Stay compliant with our water testing modification effort

Background

Starting in February 2024, we issued pre-priced, unilateral change orders to include a scope of work for baseline water quality testing in our existing leases, with certain exceptions. We are ordering baseline testing in federally owned facilities and leased spaces in response to water stagnation concerns, including issues related to Legionella.

What you need to do

You need to review and act upon these lease amendments when you receive them. They will include a scope of work for the testing and a not-to-exceed payment that we authorized. We will not countersign them, because it’s not required for unilateral lease amendments. We appreciate your cooperation.

Use our water testing ULA checklist for lessors to help you with the testing, notification, and submittal requirements stated in the ULA scope of work.

If you are having trouble locating vendors

First we suggest you use any search engine to look for local environmental or industrial hygiene consultants to perform the work. Board for Global EHS Credentialing or ASSE International-certified professionals are not required, but you can opt to use them. We do not endorse any company on the lists or otherwise.

If you already have a test for your building

Unfortunately we cannot use prior tests. There are many reasons for this:

• Water quality is dynamic and can change literally every few days.
• Prior testing may not have included all of the testing elements or focused on our leased space.
• Our scope of work requires a specific testing protocol.

If the test results indicate a problem with the water in my building

You bear the responsibility and expense to correct the problem and perform any follow-up testing that is necessary to be in full compliance with the lease. 

For fixtures that are only above GSA’s action level for Legionella, GSA is following the recommendation from industry experts to leave the affected fixtures in service while corrective actions are being completed to reduce the risk of exposure.  Signage and corrective actions are still required.

FYI, here is a link [PDF - 219 KB] to signage wording that GSA uses for exceedances at our owned facilities, which you may use. The first two signs (English and Spanish) are for legionella exceedances only and the third and fourth signs (English and Spanish) are used for lead, copper or Total Coliform/E. Coli exceedances. 

If you want to collect water samples yourself instead of hiring a third-party vendor

You cannot do this, even if you have personnel who meet the professional qualification requirements in the ULA scope of work. You must use an independent third party to perform the testing. We clarified this in the ULA SOW.

If you haven’t received the ULA

You should receive a heads up email notification approximately five business days before we send the ULA at the email address listed under your SAM.gov entity registration. If you listed a property management point of contact, we will copy them on the email too.

You will get the actual ULA through DocuSign, but you do not need to sign it for it to be effective.

If you have a question about the ULA

Reach out to the lease administration manager we identified in the ULA

If you are not sure which common areas our tenants and visitors have access to or are reasonably expected to use

Here are some examples, but this is not an exhaustive list:

• Drinking fountains or bottle fillers that are on the same floor and closest to the leased space, but you are not required to test drinking fountains that are not on floors our federal tenants occupy.
• A drinking fountain located in the ground floor lobby that our tenants’ visitors would use.

If you are ready to schedule the test and notify occupants

You need to coordinate any testing dates at least five business days ahead with the tenant agency to ensure minimum disruption to agency mission activities. Make sure to also notify the LAM identified in the ULA.

Submit your questions and comments to waterquality@gsa.gov.