GSA Lease Water Quality Testing

Technician collecting a water sample from a homeowner's kitchen sink for water quality testing – Full Spectrum Environmental

Guide to Meeting US GSA Drinking Water Quality Management Standards

In 2023, the US General Services Administration (GSA) significantly updated its GSA Order on Drinking Water Quality Management, originally established in 2016. The revision was driven by growing concerns over water quality and its impact on health, such as a reported nine-fold increase in Legionnaires’ disease cases between 2000 and 2018 by the CDC
This surge, among other factors, prompted the GSA to mandate water quality testing in leased spaces starting in the fiscal year 2024. Lessors have 90 days from receiving a Unilateral Lease Amendment (ULA) to provide GSA with test results that meet the specified requirements. Lets dive into what exactly is required to comply with this lease mandate.

What Water Testing Does GSA Require?

GSA requires the lessor to provide results from a qualified 3rd-party tester with the following contaminants

  • Legionella

  • Total Coliform including E. coli

  • Lead

  • Copper

Where Will GSA Require Testing?

GSA will issue a Unilateral Lease Amendment (ULA) requiring testing for all leases greater than 60 square feet of usable square footage that contains drinking water systems, including over 6,000 leased facilities. Each ULA will be issued through phases:

  • Phase 1: 207 ULAs issued Feb 13th and 15th

  • Phase 2: 588 ULAs issued March 18th and 19th

  • Phase 3: ~2,000 ULAs issued on or about April 16

  • Phases 4 – 5: To be determined, to be issued approximately 1 month apart

 

What To Do When You Receive Your ULA

Upon receiving your Unilateral Lease Amendment it is crucial to go over the Water Quality Testing ULA Lessor Checklist to ensure your deliverables meet the requirements of the Scope of Work (SOW).

Brief Checklist Takeaways:

  1. Obtain a Qualified Third-Party Sampling Contractor: Provide the complete SOW (provided by GSA) to the contractor.

  2. Coordinate Testing: Work with the local agency and notify date of testing to GSA Lease Administration Manager (LAM). (Be cautious of date restrictions in regards to testing parameters; specified in SOW)

  3. Immediate Notification of Exceedances: Notify the GSA LAM within 24 hours if any exceedances are detected.

  4. Submit Test Results: Send test results and reports to waterquality@gsa.gov.

  5. Follow-Up Actions: If actionable test results are found, follow the lease requirements for potable water and take necessary remediation actions.

 

What If an Exceedance is Found?

 

Lead – Less than or equal to 15 ug/L

Copper – Less than or equal to 1,300 ug/L

Total Coliform / E. Coli – Presence detected positive / negative

Legionella – Less than or equal to 1 CFU/mL

 

If Any Test Shows Exceedances, Lessors Must:

  • Notify the GSA LAM immediately.
  • Mitigate potential exposure by removing impacted outlets from service, posting signage, and notifying tenants.
  • Perform remediation actions such as flushing the system, adjusting operational parameters, implementing a water management program.
  • Retest the impacted fixtures to ensure corrective actions are effective before returning them to service.

 

Invoicing for Testing

After completing the testing, lessors must email an electronic copy of the invoice to the Lease Administration Manager identified in the ULA and copy g-rex.file@gsa.gov within three business days. The invoice should clearly break down the amount paid to the testing contractor.

Conclusion

Staying compliant with GSA’s updated water quality testing requirements is essential for lessors and property managers of federal facilities. By understanding and following the outlined steps, you can ensure the safety and well-being of building occupants while maintaining compliance with federal regulations.