oswego County Department of Health.
The records must be kept for ten years and monitoring will occur every five years.
With that, the next sampling event will take place in 2020 which will align with the Building Condition Survey (BCS.)
FCSD is hopeful the water sampling and the BCS can come from the same funding, although that is still yet to be officially determined, according to Seguin.
As of right now, Seguin and his team have identified all water outlets throughout the district. They have completed sampling at the Education Center, Fairgrieve Elementary, Volney Elementary, and Lanigan Elementary with completion at Granby Elementary expected by the end of the week.
Despite testing 18-20% of water outlets earlier this year, there are an additional 320 samples required from elementary schools throughout the district as well as an additional 300 samples required from the Junior High School, High School, and athletic complex.
The second sample collected from all water outlets in sixth grade through twelfth grade are due on October 31.
“They keep telling me, Fulton schools are in really good shape. We’re out in front of this,” Seguin said.
Superintendent of Schools Brian Pulvino took a moment to recognize Seguin and his team of staff at the district that are working to complete all the sampling.
“I didn’t realize there was that many (water outlets),” Pulvino said. “Jerry and his team made a commitment to do this outside of school hours so they didn’t interfere with students at all. I just wanted to recognize the team for doing that and for following the procedures and process to a T. It’s just been impressive to me.”