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Before Sampling:
- Hire a qualified professional as outlined in the Statement of Work (SOW). If you encounter difficulty in locating a suitable firm, a helpful suggestion is to conduct a search for “industrial hygiene consultant” or “environmental consultant” in your local vicinity or the nearest major city using search engines such as Google.
- For this water testing project, a “qualified professional” is detailed in the table below:
Requirements
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Additional Details
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Experience in relevant fields
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A qualified professional must work in an environmental, industrial hygiene, or engineering consulting firm with at least two years of experience.
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Specific experience in on-site testing of drinking water, including Legionella
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The professional must have experience specifically in testing drinking water on-site, including methods for detecting Legionella bacteria.
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Preferential certifications
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We prefer professionals with certifications in ASSE 12080 or those who are certified industrial hygienists (CIH), or supervised by them.
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Certification not mandatory, but preferred
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Although not mandatory, it’s preferred for the professional to have ASSE 12080 certification, be a certified industrial hygienist (CIH), or be supervised by someone with these certifications.
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- Provide the entire SOW and checklist to the qualified professional that you hired.
- Determine all the drinking water outlets that are primarily designed for human consumption and showers in the GSA leased space and all common areas to which the GSA tenants and its visitors have access and would reasonably expect to use.
Areas
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Additional Details
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Outlets Primarily Designed for Human Consumption
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These are places where people typically drink water, such as kitchen sinks, bottled water filling stations, and drinking fountains.
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Not Required for Testing
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This testing does not include bathroom sinks or water lines to tenant-owned equipment (e.g. refrigerators).
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Exclusion of Gyms, Childcare Centers, and Health Units not Part of the GSA Leased Space
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These unique spaces that are not within the GSA leased space are not included in this project.
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- Coordinate a testing date with the on-site Government tenant to minimize disruption of their operations.
- Inform the LAM no later than 5 business days prior to the scheduled testing date.
- Ensure the qualified professional follows all SOW items during the sampling event.
After Sampling:
When results indicate that lead, copper, total coliform bacteria, or E.coli levels exceed EPA, state, or local thresholds, or when Legionella growth is poorly controlled:
- Threshold limits by sample type:
Contaminant
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Limit
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Action Required
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Lead
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≥ 15 ug/L
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Notification and remediation
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Copper
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≥ 1300 ug/L
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Notification and remediation
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Total Coliform/ E. Coli
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Presence detected / Positive
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Notification and remediation
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Legionella
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≥ 1 CFU/mL
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Notification and remediation
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- Ensure the qualified professional provides notification of any exceeding results within 24 hours of notice from the laboratory, their notification should highlight the areas that didn’t meet established standards.
- Notify the GSA LAM the same day a laboratory report identifying exceedances, or a heads-up about laboratory data with exceedances, is received from the qualified professional.
- Indicate that outlets have been taken out of service along with the date implemented.
- Indicate that signage has been posted along with the date implemented.
- Indicate that tenants have been notified along with the date sent.
- Indicate what corrective actions are taking place or planned along with the date implemented or projected implementation date.
- Ensure the written report from the qualified professional is submitted to waterquality@gsa.gov within five business days of receipt. The written report should include, at minimum, the following components:
- Executive summary.
- Brief description of the facility and water system
- Name of the person who performed the investigation
- Summary of the investigative work performed
- Summary of any findings, including test results, compared to CDC resources & EPA or applicable state or local thresholds
- Table of all test results highlighting any results above CDC resources & EPA or applicable state or local thresholds.
- Background information.
- Investigation.
- Name of the person who performed the investigation and qualifications including type of firm, years of experience in potable water sampling, and applicable certifications.
- Description of the outlets sampled, along with pertinent details about each outlet
- Description of CDC resources, EPA, or applicable state or local thresholds
- Results of the sampling
- Recommended corrective actions, if applicable
- Conclusions.
- Signature of the sampler, supervisor, and applicable CIH, or the ASSE 12080 certified individual.
- Report Attachments.
- Updated inventory of outlets
- Complete laboratory analytical data packages with chain-of-custody documentation, copies of relevant laboratory accreditation/certification,
and laboratory quality control package
- Field sample forms, daily logs, and all other field paperwork
- One figure per building floor depicting each drinking water sample location and analytical result
- Photographic record of each outlet sampled including the barcode of the sampling bottle provided by the lab in the photo.
- Any additional state and local documentation requirements
- Hire a qualified professional to develop a SOW and conduct re-sampling after corrective actions have been implemented.
- Keep GSA LAM updated as additional steps are taken.
- Continue additional corrective actions and resampling until all issues have been resolved.
When all results are below EPA, state, or local thresholds, and when Legionella growth is well controlled, ensure the written report from the qualified professional is submitted to waterquality@gsa.gov within five business days of its receipt. The written report should include, at minimum, the following components:
- Executive summary.
- Brief description of the facility and water system
- Name of the person who performed the investigation
- Summary of the investigative work performed
- Summary of any findings, including test results, compared to CDC resources & EPA or applicable state or local thresholds
- Table of all test results
- Background information.
- Investigation.
- Name of the person who performed the investigation and qualifications including type of firm, years of experience in potable water sampling, and applicable certifications.
- Description of the outlets sampled, along with pertinent details about each outlet
- Description of CDC resources, EPA, or applicable state or local thresholds
- Results of the sampling
- Conclusions.
- Signature of the sampler, supervisor, and applicable CIH, or the ASSE 12080 certified individual.
- Report Attachments.
- Updated inventory of outlets
- Complete laboratory analytical data packages with chain-of-custody documentation, copies of relevant laboratory accreditation/certification,
and laboratory quality control package
- Field sample forms, daily logs, and all other field paperwork
- One figure per building floor depicting each drinking water sample location and analytical result
- Photographic record of each outlet sampled including the barcode of the sampling bottle provided by the lab in the photo.
- Any additional state and local documentation requirements
* The Lessor will send the Drinking Water Testing Deliverable Report to waterquality@gsa.gov using the following naming convention in the email subject line and attachment: <BLDG_NUM> - Drinking Water Testing - 2024.
Can we use a test that we already have for our building?
Water quality is dynamic and can change literally every few days, so many tests are very likely too old to be relevant. Prior testing may not have included all of the testing elements GSA is looking for in the testing we are performing, and they were very likely not done with a focus on GSA specific leased space. In addition our scope of work requires a specific testing protocol. As such, prior tests will not be accepted.
If the test results indicate a problem with the water in my building, who funds the remediation and any follow-up testing?
The Government is initiating the testing under the contractual authority of the lease. If a problem is identified, it is the responsibility of the lessor to remediate (correct) the problem in order to be in full compliance with the lease and perform any follow up testing necessary.
If my company has personnel that meet the professional qualification requirements stated in the ULA scope of work, can we perform the testing ourselves or must we contract with a third party vendor?
The testing must be performed by an independent third party. The ULA Statement of Work (SOW) has been modified for Phases 2 onwards to clarify this.
Can we collect the water samples ourselves, or must that be done by the third party testing vendor?
The lessor may not collect the water samples for the testing, which must be performed by an independent third party.
Will I receive prior notification before I receive the water testing Unilateral Lease Amendment (ULA)?
Yes, we plan to send a “heads up” email notification approximately 5 business days prior to sending the ULA itself. These “heads up” emails will be sent to the email address listed under your SAM.gov entity registration.
How are you issuing these Unilateral Lease Amendments?
GSA is signing and issuing these Unilateral Lease Amendments (ULAs) using our DocuSign application. ULAs will be sent to the email address listed under your SAM.gov entity registration. To the extent that we have a lessor’s property management point of contact (POC) listed for your entity, we will copy them within the DocuSign application as well. It is very important that whomever receives the ULA ensure that it is forwarded to the appropriate party within your entity’s organization for action.
Who do I contact if I have a question about the Unilateral Lease Amendment (ULA)?
Please reach out to the appropriate GSA Lease Administration Manager (LAM) as identified in the ULA with any questions or concerns.
Do I need to sign the Unilateral Lease Amendment?
ULAs do not require lessor signature in order to be effective.
The Unilateral Lease Amendment (ULA) scope of work (SOW) requires testing within GSA’s leased space and “all common areas to which the GSA tenants and its visitors have access and would reasonably expect to use.” Can you please provide an example of what types of common areas that should or should not be tested?
An example of common areas that should be tested are drinking fountains or bottle fillers in close proximity (i.e., on the same floor and closest to the leased space). Another example would be a drinking fountain located in the ground floor lobby that would be used by our federal tenants’ visitors. An example of common areas that should not be tested include drinking fountains on floors not occupied by our federal tenants. These examples are not exhaustive. Please contact the identified GSA Lease Administration Manager (LAM) for additional information.
I am ready to schedule the test. Who do I notify and when?
Per the Unilateral Lease Amendment (ULA) scope of work (SOW), please coordinate any testing date with the tenant agency to ensure minimum disruption to agency mission activities. No later than five (5) business days ahead of the scheduled testing date, notify the GSA Lease Administration Manager (LAM) identified in the ULA.