News - Lead Exposure & Lead Copper Rule (LCR)

Lead exposure has been a public health concern for over decades. The accumulative scientific studies have demonstrated even low-level lead exposure over a period of time can cause adverse health effects on adults and typically children.

Why is lead hazardous to the human body? The main reason is attributed to its similarity to calcium, a building block for human bone. Lead, when being dissolved, can replace and function as calcium. Because of this, the research indicated over 90% of lead in the human body is stored in bone. The stored lead in bone can migrate into blood during the period of heightened bone turnover, such as pregnancy when lead is released from bones as maternal calcium and transferred through the blood stream to the fetus to help the bones formation.

In serious cases this can reduce the growth of the fetus and result in premature birth. Due to similar effects, lead is more harmful to infants and young children than adults. The studies have shown even low levels of lead in children can cause heath issues, such as behavioral and learning problems; lower IQ and hyperactivity, etc.

How lead can get into drinking water? It is through corroded service pipes and fixtures. Homes built before 1986 are more likely to have lead pipes, fixtures and solder which can leak lead into the water system by corrosion. To address the corrosion issue of lead and copper into drinking water, in 1991 the Environmental Protection Agency (EPA) issued the Lead Copper Rule (LCR) under the authority of the Safe Drinking Water Act (SDWA). The regulation was revised in 2000 and 2007. EPA delegates primary enforcement responsibility (also called primacy) for public water systems (PWSs) to states and tribes if they meet certain requirements.

In light of a very publicized Flint water crisis, the EPA has requested that states take action to ensure LCR is being properly implemented. Texas achieved final primacy approval for the LCR Minor Revisions in 2006 and LCR Short Term Revision in 2012. On behalf of the state of Texas, Texas Commission on Environmental Quality (TCEQ) is responsible for overseeing the program that ensures production, treatment, delivery and protection of safe and adequate drinking water to the public.

TCEQ has required the community and non-transient non-community PWSs in Texas to monitor LCR starting from 2016 to ensure the LCR and primacy requirements are implemented. The protocols and procedures that TCEQ uses for implementing the LCR are consistent with EPA's guidelines and are shown from the link below:

The requirements for sampling (when and how many) are listed below:

System Size

(number of people served)

Number of sites for

Initial/Routine monitoring

Number of sites for Reduced monitoring:

1YR, 3YR, or 9YR

More than 100,000



10,001 to 100,000



3,301 to 10,000



501 to 3,300



101 to 500



100 or fewer



Initial Sampling: Systems must complete two (2) rounds of consecutive six-month sampling. The monitoring periods for collection are:

6M1: Jan 1 - June 30, analytical results are due to TCEQ no later than July 10

6M2: July 1 - Dec 31, analytical results are due to TCEQ no later than Jan 10

Reduced Sampling: Systems that have completed their two (2) rounds of initial sampling can be reduced to 1-year or 3-year sampling based on their 90th percentile lead and copper sampling during their initial sampling period. Reduced monitoring has a second requirement of a seasonal sampling period:

Reduced: Jun 1 - Sept 30, analytical results are due to TCEQ no later than Oct 10

The requirements for bottle type, preservation and chain of custodian:

·Laboratories must deliver and accept only one-liter unpreserved wide mouth laboratory-grade bottles.

·First-draw tap samples should be received at the laboratory within 14 days after collection date so laboratories can preserve the samples.

·Laboratories cannot accept bottles for analysis without TCEQ Form 20683 -LCR Chain of Custody completely filled out and signed by the PWS representative. This form has the necessary information on it to determine first-draw samples and sampling sites or addresses.

The requirements for sample analysis:

Lead and copper samples MUST be analyzed by a laboratory that is accredited in the "Drinking Water" matrix using an EPA approved drinking water method shown below


EPA Methods

200.5, Rev. 4.2

200.7, Rev. 4.4

200.8, Rev. 5.4

200.9, Rev. 2.2

ASTM Method

D1688-90 A

D1688-95 A

D1688-02 A

D1688-07 A

D1688-12 A

D1688-90 C

D1688-95 C

D1688-02 C

D1688-07 C

D1688-12 C

Standard Methods

3111 B – 18th-22nd eds.

3111 B-99 (online ed.)

3113 B - 18th-22nd eds.

3113 B-99, B-04, B-10 (online eds.)

3120 B – 18th-22nd eds.

3120 B-99 (online ed.)

Hach Methods

8026, Rev. 1.2

10272, Rev. 1.2


200.5, Rev. 4.2

200.8, Rev. 5.4

200.9, Rev. 2.2

D3559-90 D

D3559-96 D

D3559-03 D

D3559-08 D

3113 B - 18th-22nd eds.

3113 B-99, B-04, B-10 (online eds.)


Please contact Ana-Lab for assistance. Ana-Lab is fully approved and accredited by EPA and other states to help you in your compliance efforts.

Bill Peery

Bill Peery is the Vice President of Technical Services and has been with Ana-Lab for over 30 years. He holds a Bachelor of Arts degree in Biology and Chemistry from the University of Texas at Austin and a Bachelor of Science degree in Software Engineering from Lamar University. He also earned his Master's degree in Computer Science and Chemistry from the University of Texas at Tyler.