Lead in Water: Updating LBP Risk Assessments and EBLL Environmental Investigations

What Happened

Several risk assessor trainers asked Unleaded Kids for guidance on tap water sampling as part of lead-based paint risk assessments (“LBP risk assessments”), and environmental investigations of children with elevated blood lead levels (“EBLL environmental investigations”). They explained that HUD’s 2012 guidelines may be outdated given EPA’s overhaul to its drinking water Lead and Copper Rule (LCR) in 2021 and 2024. Those guidelines provide essential details for how risk assessors should evaluate lead hazards, especially dust, soil, and paint, and are relied on by health departments managing EBLL cases.

For those not familiar with drinking water programs, the LCR’s changes include requiring drinking water utilities (aka “community water systems”¹) to:

• Make publicly available their service line inventories that identify every service line and whether it is lead, galvanized-requiring replacement (GRR), non-lead, or lead status unknown (“unknown”).
• Replace the vast majority of the nation’s estimated 4 million LSLs by 2037. LSLs are the lead pipes that connect the water main under the street to the building or home and are the primary source of lead in drinking water.
• Meet a more protective lead action level (LAL) of 10 parts per billion (ppb) based on a tap water monitoring program focused on LSL. This change, which goes into effect in November 2027, is anticipated to dramatically increase to almost 33% the number of utilities with LSLs that exceed the LAL.
• Ensure tap water testing in elementary schools and child care facilities (CCFs) is performed over five years starting in November 2027. This testing is an essential element of EPA’s updated 3Ts guidelines for schools and CCFs to reduce lead in drinking water in these settings.
• Increase and improve public education efforts, especially where service lines are LSLs, GRR, or unknown, or when the LAL is exceeded.

Recognizing the significance of EPA’s rule changes, to jumpstart the process, we agreed to provide our recommendations to help those who are interested. We anticipate that HUD will update the guidelines as its limited resources allow.

As explained in detail below, we recommend those conducting LBP risk assessments or EBLL environmental investigations consider four steps. Since none are required under the HUD guidelines, we provide our assessment of which to prioritize if the client is hesitant.

Why it is Important

HUD’s 2012 guidelines use 20 ppb for an action level in LBP risk assessments² and 15 ppb in EBLL environmental investigations.³ The 20 ppb was based on EPA’s 3Ts from 2000. In its 2018 revisions, EPA removed that 3Ts’ level, letting the state or school determine the appropriate level. The 15 ppb was likely based on EPA’s LAL from 1991, which the agency lowered to 10 ppb.

Because there is no safe level of exposure to lead, those levels are expected to result in harm. For context, we used EPA’s All-Ages Lead Model (AALM) to estimate the average blood lead level for a person routinely drinking water at 20 ppb with no other lead sources of lead exposure. Those blood lead levels are:

• 1.2 µg/dL for a child from 0 to 6 years of age. This is associated with an estimated loss of 0.6 IQ points for a cost of $27,600.⁴
• 1.8 µg/dL for an adult from 40 to 80 years of age. This is associated with a 24% to 78% increased risk of premature death due to cardiovascular disease at a societal cost of roughly $9,300 to $30,000 per person.⁵

We these levels are below the CDC’s blood lead action level of 3.5 µg/dL, when other sources are considered, they may result in an EBLL. Note that the levels in the samples may not be representative of what a person drinks on a regular basis because they may flush the lines. However, the sample protocol also does not represent the high levels of lead from LSLs that can happen erratically.

Details on Our Recommendations

Below, we provide detailed guidance to people conducting LBP risk assessments or EBLL environmental investigations. Note that since none are required under the HUD guidelines, we also provide our assessment of which to prioritize if the client is hesitant.

As you consider our guidance, we encourage you to check out the resources at the Lead Service Line Replacement Collaborative and the Environmental Defense Fund’s map of LSL replacement programs.

Step 1: Contact the water utility prior to the site visit to gather important information such as composition of service line.

We recommend this step because it will provide you will useful information to share with the property owner and resident. Note that HUD’s 2012 guidelines encourage reaching out to the utility but not at this level of detail, primarily because much of this information was not available when the guidelines were last updated.

If the address is served by a private well, skip this step.

For each address you plan to visit, check with the utility that provides drinking water to the property. Go to EPA’s website to find utility names and contact information. You can also use EPA’s new service line inventory dashboard, released in November 2025, to get totals for each type of service line for each of almost 50,000 utilities. Unfortunately, EPA does not provide information about each utility’s websites, so search the Internet to find the utility since its website may have much of what you need.

We also encourage you to contact the utility to be sure you are getting the latest information and get educational materials tailored to the utility that you can share with the resident and property owner.

For each utility, you will be looking for the following:

• Consumer Confidence Report (CCR): They are sent annually to each customer by July 1 and are usually available online. For lead, the CCR must include the latest monitoring results for the utility, whether the utility exceeded the LAL, how to access the utility’s service line inventory;⁶ and testing information for schools and licensed CCFs.⁷
• Service Line Inventory: Since October 2024, utilities must make their service line inventory publicly available down to the street address. More than 1,000 utilities that serve more than 50,000 people must make it available online. The inventory must be updated and sent to the state annually and must identify each service line and whether it is lead, GRR, non-lead, or lead status unknown. The utility may separately report the status of the portion of the service line on public property and private property. The latter is more likely to be “lead status unknown.”
• LSL Replacement Program: From 2027 to 2037, utilities must replace 10% of their LSLs each year (unless the state grants an extension). Many have already started replacement programs and may have funding available, especially for low-income residents. And, as public health professionals, they may prioritize any home where an EBLL environmental investigation is being conducted.
• School and CCFs: Beginning in 2027, utilities must collect tap water samples from at least 20% of elementary schools and of CCFs annually. After five years, they can provide sampling on request. The sampling must include 5 samples per school and 2 per CCF at outlets typically used for human consumption and consists of a 250 ml first draw sample after the water has set undisturbed for between 8 and 18 hours. These requirements may vary by state, especially where the state has more stringent requirements.

Step 2: Check service line materials. If LSL or GRR, recommend replacement and use of a NSF/ANSI 53 certified filter to remove lead until non-lead replacement is completed and cleared.

We highly recommend this step because LSLs are the most significant source of lead in drinking water, especially for homes. They are also erratic source of lead so a low sample result one day could be much higher later. Note that HUD’s guidelines only touch on LSLs because their significance was not well understood when the guidelines were last updated.

You should always check the service line as it enters the building to determine what it is made of. Note that the service line material may change as it runs from water main to the building. Because you are only checking it in one place, you cannot be sure whether or not it is a GRR or LSL. The utility (or a plumber) may want to inspect the service line near the curb or property line where there is usually a shut-off valve.

To help you, EPA provides a guide for residents that can be tailored by a utility to its specific situation. NPR also provides a helpful tool. Your utility may have more information or videos. Note that service lines larger than 2 inches in diameter are rarely LSLs. In addition, interior plumbing is also rarely made of lead pipes.

Whatever you learn, share your findings with the utility, even if only to confirm the inventory, so it has the most current information. It is important because EPA requires that utilities have validated their inventory by the end of 2034. Note that some utilities provide an easy way to do that through their online inventory.

If you find the service line is an LSL or GRR, whether through your inspection of the service line or the utility’s inventory, you should recommend the property owner or resident replace the line. The Lead Service Line Replacement Collaborative has an excellent video to explain replacement.

Until the LSL is replaced, the resident or occupant should use a filter to remove lead for all water used for cooking or drinking. The filter helps protect residents from the erratic slugs of lead particulate that are common from LSLs. Only use NSF 53 lead-certified filters so you can be sure the levels in the tap water are below 5 ppb and remind the resident to replace the filters when the filter device shows it is needed or as recommended by manufacturer’s instructions.

Step 3: Collect overnight, first-draw samples from all fixtures consistent with HUD’s current guidance. If a level is over 5 ppb, use an NSF/ANSI 53 certified filter to remove lead and keep using it until one week after the fixture is replaced.

HUD guidelines say water sampling is encouraged. We agree with that recommendation, especially since they can be complicated for residents to collect. And if there is a LSL or GRR, the resident may mistakenly assume the sampling results will represent ongoing exposure rather than a snapshot in time. In addition, with the more extensive tap water monitoring now required for homes, schools and CCFs, tap sampling is less important than in the past. Note that utilities may want you to conduct sampling so support their efforts. In those situations, we recommend that you help them.

When are Samples Needed: We encourage that cold water tap samples be taken from every property unless there is reason to think it is unnecessary such as when there are existing samples (as may occur for schools and CCFs) or the fixture was replaced after 2014 (when Congress/EPA and NSF/ANSI/CAN 61 established tighter lead-leaching standards). The sample is more important for larger buildings with the plumbing system is big enough that the utility’s corrosion control treatment may be less effective and LSLs are less likely because the service line is larger than 2 inches in diameter.

Our recommendation is stronger and more specific than HUD’s 2012 LBP risk assessment guidelines that consider tap water sampling to be optional based on resident’s or owner’s request. HUD took this position “because drinking water hazards are outside the scope of lead-based paint hazards and EPA has another program in this area.”

Our recommendation is similar to HUD’s guidance for an EBLL environmental investigation where the objective is “to identify potential sources of lead” and are not narrowly focused on lead-based paint. HUD calls for tap water sampling “only if: the community drinking water is known to be at risk; the family’s home is served by a private well; history suggests contamination; or no other sources of lead can be found.”

Tap Sampling Protocol: We recommend that every faucet (aka “fixture”) used for drinking or cooking be tested. Don’t forget bathrooms where children may get a drink before bed or in the morning.

For homes with LSLs, GRRs or unknown, we also encourage a 1 L, overnight first liter and fifth liter sample of cold water from the kitchen faucet consistent with EPA’s requirements,⁸ as part of monitoring programs administered by utilities.. The faucet should not be used for between 6 and 18 hours prior to taking a sample and no water should be used in the home (including toilets and showers) for at least six hours.

For larger facilities including multifamily housing, we recommend a 250 mL sample of faucets consistent with EPA’s 3Ts guidance and its 2024 regulations for testing of fixtures in schools and CCFs as well as HUD’s 2012 LBP risk assessment guidance.⁹

Note that the utility may pay the cost as part of their customer service program or their monitoring program. They may provide 1 L bottles for the sampling. While the larger size may not be necessary, it should not be a problem.

Acting on Results: We suggest using 5 ppb as a threshold for action. This level is consistent with Healthy Schools Network’s recommendation and EPA’s practical quantification limit for lead in drinking water. In addition, it is the level that a certified filter must be able to achieve.  

Many labs can provide reliable results much lower than 5 ppb and you may want to use 1 ppb as a threshold.

If levels are more than 5 ppb (or 1 ppb), the fixture appears to have either significant amounts of lead leaching from its brass, its solder connection, or lead particulate that has come from a lead pipe earlier in the system. We suggest replacing the fixture and until that happens using a, NSF/ANSI 53 certified filter. We also suggest continuing to use the filter for at least one week after installation of the new fixture to protect residents from lead leaching of new brass that may be seen.

Step 4: Educate resident and property owner about findings.

We recommend this step because your efforts represent an important opportunity to educate the resident about lead in drinking water.

We encourage you to work with the utility so you have the latest information on their system. Many will share their tailored educational materials that you can provide to the resident and property owner.

Specifically, EPA requires the utility to have written public education materials that address the following steps a consumer can take to reduce exposure:

1. Explain use of a filter.
2. Encourage running water to flush out the lead and that longer times may be needed if the water flows through a LSL or GRR.
3. Explain concerns with using hot water especially for preparing baby formula.
4. Explain that boiling water does not reduce lead levels.
5. Encourage regular cleaning of faucet aerators.
6. Discuss other steps to take especially for pregnant persons, infants, and young children, such as using alternative sources of water.
7. Suggest that parents have their child’s blood tested for lead.
8. How to get water tested.

We want to highlight in particular that people should not use hot water from the tap for drinking and cooking. Lead is more likely to leach into hot water. And if there is a LSL or GRR, the hot water tank may accumulate lead particulate that could be disturbed. For these reasons, tap water testing is only for cold water.

Conclusions

We encourage HUD to update its guidelines as soon as it has the resources and time. The guidelines serve a critical role in helping risk assessors and environmental investigators do their work effectively. As part of the process, HUD should harmonize the different sampling protocols in Chapter 5 for LBP risk assessments and Chapter 16 for EBLL environmental investigations. We hope that our recommendations can help advance that effort. As always, we welcome feedback on these recommendations and acknowledge they can be improved both in clarity and contract. Please email suggestions to tneltner@unleadedkids.org.

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1. The LCR requirements also apply to non-transient, non-community water systems (NTNCWS). There are roughly 50,000 CWSs and 17,000 NTNCWS. See EPA’s webpage for more information. ↩︎
2. Chapter 5, Section V.5 on page 5-80 (page 80 of the PDF). ↩︎
3. Chapter 16, Section III on page 16-13. ↩︎
4. Based on median blood lead level of 0.60 µg/dL based on 2017-2020 NHANES results and value of $46,041 per IQ point using a 9% increase in consumer price index (CPI) from 2022 to 2025. See our blog to learn more. ↩︎
5. Based on median blood lead level of 0.60 µg/dL based on 2017-2018 NHANES results and value of $14.15 million in value of a statistical life using a 9% increase in CPI from 2022 to 2025. See our blog for details. ↩︎
6. This information may not be available until 2028. ↩︎
7. This information may not be available until 2028. ↩︎
8. Sampling sites must be selected from the highest tier available (Tier 1 is the highest tier and Tier 5 is the lowest tier). Tier 1 sampling sites are single-family structures with premise plumbing made of lead and/or served by a lead service line. Tier 2 sampling sites are buildings, including multiple-family residences, with premise plumbing made of lead and/or served by a lead service line. ↩︎
9. HUD’s EBLL Environmental Investigation guidance recommends a 1 L sample. Given the purposes, a smaller sample is more appropriate, unless the utility requests a larger sample or will conduct the analysis for you. ↩︎