TO: RSD Parents and Guardians
FROM: Antony A. L. McLetchie, Superintendent/CEO
RE: Lead Testing of Water Fixtures at RSD
DATE: September 22, 2016

In light of concerns regarding the possibility of elevated levels of lead in drinking water in schools across the nation, the leadership team at Rochester School for the Deaf (RSD) decided to voluntarily test lead levels in drinking water and other outlets in RSD buildings starting this past May.  Testing is ongoing and an environmental testing firm was hired to assist us in conducting the tests.  In addition, we retained the services of a certified hygienist to evaluate the test results as they become available and advise us on its options to address outlets containing elevated lead levels. 

The United States Environmental Protection Agency (EPA) and other governmental agencies have published guidance documents to address lead in water concerns, which are technical documents outlining steps that can be taken by schools to address lead in water found in excess of recommended action levels. The preeminent guidance document available for addressing lead in water at schools is the EPA’s so-called “3Ts for Reducing Lead in Drinking Water in Schools” (the 3Ts Guidance), which identifies action levels at which school officials are advised to implement measures to address elevated levels.  According to the 3Ts Guidance, the corrective action level for addressing lead in water for schools receiving water from a public water system is 20 parts per billion (ppb). 

Based on the new law and regulations that became effective on September 6, 2016, the New York State Legislature amended the New York Public Health Law to include section 1110 and the New York State Department of Health (DOH) also issued emergency regulations in conjunction with the new law requiring all public schools and board of cooperative educational services to conduct testing of school water for lead, report the results, and implement a remediation plan in accordance with the 3Ts Guidance.  This is the first law requiring lead in water available at schools be tested.  The new law and regulations apply only to public schools, and unlike the EPA’s recommended action level of 20 ppb, the DOH has adopted a more stringent action level of 15 ppb.  Please be assured that the health and welfare of RSD’s students, faculty, staff, and volunteers is our first priority and for that reason, we are also adhering to the requirements of the new law and regulations, even though on their face they may not apply to RSD, by using the corrective action level recommended by the DOH’s emergency regulations of 15 ppb. 

As indicated, RSD has and is undertaking the testing of water outlets at RSD buildings, including drinking water fountains as well as other outlets.  Final information concerning the completed testing will be available on the homepage of the RSD website and the testing results are available to review in the RSD Administrative Office.  Approximately 26% of the tested outlets have been identified above the DOH action level.  The number of outlets identified above the action level is considered typical for facilities with older infrastructure.  RSD is addressing lead in the outlets found to be above DOH’s corrective action level for schools, in the following ways (in accordance with the 3Ts Guidance and the newly enacted Department of Health regulations which incorporate such 3T’s Guidance’s recommended mitigation measures): Replacement of plumbing fixtures or other piping/equipment; and/or, Institution of a morning flushing program. 

In the meantime, where preliminary information indicates it is prudent to do so, temporary measures have been implemented to be as protective as possible.  You may have heard about or seen the implementation of such temporary measures in the form of placards advising students and staff not to use particular outlets.

As parents and guardians of RSD students, I know you may have questions about the testing process and what all of this means.  We have provided answers to some frequently asked questions together with this letter.  If you have additional questions, please email them to the Director of Facilities, Mike Kaiser at  We will continue to update you on the progress of our testing and remediation efforts.  Rochester School for the Deaf is committed to ensuring that the water available to our students and staff meets applicable guidelines.  We thank you for your support as we continue to safeguard our students and staff.


Antony A.L. McLetchie

How does lead get into drinking water?

Lead can get into drinking water in two ways: by being present in the water source, due to contaminated runoff or from water pollution; or through an interaction between water and plumbing materials/fixtures or piping containing lead, including from corrosion.  RSD receives its water from the Monroe County Water Authority.

Why test school drinking water for lead and what is meant by a corrective action Level?

In significant quantities, lead can cause developmental delays in children. According to the United States Environmental Protection Agency, homes and buildings built before 1986 are more likely to have lead at heightened levels in their drinking water.  Prior to the enactment in the last few weeks of New York’s law requiring water available in schools be tested for lead, there was no requirement that they do so.  However, even prior to the enactment of the law requiring lead in school water be tested, out of an abundance of caution, RSD opted to voluntarily test water outlets at its facilities for lead.  The EPA’s 3Ts Guidance on drinking water describes the testing protocol and recommends potential measures to address the presence of lead in water when testing shows levels of 20 parts per billion or above.  On the other hand, the new law and regulations issued by the New York State Department of Health that apply to public schools prescribe a lower action level of 15 parts per billion compared to the 20 ppb action level recommended by EPA in the 3Ts Guidance.

Although the new regulations rely on the 3Ts Guidance and state that the 3Ts Guidance should be used as a technical reference for conducting testing and implementing remediation measures, it is unclear why the New York State Department of Health adopted a lower action level than the one provided for in the 3Ts Guidance.

RSD is proceeding with testing and the adoption of any measures needed to address exceedances by using the lower action level described in the new law and regulations of 15 parts per billion.  Once final results are available and reports are complete for the RSD testing, outlets found to contain lead at or above 15 parts per billion will be addressed with long term or permanent measures.  In the meantime, when preliminary information has indicated lead levels are 15 ppb or above, outlets have been taken off-line.

Can you explain how the tests were conducted?

RSD worked with a local environmental consulting firm to take samples in the manner recommended by the EPA’s 3Ts Guidance and a laboratory was retained to have the samples analyzed and produce the results of such sampling for review.

What are the next steps?

RSD will provide information on the test results and continue with its remediation plan to address water sources testing above 15 parts per billion, with such plan to potentially include flushing fixtures, replacing fixtures or other measures as recommended by applicable guidance and as may be recommended by the hygienist that is working with RSD on this matter (as indicated, in the interim, some outlets may be taken off-line).

Who should I contact if I need more information?

If you have additional questions, please email them to our Director of Facilities Mike Kaiser at


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