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Summary of GSA Testing Scope of Work

The GSA testing scope of work outlines the necessary water testing for facilities leased to government agencies, focusing on ensuring the safety of tenants and visitors. This includes testing for Legionella, lead, copper, total coliforms (including E. coli), and other waterborne pathogens across a representative number of outlets throughout the facility. The testing process requires adherence to federal, state, and local guidelines, as well as specific protocols for sampling and laboratory analysis. Compliance with these protocols is essential to avoid resampling and additional costs. Furthermore, test results must be reported promptly, with follow-up measures and corrective actions taken if necessary.

Benefit of Utilizing U.S. Water’s Legionella Management Team

The U.S. Water Legionella Management Team offers comprehensive services to help landlords comply with GSA requirements and ensure the safety of their water systems. As specialists in waterborne pathogens, the team provides expert guidance through every stage of the process—from assessing the facility and creating a testing plan to executing precise sampling and performing laboratory analysis. The team ensures full compliance with all regulatory standards, provides detailed reports, and recommends any necessary corrective actions. By entrusting these responsibilities to U.S. Water, landlords can maintain a safe and compliant environment while avoiding potential disruptions and additional costs. U.S. Water’s experienced professionals offer peace of mind and confidence in meeting GSA standards.

Scope of Work

Water testing must be performed in GSA leased space and all common areas to which the GSA tenants and its visitors have access and would reasonably expect to use.

Testing for the presence of legionella is necessary for a representative number of outlets in both the hot and cold-water systems. Legionella sampling locations must include:

      1. If applicable, building common and tenant showers – at least 1 sample for every 3 fixtures.
      2. If applicable, all point-of-use outlets that are primarily designed for human consumption in a Childcare Center. Test the hot water side when available or the cold water when there is no hot water.
      3. If applicable, all point-of-use outlets that are primarily designed for human consumption or treatment of patients in a Health Unit. Test the hot water side when available or the cold water when there is no hot water. In addition to the Legionella-only testing above, testing for Legionella, as well as lead, copper, and total coliform. [including Escherichia coli (E. coli)] is mandatory for a representative sample, comprising a minimum of 10% of water outlets throughout the leased space and common areas as described above that are primarily designed for human consumption, such as drinking fountains, bottle fillers, and kitchenettes. In smaller facilities, where this calculates to less than five outlets, a minimum of five outlets shall be tested. It’s important to emphasize that bathroom sinks, or similar outlets equipped with automatic mixing valves are not primarily designed for human consumption are exempt from this 10% sampling requirement. When performing the Legionella test on this 10% group, test the hot water side when available or the cold water when there is no hot water. 

For the lead, copper and total coliform test, only use the cold water. Testing must be conducted in accordance with the following requirements:

      1. To commence the assessment, initiate the process by collecting and reviewing information regarding Federal, state, and local requirements specific to the facility’s location that could have an impact on the test. These could include, but not be limited to, the following aspects:

          1. Required qualifications for the person responsible for sampling.
          2. Proper procedures for sample collection.
          3. The type and quantity of samples needed.
          4. Approved analytical methods.
          5. Designated laboratories that meet acceptance criteria.
          6. Mandatory documentation as per the lab, state, and local regulations.
          7. Applicate federal, state, or local thresholds that must be met.

2. Obtain an accurate inventory of outlets before arriving onsite.

          1. As part of this, determine outlets to be sampled and develop a sampling schedule; identify these on floor plans, if available.

3. The lessor and their contractor must determine a way to ensure that all outlets scheduled to be sampled out of use for at least 8 hours, but ideally not longer than 18 hours, before sampling for metals and ensure any access issues are resolved. Some items to consider are:

          1. Do not use mechanical shutoff valves to isolate outlets before sampling.
          2. Do not remove aerators before sampling.
          3. Do not conduct flushing before sampling unless instructed to do so.
          4. Tenant spaces that require tenant authorization to enter or require a representative to accompany the sampling contractor.

4. Arrive onsite following a regular business day (i.e., do not perform sampling on a Monday or after a holiday).

          1. Review the inventory created pursuant to the requirements of step 2. above and ensure it accurately reflects the current outlets in the facility. If changes are noted, update the device inventory on the floor plan to reflect current conditions accurately.
          2. As required above, all sample collection methodologies and protocols must comply with applicable federal, state, and local drinking water requirements.
          3. Document the location, type of outlet, condition, presence and type of any point-of-use filtration device, and the installation date of the filter (if available).
          4. Take a photograph of each outlet sampled and include the barcode of the sampling bottle provided by the lab in the photo.
          5. Clearly mark each outlet on a drawing.

5. Follow all Federal, state, and local procedural requirements for sample preservation, storage, and hold times.

***Failure to properly adhere to applicable requirements will result in resampling by the Lessor at no additional cost to the government.***

Testing Requirements

Lead and Copper Testing

Testing must be conducted in accordance with the following requirements:

      1. Metal parameters must be analyzed at a State-certified laboratory accredited under the National Environmental Laboratory Accreditation Conference (NELAC) program using EPA Method 200.8 or the state-approved equivalent method. Please be aware that state and local requirements might require specific laboratories to be used.
      2. The testing laboratory must be contacted before sampling to receive sample collection materials, information on sampling methodology, paperwork, and transport. The sampling contractor must follow all instructions from the testing laboratory closely, including completing the chain of custody.
      3. Metals must be “first draw” samples after an 8-hour minimum stagnation period and before the use of any drinking water outlet by the occupants. The stagnation period should be ideally no longer than 18 hours.
      4. Sample bottles must be pre-cleaned, laboratory-provided polyethylene bottles or as state and local requirements otherwise mandated.
      5. A single 250 mL sample must be collected or as otherwise mandated by state and local requirements.
      6. Only sample cold water outlets, do not sample hot water outlets or outlets with automatic mixing valves.
      7. Samples must be transported under standard chain-of-custody protocols to the state-certified drinking water laboratory accredited under the NELAC program.
      8. Analyze samples with a standard analytical turnaround of no greater than seven calendar days upon laboratory receipt of the sample.
      9. Assess the analytical results by comparing them to the relevant state and local regulations. In cases where such regulations are acceptable, apply the thresholds set by the EPA National Primary Drinking Water Standards to determine compliance.

Total Coliform including E. Coli Testing

The Lessor must ensure the sampling contractor adheres to the following requirements:

      1. Total coliform and E. Coli samples must be collected and analyzed using an EPA method for coliform approved under the Revised Total Coliform Rule (such as EPA Standard Method 9223 B-1997, 9221, or 9222) or the state-approved equivalent method and must be analyzed at a State-certified laboratory.
      2. The testing laboratory must be contacted before sampling to receive sample collection materials, information on sampling methodology, paperwork, and transport. The sampling contractor must follow all instructions from the testing laboratory closely, including completing the chain of custody.
      3. The exterior of the fixture or sample must be disinfected before sample collection to prevent sampling contamination.
      4. The standard sample volume required for total coliform analysis, regardless of the analytical method used, is 100 ml.
      5. It is only required to determine the presence or absence of total coliforms; a determination of total coliform density is not required.
      6. Evaluate analytical results against EPA National Primary Drinking Water Standard thresholds, determining threshold conformance. A positive result shall be considered an exceedance.

Legionella Testing

Testing must be conducted in accordance with the following requirements:

      1. Legionella must be analyzed at a laboratory accredited for Legionella analysis according to the international laboratory quality standard ISO 17025:2017 by an accreditation body that is itself accredited according to ISO 17011:2017 (such as AIHA LAP), approved by the CDC Environmental Legionella Isolation Techniques Evaluation program, or as required by specific state requirements (such as the New York State Environmental Laboratory Approval Program for New York State).
      2. Analyze all water sampling using the traditional spread-plate Legionella culture method (based on ISO 11731:2017 and/or the U.S. CDC methods published in 2005). PCR sampling will not be accepted for this effort. Reporting of Legionella concentration in colony-forming units per milliliter (CFU/mL) and the identification of the basic types of species present (e.g., Legionella pneumonia serogroup 1, Non-LP1 Legionella pneumonia, non-Legionella pneumonia) is required.
      3. The testing laboratory must be contacted before sampling to receive sample collection materials, information on sampling methodology, paperwork, and transport. The sampling contractor must follow all instructions from the testing laboratory closely, including completing the chain of custody.
      4. A single 250 mL sample must be collected or as otherwise mandated by state and local requirements (such as 1.0 L).
      5. Analyze samples with a standard analytical turnaround of no greater than fourteen days upon laboratory receipt of the sample.
      6. Evaluate analytical results according to the CDC resource for Routine Testing of Legionella, specifically Figure 1. Routine Legionella testing: A multifactorial approach to performance indicator interpretation, or state requirements, whichever is more stringent.

Deliverables

Water quality issues require a timely response. For this reason, the Lessor’s sampling contractor must report all sampling results that exceed applicable federal, state, or local thresholds back to the Lessor within 24 hours of receipt from the laboratory, highlighting threshold exceedances and/or other concerns. The Lessor must then immediately notify the GSA Lease Administration Manager concerning the results. In addition, the sampling contractor will provide a written report as soon as all investigative and sampling information is available following the completion of the investigative work. This report or portions of this report may be released to the public. Include the following, at a minimum:

1. Executive summary.

          1. Brief description of the facility and water system
          2. Name of the person who performed the investigation.
          3. Summary of the investigative work performed.
          4. Summary of any findings, including test results, compared to CDC resources & EPA or applicable state or local thresholds.
          5. Table of all test results highlighting any results above CDC resources & EPA or applicable state or local thresholds.

2. Background information.

3. Investigation.

          1. Name of the person who performed the investigation and qualifications including type of firm, years of experience in potable water sampling, and applicable certifications.
          2. Description of the outlets sampled, along with pertinent details about each outlet.
          3. Description of CDC resources, EPA, or applicable state or local thresholds
          4. Results of the sampling
          5. Recommended corrective actions, if applicable

4. Conclusions.

5. Signature of the sampler, supervisor, and applicable CIH, or the ASSE 12080 certified individual.

6. Report Attachments.

          1. Updated inventory of outlets
          2. Complete laboratory analytical data packages with chain-of-custody documentation, copies of relevant laboratory accreditation/certification, and laboratory quality control package
          3. Field sample forms, daily logs, and all other field paperwork
          4. One figure per building floor depicting each drinking water sample location and analytical result.
          5. Photographic record of each outlet sampled including the barcode of the sampling bottle provided by the lab in the photo.
          6. Any additional state and local documentation requirements ensure minimum disruption to agency mission activities.