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Water Sampling Plan

The safety of students and staff is a primary concern of the Pasadena Unified School District. The District has a safety program to maintain safe working conditions and equipment at all times to ensure that hazardous materials are appropriately managed, to comply with standards prescribed by applicable federal, state and local laws and regulations, and to serve as the environmental health and safety contact for school staff, parents, and the community.

Background on Water Testing
As a result of action taken on January 19, 2017, the State Water Resources Control Board (SWRCB) Department of Drinking Water amended the permit requirements for California water suppliers to provide assistance with sampling a school's drinking water system to test for lead. Any remediation is funded by the school district. 

Water for Pasadena Unified School District sites is provided by Pasadena Water & Power (PWP), Rubio Canyon Land and Water Association, Lincoln Avenue Water Community, and the City of Sierra Madre. To ensure all water outlets that may be used for drinking or food preparation meet the state’s standards, PUSD has requested that water agencies sample water outlets used for human consumption at district-owned sites, including PUSD schools and campuses operated by charter organizations.

Water outlets used for drinking or food preparation are tested after six hours of inactivity, according to California State Water Resources Control Board protocol. Samples are collected by trained staff members (City Municipalities, PWP) and sent to laboratories certified by the Environmental Laboratory Accreditation Program (ELAP) for lead analysis.  Laboratories submit the results to the SWRCB.

District Water Sampling Plan & Response
PUSD’s plans for water testing were first developed before the SWRCB action in January.  Once the state action was finalized, district staff met with representatives from water suppliers to develop water sampling and analysis plans at all sites covered by this permit amendment. PUSD has requested that water suppliers collect and analyze up to five water sample locations for each school site, including drinking fountains and kitchen faucets. 

The water sampling plan goes above and  beyond testing required by the state and calls for collecting two samples at five locations at each site. The plan includes a proposed remediation strategy for a school to implement in the event that lead is detected in the drinking water. Collecting two samples instead of one helps validate the remediation strategy and also helps mitigate the issue.

Test Results
The Pasadena Unified School District will take immediate action if lead levels are detected. Water faucets and other outlets used for human consumption will be immediately closed and bottled water will be delivered to the school until corrective action is completed. As test results are received, the school and its families will be quickly notified.  

Results which exceed the state’s action level will be addressed by PUSD’s Maintenance & Operations staff. Upon notification of an exceedance, M & O staff will quickly close access to water outlets with detectable lead levels, provide bottled water to the school, investigate potential sources of contamination, and begin plumbing and infrastructure fixes to eliminate sources of lead contamination.  Staff will also coordinate with the school principal in alerting parents and staff of results.  Once re-tested with results below the action level, the outlet will be placed back into service.

Why is the school district testing its water now?
A new state program now requires water providers to test water in schools if requested to do so by the school district. Pasadena Unified is taking advantage of this proactive program and has requested testing in all of its schools by agencies that provide water to district campuses: Pasadena Water & Power, the City of Sierra Madre, Rubio Canyon Land and Water Association, and Lincoln Avenue Water Community.

What action are you taking?
The District has requested that water suppliers test water fountains and food preparation water sources for lead content.  If test results show detectable levels of lead, PUSD will close access to those water sources, provide bottled water to the school, and complete plumbing and infrastructure fixes to resolve the issue. Once re-tested with results below the action level, the outlet will be placed back into service.

Where is information posted on water sampling?
Information is posted on the PUSD Facilities, Maintenance & Operations website at /Domain/56Another useful resource is the California Water Board’s Frequently Asked Questions webpage:

Who is doing the testing?
Testing is done in accordance with the SWRCB’s Division of Drinking Water sampling protocol, and is performed by trained staff from Pasadena Water & Power (PWP), the City of Sierra Madre, and other water agencies that serve the Pasadena Unified School District. Samples will be analyzed by laboratories certified by the Environmental Laboratory Accreditation Program (ELAP) for lead analysis. 
Information on the City of Pasadena’s water testing is available at

What is “first draw” testing of school drinking water for lead?
The “on-again, off-again” nature of water use at most schools can raise lead levels in school drinking water. Water that remains in pipes overnight, over a weekend, or over vacation periods stays in contact with lead pipes or lead solder and, as a result, could contain higher levels of lead. This is why schools are required to collect a sample after the water has been sitting in the plumbing system for a certain period of time. This “first draw” sample is likely to show higher levels of lead for that outlet than what you would see if you sampled after using the water continuously. However, even if the first draw sample does not reflect what you would see with continuous usage, it is still important because it can identify outlets that have elevated lead levels.

What schools will be tested?
Testing will be performed at all district-owned campuses, including PUSD schools, PUSD children’s centers, and charter schools.

When did testing begin?
Testing began in Summer 2017 and is expected to continue until testing is completed at all schools.

What about children’s centers?
While the state program only requires water suppliers to test schools listed in the California
School Directory (which excludes children’s centers), Pasadena Unified has requested that water suppliers draw samples from every children’s center.

Will water used in kitchens be tested?
Kitchens will be tested as part of this effort.

How will parents learn of the test results?
Parents will be updated by their child’s school. Parents may also visit the district’s water sampling webpage at /Domain/56

What should parents know about water sampling?
Water testing is taking place so that the district can provide parents the information they need to make informed decisions about their child’s well-being. Pasadena Unified is committed to keeping parents updated as the water testing takes place.
Parents are also encouraged to visit the City’s lead testing in schools page where additional resources may be found.

What will the district do if lead levels are found to exceed the recommended level?
Should a sample result reveal higher than allowable lead concentrations, the district is prepared to do the following:

  • Quickly close access to contaminated water fixtures
  • Provide bottled water to the school
  • Investigate potential sources of contamination and begin plumbing and infrastructure fixes to eliminate sources of lead contamination
  • Coordinate with the school principal in alerting parents and the public of results which will also be posted on district’s water sampling webpage
  • Once re-tested with results below the action level, the outlet will be placed back into service

Where does lead in drinking water come from?
According to the U.S. Environmental Protection Agency’s 3Ts (Training, Testing, and Telling) Program for Schools: “Most lead gets into drinking water after the water leaves the local well or treatment plant and comes into contact with plumbing materials containing lead. These include lead pipe and lead solder (commonly used until 1986) as well as faucets, valves, and other components made of brass. The physical/chemical interaction that occurs between the water and plumbing is referred to as corrosion. The extent to which corrosion occurs contributes to the amount of lead that can be released into the drinking water.”

Can't you just replace all pipes and faucets?
Wholesale replacement of piping may not be required since lead can leach into water from several sources, including lead solder and brass fittings. Most lead gets into drinking water from plumbing components such as faucets and valves made of brass or lead-containing solder.  The physical and chemical interaction that occurs between plumbing and water, known as corrosion, directly contributes to the amount of lead that is released into water.  Although plumbing components installed prior to the 1990’s contained more lead than new materials, the amount of lead cannot be predicted by the age of the building.

Replacing the brass infrastructure may not reduce lead concentrations immediately. In fact, new brass plumbing can cause higher concentrations of lead to be detected initially compared to older brass fixtures. Primarily because the lead present in older brass plumbing has leached out over the life of the plumbing fixtures while new brass, even low lead brass, will have higher concentrations of lead than older brass plumbing.

Water quality experts recommend flushing - or running water - through fixtures and drinking fountains that may be used for consumption of water or used for food preparation for 30 seconds to two minutes prior to the first use of the day.

Where can parents access information about the effects of lead?
The City of Pasadena’s Public Health Department has a Childhood Lead Poisoning Prevention Program with excellent resources about lead, prevention, and health impacts.  The Pasadena Public Health Department can be contacted at 626-744-6171 or online at

The County of Los Angeles Public Health Department also has a Childhood Lead Poisoning Prevention Program. The LA County Health Education Services can be contacted at 1 (800) 524-5323 or online at

What are the environmental sources of lead exposure for children?
According to the U.S. Environmental Protection Agency’s 3Ts (Training, Testing, and Telling) Program for Schools, the most common source of lead exposure for children is chips and particles of deteriorated lead paint, especially if they are exposed to house dust or soil contaminated by leaded paint. Other potential sources include lead in the air from industrial emissions, lead deposits in soils near streets from past emissions by automobiles using leaded gas, and lead in consumer products and food, such as imported candies, medicines, dishes, toys, jewelry, and plastics.

Is my child at risk of lead poisoning from drinking water?
Most sources of lead contamination for children come from paint manufactured before 1978, “take home” exposure (i.e., an adult unintentionally bringing lead from work to household), soil contaminated from unsafe work practices, and some home remedy treatments.

Is the water in my home safe?
Parents and guardians should be aware that lead in drinking water may exist in homes and other areas throughout the community. Any structure or brass fixtures with galvanized pipes or pipes where lead solder was used may leach lead into drinking water. In 1993, the U.S. EPA issued guidelines for households to flush faucets to reduce the amount of lead in drinking water.