Audit of GSA’s Response to COVID-19: PBS Faces Challenges to Ensure Water Quality in GSA-Controlled Facilities

Why We Performed This Audit

In April 2020, we began monitoring the actions GSA took in response to the nationwide public health emergency resulting from Coronavirus Disease 2019 (COVID-19) and GSA’s implementation of the Coronavirus Aid, Relief, and Economic Security Act. During our monitoring efforts, we learned that decreased water usage resulting from building closures or occupancy reductions in GSA-controlled (i.e., owned and leased) facilities can create hazards for returning occupants, such as an increased risk of exposure to lead, copper, Legionella bacteria, and other contaminants. As a result, we included this audit in our Fiscal Year 2022 Audit Plan.

Our audit objective was to determine whether GSA has implemented Centers for Disease Control and Prevention (CDC) and U.S. Environmental Protection Agency (EPA) guidance, as well as GSA policies and guidance, to ensure safe drinking water in GSA-controlled facilities after reduced occupancy due to the COVID-19 pandemic.

What We Found

Since the onset of the COVID-19 pandemic, many GSA buildings have experienced extended periods of reduced or no occupancy. During these periods, decreased water usage can cause water in the building systems to become stagnant. This may allow hazardous contaminants like lead, copper, or Legionella bacteria to accumulate.

To address the risk of water stagnation arising from the COVID-19 pandemic, GSA’s Public Buildings Service (PBS) developed water safety guidance that was designed to include recommendations from the CDC and EPA. PBS relied extensively upon its operations and maintenance (O&M) contractors to implement the water safety activities set forth in the PBS water safety guidance. However, we found that PBS did not consistently incorporate these water safety activities into O&M contracts or provide the necessary oversight to ensure that the O&M contractors performed the activities.

We also found that PBS did not follow its requirements for periodic testing for lead and copper in water outlets in GSA child care centers. GSA closed the majority of its child care centers during the COVID-19 pandemic. However, PBS did not test the water in many of these centers for months or years after reopening them. Once performed, tests identified hazardous levels of lead and copper in outlets at some GSA child care centers.

Finally, we found that PBS’s Drinking Water Quality Management policy and the PBS water safety guidance were flawed. Specifically, PBS’s Drinking Water Quality Management policy did not fully incorporate CDC and EPA recommendations on maintaining water quality or testing for contaminants during periods of reduced or no occupancy. Additionally, the PBS water safety guidance did not include clear requirements for flushing and checking disinfectant levels, which can be a key indicator of water stagnation in building systems.

What We Recommend

We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by: 

1. Defining roles and responsibilities for maintaining water quality in GSA-controlled facilities.
2. Ensuring that:
   1. Water quality is maintained through consistent policies and practices nationwide;
   2. Deviations to PBS’s Drinking Water Quality Management policy and the PBS water safety guidance are approved by PBS’s Central Office; and
   3. Any water safety policies or guidance developed by regional offices do not contradict policies and guidance issued at the national level.
3. Ensuring that PBS’s water safety activities are incorporated into O&M contracts, recorded in PBS’s National Computerized Maintenance Management System, and overseen by PBS personnel.
4. Incorporating PBS’s water safety oversight responsibilities into quality assurance surveillance plans for O&M contracts to ensure contractor compliance with water safety activities.
5.  Ensuring that PBS personnel and O&M contractors have access to tenant spaces so flushing can be performed.
6. Amending O&M and other contracts to ensure that energy efficiency and water conservation requirements do not conflict with PBS’s Drinking Water Quality Management policy and the PBS water safety guidance.
7. Ensuring that water is tested in GSA’s child care centers as required by PBS’s Drinking Water Quality Management policy.
8. Ensuring water quality test results—especially those above EPA action levels—are communicated timely to building tenants, GSA child care center operators, and parents and guardians of affected children.
9. Amending and implementing PBS’s Drinking Water Quality Management policy to:
   1. Include reduced occupancy or decreased water usage as additional criteria for lead, copper, Legionella bacteria, and other contaminant testing;
   2. Ensure requirements in PBS’s Drinking Water Quality Management policy, its companion Desk Guide for Drinking Water Quality Management, and the PBS water safety guidance are incorporated into the amended policy, unless there are safety reasons why such requirements cannot or should not be incorporated; and
   3. Formalize its requirement to complete additional testing at child care centers that close for extended periods of time.
       

The PBS Commissioner agreed with the report recommendations. PBS’s response can be found in its entirety in Appendix B.