EPA’s 3Ts Program: Lead Testing for Schools and Daycares
If you run a school or child care facility and
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If you run a school or child care facility and go looking for guidance on checking water for lead, you will probably land on the EPA’s 3Ts program. The 3Ts lead-in-drinking-water guidance is voluntary, and it organizes the work into Training, Testing and Taking Action.
ETR Laboratories is a water testing lab in Leominster, Massachusetts, and we want you to know that school sampling follows a different protocol than a home test. It uses 250 mL samples, a set stagnation window and a separate sample from each outlet.
In this article, we explain what the program is, whether it is required, how sampling works and how to choose a lab.
The 3Ts program is the EPA’s toolkit for reducing lead in drinking water at pre-K to 12 schools and child care facilities. Its full title is 3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities: A Training, Testing, and Taking Action Approach.
The current manual is a 2018 revision of the 2006 version, which the EPA’s 3Ts page organizes into seven modules. Here are the modules:
Next, how much of this you must follow.
No. The EPA presents the program as voluntary suggestions, and many schools and child care facilities are not regulated under the Safe Drinking Water Act because they buy water from a public water system. The manual itself says its recommendations are suggestions only and not requirements.
That is why EPA lead-testing requirements for schools vary by location, and the 3Ts lead-in-drinking-water guidance sits beside them. The EPA guidance is voluntary, state and local rules may be stricter, and the 2024 lead rule puts sampling duties on water utilities instead of schools.
A school that runs its own well counts as a public water system and is regulated. The 1988 Lead Contamination Control Act focused on water coolers and did not create a national testing mandate.
With the rules sorted out, the three Ts give you a working order.
The 3Ts run through the seven modules in order, from awareness to testing to fixes.
Training means raising awareness among staff and parents about where lead comes from. Children are most susceptible because their bodies are still developing, and lead typically reaches water from aging lead pipes and plumbing fixtures.
Knowing how to test for lead in school drinking water starts with a sampling plan. Sample the outlets used for drinking and cooking, use a two-step method, and record every result. The comparison below shows how it works.
Taking Action means ranking fixes by sample results, finding the source with a flush sample and replacing problem fixtures. The 2018 manual gives no numeric trigger and tells schools to check with their state and local health departments.
School sampling is a different protocol from a residential test. A home lead test using the first-draw method or a residential first-draw-and-flush kit follows its own instructions, which should not be copied for a school.
| Feature | Home first-draw test | School 3Ts sampling |
| Sample size | Set by the kit | 250 mL per sample |
| Stagnation time | About 6 hours or more with no use | 8 to 18 hours with no use |
| Timing | After the water has sat unused | Before the facility opens, not after weekends or holidays unless directed |
| Outlets | Usually one tap | Every outlet used for drinking or cooking |
| Follow-up | A flushed sample after running the tap for several minutes | A 30-second flush sample if the first draw is high |
The first-draw sample shows what the fixture contributes, and the flush sample shows whether lead comes from the plumbing behind it. If you collect both together, the lab can hold the second sample and analyze it only when the first result is high.
Choosing the right outlets comes next.
Test the outlets people use to drink, cook or prepare food and beverages. The EPA strongly recommends first-draw sampling at all of them, starting with the highest-risk ones, such as these:
Lead can sit in one fixture or one section of pipe, so one result should never represent the whole building. Prioritize outlets used by children under 6 and by pregnant staff. Small child care buildings are also more likely to have lead service lines, so your plan should include checking service line material.
After sampling, you will need to know what the numbers mean.
The 2018 3Ts manual sets no numeric trigger, and the EPA says there is no safe level of lead for children. Schools are told to reduce lead to the lowest possible level and follow any trigger set by their state or local health department.
The numbers you will see come from different sources and serve different purposes:
| Level | What it means |
| 0 ppb | The EPA’s health goal for lead in drinking water |
| 15 ppb | The action level for water systems, which is not a health-based standard |
| 5 ppb | A comparison point the manual uses when interpreting follow-up samples, and Minnesota’s remediation level |
The EPA’s lead information lists the 15 ppb action level and the goal of zero, so a result under 15 ppb is not a clean bill of health for a school. Minnesota requires schools and child care centers to remediate at 5 ppb, for example.
Take the affected outlet out of service for drinking and cooking, then work down from the highest results. The EPA recommends planning your response before sampling.
Here are the short-term options the manual describes while a permanent fix is arranged:
Follow-up sampling helps find the source, and cleaning the aerator and retesting can show whether trapped debris was adding lead. After permanent corrections, such as replacing the fixture or the plumbing behind it, follow up with more testing, and apply your state’s remediation threshold where one exists.
Everyone who uses the building should hear the results.
Tell parents and staff what you plan to test, what you found and what you are doing about it. The manual says to share results regardless of the lead level.
Here is what to cover and when:
A separate change is coming for water utilities.
From November 1, 2027, community water systems must begin sampling certain schools and child care facilities under the Lead and Copper Rule Improvements. The EPA’s fact sheet on schools and child care lays out the schedule, though timelines can change, so confirm the current status with your state or utility.
Here is what the fact sheet describes:
A state can waive utility sampling where its own program is at least as stringent. Utilities bear the burden because the EPA lacks authority to require schools that are not public water systems to comply.
Either way, the lab you choose shapes the results.
Choosing a Lab for School or Child Care Sampling
Choose a lab that can supply the right bottles, report in ppb and document the sampling. For school sampling, the EPA manual advises using a certified laboratory approved by the state or EPA for lead in drinking water.
Here are the questions we suggest asking any lab:
The questions to ask before you pay for a water test apply here too, and choosing a panel explains why your panel decides what the lab looks for.
You can ask ETR Laboratories about testing for a school or child care facility, and we will say plainly what we can and cannot supply for a multi-outlet program.
Here are five steps for the first month:
These questions come up often.
The 3Ts program is voluntary and state rules vary, so check your state’s program for the duty that applies to you. Lead testing for daycares may also come through the utility, since from November 2027 the lead rule has utilities sampling child care facilities, 2 samples each, unless a state waives it.
Under the lead rule, utilities take 5 samples per school and 2 per child care facility. The 3Ts recommends sampling every outlet used for drinking and cooking, so a full program is usually larger than that minimum, depending on how many outlets you have.
Responsibility commonly sits with the district, operator or owner, depending on the state. WIIN grants go to states, territories and tribes rather than individual schools, and the EPA fact sheet states no cost to the facility, so do not assume sampling is free.
Ask the district or operator, since the 3Ts recommends sharing results at any lead level, and you can request the latest sampling report. Some states may also post results online, so check your state’s health or education agency.
The EPA strongly recommends first-draw sampling at all outlets used for drinking or cooking, starting with high-risk outlets if you must prioritize. Bathroom and janitor sinks do not automatically belong in the plan unless they supply drinking or food preparation, and one building-wide sample is not enough.
No. The EPA says not to remove aerators before sampling, because lead-containing debris trapped in the screen may be part of what the test should capture. If a result is high, cleaning the aerator and retesting can show whether the screen contributed.
If you are weighing how to test the water in a school or child care facility, ETR Laboratories offers a free consultation, and we are glad to talk through the 3Ts and what a result means.
A home-based family daycare may find our Lead Water Test, listed at $45 with results in 1 to 3 business days, a practical start. Check your state’s rules for licensed home child care first, since a state or local program may set its own protocol.
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