How to Comply with US GSA Drinking Water Quality Management Order

Buildings Owners Leasing to Government Entities Must Complete Sampling of Drinking Water in Leased Space in 2024

By Corey H. Myers, CIH, Technical Director

The US General Services Administration (GSA) manages government buildings and leased real estate assets. Many building owners throughout the country lease space to government entities, and as a condition of the GSA lease, must complete sampling of drinking water in the leased space in the fiscal year 2024. But what is required to be compliant with this lease requirement?

Water Quality Management Order Requirements

The US GSA published a guidance called “Drinking Water Quality Management (PBS 1000.7A)” in November 2023. As part of this guide, the GSA is requiring baseline testing of drinking water at most of their owned and leased spaces, including over 6,000 leased facilities. This requirement helps ensure the safety of federal employees, contractors, and visitors in federal buildings as part of a healthy work environment.

According to the guide, the sampling of the potable water sources shall be completed by a qualified professional with a minimum of two years of experience in conducting potable water sampling, and with preference to professionals who hold an ASSE 12080 certification or a Certified Industrial Hygienist (CIH) designation, or with a professional working under the supervision of a CIH or ASSE 12080 certified individual.

Water Sampling Protocol

The sampling protocol itself includes using laboratory-provided preserved bottles to collect hot water (when available) for analysis of Legionella bacteria, and cold water for analysis of Total Coliform/e. coli bacteria, lead, and copper. The potable outlets to be sampled include showers, kitchen sinks, drinking fountains, bottle filling stations, etc. The sampling protocol has specific timing and scheduling requirements as well. Determining how many samples need to be collected depends in part on the facility usage.

• Child Care or Healthcare Unit– all potable outlets designed for human consumption (i.e. not bathroom sinks)
• Other Use Facilities:
  • Showers, including common area showers – 1 sample per 3 fixtures.
  • The greater of 5 outlets or 10% of leased and common area drinking water outlets designed for human consumption (i.e. not bathroom sinks)

Next Steps for Building Owners

Partner can provide this sampling protocol under the direct supervision of our CIHs. Partner has been providing drinking water sampling, analysis, and consulting for over a decade to public and private clients nationwide. If you are leasing to a GSA tenant, contact Partner to assist in meeting your drinking water sampling requirements.

For any questions or further discussion, contact Corey Myers, CIH, at [email protected].