Township’s Sampling from Only Lowest-Risk Homes Could Mislead Residents Regarding Actual Lead Risk

(Lititz, PA)-The Warwick Township Municipal Authority may have disregarded state and federal drinking water regulations in 2013 when it only tested homes that were at lower risk for lead in drinking water in systems it serves in Rothsville and Lititz, according to documents provided to in response to a request under the Right-to-Know Law.

The decision by WTMA officials to only test lower-risk homes known as Tier 3 sites for lead instead of sampling water from higher-risk Tier 1 or 2 sites may have mislead Lititz residents about levels of the toxic metal in tap water entering their homes from a well in Rothsville and in the water it purchases from Lititz Borough for distribution to township customers.

“Sampling only Tier 3 sites is acceptable ONLY if there are NO Tier 1 or Tier 2 locations anywhere in the distribution system,” according to an email from Neil Shader, spokesperson for the PA DEP.

All locations that WTMA tested for lead in water during 2013 were lower-risk Tier 3 homes. Document Courtesy WTMA

All locations that WTMA tested for lead in water during 2013 were lower-risk Tier 3 homes. Document Courtesy WTMA

Lead is rarely found at the source of drinking water, but the quality of water and deterioration of aging pipes can cause dangerous lead particles to leach into household water.

“Lead and copper corrosion pose various health risks when ingested at any level,” according to the 2014 Pennsylvania Department of Environmental Protection Annual Compliance Report. The federal allowable limit for lead in drinking water is 15 parts per billion (pbb) and is an arbitrary number not based on health risks.

Results reported by the WTMA to the state and consumers in 2013 were within acceptable levels according to the EPA regulation, but may have been skewed by the selective sampling of lower-risk homes.

Our email request for an interview with WTMA Board Chairman Troy Clair went unanswered. Dan Zimmerman, who serves as the township manager and the administrator of the Warwick Township Municipal Authority, refused to take part in a recorded interview with

The WTMA reported Rothsville at 11 ppb, near the 15 ppb federal limit, and Lititz water at 3.1 ppb. The figures calculated from a small percentage of homes are meant to be representative of the highest-risk residences for lead contamination, but in the case of WTMA service areas, the levels were derived only from lowest-risk homes.WTMALititzp1

Federal and state regulations require water suppliers to first test homes that are at highest risk for lead contamination in drinking water—single family homes with copper plumbing and lead solder built between 1982 and 1985, or with lead service lines or pipes—on a set schedule.

The WTMA must test these sites, classified as Tier 1, every three years. If no Tier 1 sites are available, or there are not enough homes to meet the sample quota, the WTMA must sample sites classified as Tier 2, which broadens potential test locations to include buildings and multi-family residences built between 1982 and 1985 that have copper pipes and lead solder, or locations that have lead service lines, or lead pipes. If a water provider still does not have an adequate number of samples, only then may it test water from the lowest-risk category: Tier 3 homes built before 1980.

Warwick Township water officials needed to identify and sample only 20 high-risk sample sites from among over 3,000 connections it serves with Lititz Borough water in 2013, but instead the township only sampled from lower-risk Tier 3 homes, according to documents provided to

Through real estate records, was been able to identify at least six homes in Rothsville that appear to meet Tier 1 qualifications for testing on the street where two of the sampled Tier 3 homes are located.

All water samples sent by the WTMA from its Rothsville and Lititz water sources to a lab in Middletown for lead testing in 2013 were from Tier 3 sites, according to documents provided to in response to a request under the Right-to-Know Law.

In 2013, Warwick Township reported the 90th percentile level for lead at 3.1 parts per billion in the Lititz water it buys from the borough, “well below action level,” according to an email received from Dan Zimmerman, who manages Warwick Township and serves as the WTMA administrator.

In Rothsville, where the 90th percentile finding for lead was 11 ppb, the WTMA sampled only 10 low-risk homes in 2013, the last year it was required to test. The findings may have been higher had the water authority identified and sampled water from Tier 1 homes as required.

Zimmerman explained the sampling sites selected in Rothsville in an email to

“First, our sampling protocol follows all required requirements from DEP.  The sampling base consists of 10 residential structures. We select homes built before 1980.  The reason for that sample group is the common practice of lead solder on copper piping.” Zimmerman later acknowledged by email that those homes fall into Tier 3 classification, a fact backed up by the documents provided.

Warwick Township released a statement last week that “All water quality information on the reports is derived from sampling protocol that meets PADEP and United States Environmental Protection Agency (USEPA) standards. As a public water utility we are required to meet their sampling data protocol.”

“I have to respond [to requests] under the Right-to-Know Law,” said Zimmerman, who also serves as the township’s Right-to-Know Law officer.

“Not everybody wants to take the samples,” Zimmerman said, “I can’t force people to take a sample.”

“The water tested in Warwick was 11 ppb, below the EPA’s action level of 15 pbb, and is considered safe to drink” wrote PA DEP’s Neil Shrader in an email to after learning of the sampling of only Tier 3 sites in Rothsville.

The next meeting of the Warwick Township Municipal Authority will take place tomorrow, Tuesday, February 17 at 7 p.m. at the township building, 315 Clay Road, Lititz. The meetings are free and open to the public.