Letter to Robin Carnahan, Administrator of the General Services Administration, Nina Albert, Commissioner of the Public Buildings Services - Cardin, Cramer Call for More Complete Water Testing at Child Care Centers in Federal Buildings

Letter

Dear Administrator Carnahan and Commissioner Albert:

Thank you for your service to civilian federal employees through the provision of their workspace. The indoor environment affects productivity and well-being. Exposure to lead--like that found in contaminated water--can result in significant health problems. Children are particularly at risk because their growing bodies absorb more lead than adults'. Therefore, we urge you to strengthen the assessment of water quality in GSA-controlled child care facilities.

On September 6, 2022, the Assistant Inspector General for Auditing sent an alert memorandum raising concern over a finding "[d]uring the survey phase of [the] Audit of GSA's Response to the Coronavirus Disease 2019 (COVID-19): Assessment of Water Quality in GSA Controlled Facilities thatthe Public Building Service (PBS) did not effectively test for water contamination prior to reopening GSA child care centers that were closed during the pandemic." The alert memorandum also found that, prior to the pandemic-related closures, PBS had not been testing the water in 57 of its 92 child care centers for lead and copper at least once every three years, as required by GSA Order PBS 1000.7.

GSA provides space in its facilities for 92 child care centers across the country that provided daily care for more than 7,000 children prior to the COVID-19 pandemic. Eighty-four of the child care centers closed temporarily, causing "water stagnation in [child care centers'] plumbing system due to decreased water use." When water becomes stagnant in plumbing systems, the risk of corrosion increases, possibly allowing for "the release of lead and copper into the [child care center's] drinking water." Per the EPA, no level of lead in a child's bloodstream is safe, as "even low levels of lead in children can cause behavioral and learning problems, reduced intelligence and hyperactivity, impaired growth, hearing loss, and anemia." Much like lead, excess copper in a child's bloodstream "can cause vomiting, nausea, abdominal pain, and diarrhea." Despite the risks, 71 of the 74 child care centers that have reopened did so without conducting water tests.

We are deeply concerned by the latest information indicating that the PBS has since tested water in only 38 of the 71 child care centers that were previously untested. Clearly testing is warranted: three child care centers at the Richard Bolling Federal Building in Missouri, Union Park Plaza in Colorado, and IRS Service Center in Utah were found to have elevated levels of lead, copper, or both. This means 33 of GSA's open child care centers still need to be tested.

Further, while PBS has tested water in 38 facilities, the testing has not been comprehensive to identify potential contamination from Legionella bacteria, which can cause a serious lung infection called Legionaries' disease. According to the CDC, like lead, there is no safe level of Legionella bacteria in drinking water.

Given the seriousness of this issue, we request your urgent response to the following questions:

Do you affirm that PBS bears primary responsibility for water quality in its buildings? Please describe how PBS is moving forward to implement building management and systems to ensure access to safe drinking water for all occupants in line with requirements under GSA Order PBS 1000.7.
Which child care centers have not been tested as of today? How will you ensure drinking water in all reopened child care centers is (re)tested for lead, copper, and Legionella bacteria in accordance with CDC guidance on reopening buildings after prolonged shutdown or reduced operation? Will children and staff at the child care centers be provided with an alternative source of safe drinking water until water testing is performed?
What necessary steps will PBS take to ensure that proactive water testing at GSA child care centers meets the internal standard of a minimum of once every three years, as required by GSA Order PBS 1000.7? Will you work with GSA to update the testing requirements under the Order to include Legionella bacteria, in addition to lead and copper?
What actions will you instruct PBS to undertake to provide adequate and prompt guidance on testing water quality, and to ensure guidance is applied consistently and fully followed?
Thank you for your attention to this urgent public health matter. We look forward to working with you to ensure the water is safe to drink for all occupants of federal properties, nationwide.

Sincerely,

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