Lead in Drinking Water
An Investigation of Arizona Schools

ARIZONA DEPARTMENT OF HEALTH SERVICES
Bureau of Epidemiology and Disease Control Services
Office of Environmental Health
150 N. 18th Avenue
Phoenix, Arizona 85007

Purpose
In March 2004, the U.S. Environmental Protection Agency (USEPA) requested information on
efforts to monitor and protect children from exposure to lead in drinking water at schools. The
Arizona Department of Health Services (ADHS) reviewed the state lead poisoning registry, and
analyzed drinking water samples from 45 randomly selected schools. Funding for the collection
and analysis of these samples was provided by the Children’s Environmental Health Section
located within ADHS. The Office of Environmental Health provided this consultation to help
document our findings and supplement our response to USEPA.
This work was also undertaken to help provide useful information should hazardous waste sites
be discovered in the future near these schools. We also wanted to apply the ATSDR health
assessment process in support of state and federal efforts to protect the health of children.
Introduction
In 2004, homes served by the District of Columbia (DC) Water and Sewer Authority (WASA)
was found to have elevated levels of lead in their drinking water. This discovery resulted in
national attention on lead in drinking water in DC and in states. Many school districts in the
greater DC area, tested their drinking water and found elevated lead levels. School systems
located in Seattle, Baltimore and Philadelphia also reported elevated lead levels in drinking
water1. As a result, in March 2004 USEPA requested information from state environmental and
health agencies on local efforts to monitor and protect children from exposures to lead in
drinking water at school facilities.
In response this request, ADHS collected and analyzed water samples from drinking fountains
and cafeterias at 45 randomly selected schools throughout Arizona. Depending on available
funding and staff resources, 35 more schools will be tested in the fall of 2004.
Background
Children are susceptible to adverse health effects from lead, such as impaired mental
development, IQ deficits, shorter attention spans, and lower birth weights. Exposure to lead is a
significant health concern, particularly for young children and infants whose growing bodies
tend to absorb more lead than the average adult. Testing water in schools and day care facilities
is important because children spend a significant portion of their days in these facilities and
likely consume water while there. There is no federal law requiring sampling of drinking water
in schools that receive water from public water systems1.
Currently, there are 1,080 elementary schools in Arizona, with 48% of the schools located in
Maricopa County. Pima County has 17% of the schools, and the remaining 13 counties each
have less than 5% of the elementary schools2.
ADHS Lead Poisoning Prevention Program
ADHS administers the Arizona Lead Poisoning Prevention Program through the Children’s
Environmental Health Program. This program maintains the state lead poisoning registry,
provides case management for lead poisoned children and adults, and conducts educational
outreach activities throughout the state.

1

The most frequently identified lead sources in Arizona are lead-based paint and lead-based paint
contaminated dust and soil. Lead-containing home remedies and imported pottery are important
sources of lead exposure in Arizona. These sources have caused the most severe cases of lead
poisoning documented in the state. According to the state’s lead poisoning registry, very few
cases of elevated blood lead levels in the past 10 years have been attributed to lead-contaminated
drinking water in Arizona.
Lead in Drinking Water
Eliminating lead in drinking water is an important step in reducing a child’s overall exposure to
lead in the environment. The irregular water use patterns of most schools can result in elevated
lead levels in drinking water. Water standing in pipes or in contact with lead-containing
plumbing components overnight, and during weekends and extended breaks may result in
elevated lead levels in the drinking water3.
Lead may enter drinking water from a building’s plumbing system. Lead may be present in
various parts of the plumbing system such as lead solder, brass fixtures, and lead or galvanized
pipes that leach lead into the drinking water present in the plumbing system. The amount of lead
in a plumbing system will depend on the materials from which the system was constructed and
the pH of the water. The age of the building is not relevant when addressing lead concerns
because new plumbing fixtures may leach lead into the drinking water3.
The length of time water is in contact with a lead source is the greatest factor contributing to lead
in drinking water. The longer water remains standing in the plumbing system, the more lead it
can absorb from any lead sources that are present. The lead concentrations may be highest after
the water has remained unused for a length of time, such as overnight, weekends, and extended
breaks. Additional factors, such as water chemistry and temperature, can also affect the rate at
which water absorbs lead3.
Methods
ADHS randomly selected 100 schools to participate in this study. This was done by first
obtaining a list of the 1,080 Arizona elementary schools from the Arizona Department of
Education. Each school was then assigned a number (1-1,080), and this range of numbers was
processed at the website www.random.org to get a randomized list of assigned school numbers.
Schools represented by the first 100 assigned numbers on this list were contacted by mail and
phone to request their participation in the study.
Forty-five schools agreed to participate and were sampled during May to June 2004. Three to
five water samples from water fountains and cafeteria kitchen sinks were collected from each
school. Sampling locations within each school were selected by proximity to high-use areas such
as playgrounds, cafeterias, and kindergarten and 1st grade classrooms.
Samples were collected in 1-liter bottles, preserved with nitric acid and submitted to the Arizona
State Health Services Laboratory for lead analysis by EPA Reference Method 200.9.
EPA protocol for sampling drinking water in schools recommends obtaining a first-draw water
sample. ADHS did not use this approach because personnel were not available to collect first-

2

draw samples at some of the rural schools. The schools with drinking water samples that had
lead results greater than the laboratory method reporting limit (MRL) will receive confirmatory
sampling in the fall of 2004.
Results
ADHS collected 191 drinking water samples from 45 schools throughout Arizona. Three schools
located in rural Arizona had lead values that exceeded the laboratory’s method reporting limit
(Table 1). Each of these schools is supplied by a public drinking water system that meets federal
and state drinking water standards and guidance levels. Lead was not detected in drinking water
samples from the other 42 schools. A summary of the results for all 45 schools is provided in
Appendix A.
Table 1. Drinking Water Results above the Laboratory Method Reporting Limit for Lead.
School

County

1

Apache

Year
Built
2004

1
1
19

Apache
Apache
Navajo

2004
2004
1977

37
37

Cochise
Cochise

1980
1980

1

Sample Location
Cafeteria Kitchen Cold Tap
Inside Water Fountain
Inside Water Fountain
Water Fountain
Kindergarten Room
Hallway Water Fountain
Outside Water Fountain

Result
(mg/l)
0.018

Exceeds .015
mg/L1,2
Yes

Exceeds 0.020
mg/L3
No

0.012
0.021
0.013

No
Yes
No

No
Yes
No

0.005
0.005

No
No

No
No

mg/L = milligrams per liter
USEPA action level for lead in drinking water
3
USEPA action level for 250 mL first-draw samples from water fountains and outlets in schools. This
type of sample is used to pinpoint specific fountains and outlets that require remediation (typically water
cooler replacement). The two lead action levels differ because of the problems they seek to detect and the
sampling protocols used. Appendix B provides additional information on the EPA action levels. The
ADHS used the .015 mg/L action level to define which schools would require confirmatory testing.
2

Discussion
School #1
This school is located in Apache County, Arizona and will have an enrollment of 35 students in
pre-kindergarten through fifth grade in the fall of 2004. This school was constructed in 2004 and
replaces the original school built in 1932. Results for the two water fountains located in the 2004
buildings were 0.012 and 0.021 milligrams per liter. The water sample from the cafeteria kitchen
faucet contained 0.018 milligrams lead per liter. These samples were taken after the school
construction was completed and the water had not been in use. The school administrator has
turned off the water fountains in the school until further testing can be done. The school was
advised to flush plumbing lines after periods of non-use before using the water. Confirmatory
sampling has been done at the school and laboratory results should be available by October 2004.
School #19
This school is located in Navajo County, in northern Arizona. It was built in 1973 and expanded
in 2003. The enrollment is 356 students from kindergarten to eighth grade. The water sample
collected from the drinking fountain in the kindergarten room contained 0.013 milligrams lead
per liter, which is below the USEPA action level for drinking water.
3

School #37
This school is located in Cochise County, in southeastern Arizona. Enrollment is 498 in grades
kindergarten through 5th grade, plus 2 preschool programs. The school was constructed in 1980.
Two water fountains, one in the hallway by the kindergarten rooms and one at an outside
playground, tested positive for low levels lead at 0.005 milligrams per liter.
Age of schools
The ages of the three schools with detectable levels of lead in drinking water ranged from new
construction to 31years. School #1 is a new construction that was not occupied until August
2004. School #37 was built in 1980. School # 19 was built in 1973 and was expanded in 2003.
In Pennsylvania, a review of drinking water test results from 300 schools indicated that there was
no correlation between the age of the school building and the number of water fountains or water
outlets with elevated lead concentrations. The age of a building may not necessarily indicate the
age of the plumbing when repairs and renovations are considered1.
Information regarding the history of plumbing repairs in these three schools is not known at this
time. It is unknown if the age of the building or past plumbing repairs contributed to the
detectable lead levels in the drinking water.
IEBUK Model
The Integrated Exposure Uptake Biokinetic (IEUBK) Model for lead in children is used to
predict the risk of elevated blood lead levels in children under the age of seven that are exposed
to environmental lead from many sources. The model combines estimates of lead intake from air,
water, soil, dust, diet, and paint with an absorption module for the uptake of lead from the lungs
and gastrointestinal tract, and a biokinetic model of lead distribution and elimination from a
child’s body. The model predicts plausible distributions of blood lead levels in children from 6
months to 7 years of age.
Standard default values were used for air, soil, dust, diet, and paint exposures based on national
data supplied by the model. The highest water sample result of 0.021 mg/L from School #1 was
used for the water exposure concentration. The model estimated that a 60–72 month old child’s
blood lead level would be 2.4 ug/dL. This is based on conservatively assuming that a child’s
entire daily intake of water would be from this fountain. This estimated blood lead level is well
below the Centers for Disease Control and Prevention guidance level of 10 micrograms per
deciliter of blood for children4. The lead model is provided in Appendix C.
School Education Outreach
ADHS and the Arizona Department of Environmental Quality (ADEQ) have established an
interagency Children’s Environmental Health Workgroup to enhance cooperation and
collaboration between the agencies and expand the exchange of information on issues affecting
children’s environmental health4.
Through this project, ADEQ is developing a curriculum module for schools. This module will
provide education about lead in drinking water to both students and administrators. The module
will actively engage children in conducting drinking water investigations at their schools. The

4

ADEQ will also provide practical ways administrators and other school personnel can reduce
potential risks to children by following U.S. Environmental Protection Agency recommendations
to reduce lead levels in drinking water5. The recommendations are provided in Appendix D.
Child Health Concerns
According to the Centers for Disease Control and Prevention, many children with lead poisoning
have no symptoms; others have only nonspecific symptoms such as headache, stomachache, or
irritability. At high levels, lead poisoning can result in stupor, coma, kidney damage, or severe
brain damage.
Medical research shows lead to be a toxic metal that can be harmful to human health even at low
exposure levels. Young children, infants, and fetuses are particularly vulnerable to lead because
the physical and behavioral effects of lead occur at lower exposure levels in children than in
adults. Overexposure to lead can permanently impair a child’s mental and physical development.
Low levels of exposure have been linked to damage to the central and peripheral nervous system,
learning disabilities, shorter stature, impaired hearing, and impaired formation and function of
red blood cells.
The degree of harm depends upon the total exposure to lead from all sources. In recent years,
government initiatives such as federal controls on lead in gasoline have significantly reduced our
overall exposure to lead. However children are still exposed to lead from a number of sources
including air, soil, dust, food, and water. Lead in drinking water can be a significant contributor
to overall exposure to lead6.
Conclusion
ADHS found no apparent public health hazard in the 45 Arizona schools that were sampled
for lead in drinking water. The three schools that showed detectable amounts of lead in the
drinking have removed the drinking fountains that were sampled from use. Some of the
confirmatory water sampling from these points of service has been conducted and the laboratory
results are pending at this time. Other locations in these schools will also be sampled. An
additional 35 schools will be tested in the fall of 2004 based on available funding and staff
resources. ADEQ will provide Arizona elementary schools with educational materials about lead
in drinking water.
Recommendations
ADHS recommends that Arizona schools follow USEPA’s Recommendations for Drinking
Water in schools (Appendix D).
Public Health Action Plan
ADHS will review follow-up sampling results, and results from any additional Arizona schools
that are sampled for lead in drinking water.
ADHS will work with the ADEQ and the Arizona Department of Education to provide an
educational curriculum for lead in drinking water to Arizona schools.

5

ADHS will make Appendix of this document and any education curriculum that is developed
available on the ADHS web site.
ADHS and ADEQ will use the interagency Children’s Environmental Health Workgroup to
enhance cooperation and collaboration between the agencies and expand the exchange of
information on issues affecting children’s environmental health.
References
1
U.S. Environmental Protection Agency. Letter from Benjamin H. Grumbles. Acting Assistant
Administrator. Washington D.C. March 18, 2004.
2

Internet access: http://www.azsba.org/factoids.htm Last accessed August 11,2004.

3

Washington State Department of Health. Fact Sheet: Lead in School Drinking Water. March
2004. DOH Pub331-255)

4

Internet access: http://epa.gov/superfund/programs/lead/ieubk.htm. Last accessed 8/13/2004.

5

Internet access: ttp://www.azdeq.gov/function/news/2004/jan.html#011. Last accessed on
8/16/2004.
6

U.S. Environmental Protection Agency. Lead in School Drinking Water. EPA 5709-89-001.
1989.
7

Internet access: www.epa.gov/superfund/programs/lead/products/tsd.pdf. Last accessed on
August 10, 2004.
Author
Kristina Schaller
Arizona Department of Health Services

6

CERTIFICATION
The Arizona Department of Health Services, under a cooperative agreement with the Agency for
Toxic Substances and Disease Registry (ATSDR), prepared this lead in schools health
consultation. It was prepared in accordance with approved methodology and procedures existing
at the time.

____________________________________
Allen Robison
Technical Project Officer
Superfund and Program Assessment Branch
Division of Health Assessment and Consultation

The Division of Health Assessment and Consultation has reviewed this health consultation and
concurs with its findings.

_________________________________
Bobbi Erlwein
Team Leader, Cooperative Agreement Team
Superfund and Program Assessment Branch
Division of Health Assessment and Consultation
ATSDR

7

Appendix A
School Drinking Water Sampling Results
School 1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

County
Apache
Apache
Maricopa
Mohave
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Yavapai
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Navajo
Maricopa
Navajo
Navajo
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa

City

Year Built
2004
1932/1973
2004
1991
2001
1958-1995
1962
2000
1982-1986
1985
1954
1989
2002
1988
1995
1992
1980-1998
1980
1973-2003
1960-1995
1988
2000
1988
1986
1960-1994
1985
1953-2000
1991

Alpine
Alpine
Arlington
Bullhead City
Phoenix
Phoenix
Phoenix
Cave Creek
Chandler
Clarkdale
Phoenix
Surprise
Phoenix
Gilbert
Gilbert
Glendale
Overgaard
Phoenix
Joseph City
Kayenta
Phoenix
Litchfield Park
Phoenix
Mesa
Mesa
Mesa
Phoenix
Wittman

8

Enrollment
in
2003
35
35
186
450
932
663
1014
675
737
358
1135
953
691
619
861
919
156
1079
356
387
623
705
791
724
904
730
924
556

No. of
Samples

Results
(mg/L)

4
2
4
4
4
5
4
5
4
5
5
4
5
4
4
5
4
4
4
4
5
4
5
4
4
5
4
5

ND – 0.021
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND-0.013
ND
ND
ND
ND
ND
ND
ND
ND
ND

Exceeds EPA
Action Level
0.015 mg/L?
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No

29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44

Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Navajo
Cochise
Pima
Maricopa
Maricopa
Pima
Pima
Pima
Yuma

Wittman
Phoenix
Peoria
Peoria
Phoenix
Phoenix
Scottsdale
Show Low
Sierra Vista
Tucson
Tolleson
Tolleson
Tucson
Tucson
Tucson
Yuma

1990-1994
1985
1980
2000
1970-1981
1981
1987
1983-1999
1980
1960-1977
2002
2002
1962-1987
1968-1980
2001
1993

Enrollment
in
2003
436
774
755
1395
576
657
674
201
498
585
500
696
521
554
600
954

45

Yuma

Yuma

1956-1993

689

School 1

1

City

County

Year Built

School names are not provided. Schools agreed to participate based on anonymity.

9

No. of
Samples

Results
(mg/L)

4
4
4
5
5
5
5
3
4
4
3
5
3
5
4
4

ND
ND
ND
ND
ND
ND
ND
ND
ND-0.005
ND
ND
ND
ND
ND
ND
ND

Exceeds EPA
Action Level
0.015 mg/L?
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No

4

ND

No

Appendix B
Action Levels for Lead in School Drinking Water.
In January1989, the EPA published a manual “Lead in Schools Drinking Water” which was
updated in 1994 to assist school officials in identifying whether a school had a problem with lead
in drinking water, the steps to reduce or eliminate this problem, and information on training
personnel in sampling and remedial programs. As a part of this program, EPA recommended that
schools collect 250 ml first-draw samples from water fountains and outlets and that the water
fountains and/or outlets be taken out of service if the lead level exceeded 0.020 mg/L. The
sample was designed to pinpoint specific fountains and outlets that required remediation (water
cooler replacement).
The final rule establishes a lead action level of 0.015 mg/L at the 90th percentile. The action level
in the final rule is based on 1 liter first-draw samples collected from numerous targeted sampling
sites throughout a distributions system and is designed to identify system-wide problems and not
problems in single outlets. This is quite different from the sampling conducted in schools where
EPA is concerned with locating individual outlets that require remediation. The school sampling
protocol maximizes the likelihood that the highest concentrations of lead are found because the
first 250ml sample are analyzed for lead after overnight stagnation (usually much longer than the
6 hour minimum specified for this regulation. Consequently, the two lead action levels differ
because of the different problems they seek to detect and the different monitoring protocols used
in the two situations7.

11

Appendix C
LEAD MODEL FOR WINDOWS Version 1.0
==============================================================================
====
Model Version: 1.0 Build 261
User Name:
Date:
Site Name:
Operable Unit:
Run Mode: Research
The time step used in this model run: 6 - Every 30 Minutes (48 times a
day).
****** Air ******
Indoor Air Pb Concentration: 30.000 percent of outdoor.
Age
Time
Ventilation
Lung
Outdoor Air
Outdoors
Rate
Absorption
Pb Conc
(hours)
(m^3/day)
(%)
(ug Pb/m^3)
---------------------------------------------------------------------.5-1
1.000
2.000
32.000
0.100
1-2
2.000
3.000
32.000
0.100
2-3
3.000
5.000
32.000
0.100
3-4
4.000
5.000
32.000
0.100
4-5
4.000
5.000
32.000
0.100
5-6
4.000
7.000
32.000
0.100
6-7
4.000
7.000
32.000
0.100
****** Diet ******
Age
Diet Intake(ug/day)
----------------------------------.5-1
5.530
1-2
5.780
2-3
6.490
3-4
6.240
4-5
6.010
5-6
6.340
6-7
7.000
****** Drinking Water ******
Water Consumption:
Age
Water (L/day)
----------------------------------.5-1
0.200
1-2
0.500
2-3
0.520
3-4
0.530
4-5
0.550
5-6
0.580
6-7
0.590
Drinking Water Concentration: 0.021 ug Pb/L
****** Soil & Dust ******
Multiple Source Analysis Used
Average multiple source concentration: 150.000 ug/g

12

Mass fraction of outdoor soil to indoor dust conversion factor: 0.700
Outdoor airborne lead to indoor household dust lead concentration:
100.000
Use alternate indoor dust Pb sources? No
Age
Soil (ug Pb/g)
House Dust (ug Pb/g)
-------------------------------------------------------.5-1
200.000
150.000
1-2
200.000
150.000
2-3
200.000
150.000
3-4
200.000
150.000
4-5
200.000
150.000
5-6
200.000
150.000
6-7
200.000
150.000
****** Alternate Intake ******
Age
Alternate (ug Pb/day)
----------------------------------.5-1
0.000
1-2
0.000
2-3
0.000
3-4
0.000
4-5
0.000
5-6
0.000
6-7
0.000
****** Maternal Contribution: Infant Model ******
Maternal Blood Concentration: 2.500 ug Pb/dL
*****************************************
CALCULATED BLOOD LEAD AND LEAD UPTAKES:
*****************************************
Year

Air
(ug/day)

Diet
(ug/day)

Alternate
(ug/day)

Water

(ug/day)
-----------------------------------------------------------------------------.5-1
0.021
2.563
0.000
0.002
1-2
0.034
2.667
0.000
0.005
2-3
0.062
3.022
0.000
0.005
3-4
0.067
2.937
0.000
0.005
4-5
0.067
2.879
0.000
0.006
5-6
0.093
3.056
0.000
0.006
6-7
0.093
3.383
0.000
0.006
Year

Soil+Dust
Total
Blood
(ug/day)
(ug/day)
(ug/dL)
--------------------------------------------------------------.5-1
4.077
6.663
3.6
1-2
6.448
9.154
3.8
2-3
6.506
9.596
3.6
3-4
6.576
9.584
3.4
4-5
4.958
7.909
2.8
5-6
4.490
7.645
2.4
6-7
4.252
7.734
2.2

13

Appendix D
Lead in School Drinking Water
U.S. Environmental Protection Agency. Lead in School Drinking Water. EPA 5709-89-001.
1989. Available online: www.epa.gov.
From : Lead in School Drinking Water
Schools should follow these recommendations to reduce any lead contamination in drinking
water:
1. Use only cold water for the preparation of food and beverages in school cafeterias and
cooking classes. Hot water dissolves lead more quickly than cold water and is likely to
contain higher levels of lead. If hot water is needed, it should be drawn from the cold-water
tap and heated on a stove.
2. Purchase bottled water if school drinking water exceeds the EPA action levels. Bottled water
sold in interstate commerce is regulated by the U.S. Food and Drug Administration. Water
that is bottled and sold within a state is under state regulation. The U.S. EPA recommends
that schools require a written statement from the bottled water distributor guaranteeing that
lead levels in the water do not exceed 5 ppb.
3. Do not use water that has been in contact with your school’s plumbing for more than 6 hours,
such as overnight, or after weekends or vacations. Have the water system flushed by the
school maintenance personnel. Before school begins, flush those outlets where test results
indicated lead levels over 0.020 mg/L. If the test results show widespread contamination
within your building, flushing the interior plumbing may also be necessary.

14