Lead Sampling in NJ Schools - Effect over Cause

Lead Sampling in School Facilities

After attending a recent training on Lead Sampling in School Facilities provided by the NJ Department of Education, I am left as many are wondering if we are not taking a 'backwards' approach to the process given the amount of front end work expected before we even no if a problem exists.  While sampling makes sense and should be done at every building where students have access to drinking water - the process as outlined by the state remains questionable while it seems like we are doing a considerable amount of work, investigation, plan development and surveying for something that may NOT even be a problem.


In a letter released from the State DOE Division of Field Services, the regulations require testing for lead in all drinking water outlets within 365 days of the effective date of the regulations, which was July 13, 2016. According to the EPA, If lead concentrations exceed an action level of 15 ppb it is considered to be actionable or "Action Stage."

Many districts in the state have already tested in the wake of Flint, Michigan and reported lead problems in Newark prior to the regulations and found their results to be far below the standard with many drinking stations reporting <1ppb. As such common sense would say these districts should not be required to spend additional time, money and resources on further investigation of a problem that is non-existent in those districts.
The measures called for by the state in development of the plan and protocols call for continued outlay of funds to cover measures such as: Sampling, Certified Lab Analysis and assistance from consultants in order to complete the process and carry out the measures.
Even if in-house staff are used to comply with the measures you still loose significant time on task, therefore reallocating manpower from other critical mission tasks that require the same level of attention and focus. Consider every dollar allocated to this effort is a dollar not available for the classroom or other district needs - "Opportunity Costs."

We should be applying the principle of Cause and Effect - Concerning ourselves with why things happen (causes) and what happens as a result (effect).  If results from sampling produce levels near or above action stage (15ppb) [cause] then most definitely implement the required Quality Assurance Project Plan (QAAP) [effect]; however, to do so without knowing the results seems to be counter productive and unnecessary not to mention a waste of valuable funds that are most definitely needed elsewhere.