FHA Water Tests

**Stuart Brooks** · 09-01-2010, 03:52 PM

Has anyone seen current official government documentation requiring specific tests on private well water for a FHA or VA home mortgage?

I take water samples and have state licensed lab perform tests on well water as an ancillary service. I often am told by the client, or in some cases the agent, that they need FHA tests or in some cases the VA tests. I always tell them that HUD, FHA, and VA do not require specific water tests but all defer to whatever is required by the locality in which the home and well are located. In my case that is Coliform bacteria. My research has never found any government document that requires lead, nitrite, nitrate, e-coli, fecal bacteria, total bacteria, pH, or anything else. The EPA suggests a similar test regimen for all private wells but cannot mandate any test.

Last week I ran into an obstinate loan processor that demanded the tests be performed. I think the real estate agent may have been too lazy to argue the point for his customer. So what if it costs $400-$500 dollars and takes up to 15 days to get the results back?

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**Scott Patterson** · 09-01-2010, 04:34 PM

Originally Posted by Stuart Brooks

Has anyone seen current official government documentation requiring specific tests on private well water for a FHA or VA home mortgage?

I take water samples and have state licensed lab perform tests on well water as an ancillary service. I often am told by the client, or in some cases the agent, that they need FHA tests or in some cases the VA tests. I always tell them that HUD, FHA, and VA do not require specific water tests but all defer to whatever is required by the locality in which the home and well are located. In my case that is Coliform bacteria. My research has never found any government document that requires lead, nitrite, nitrate, e-coli, fecal bacteria, total bacteria, pH, or anything else. The EPA suggests a similar test regimen for all private wells but cannot mandate any test.

Last week I ran into an obstinate loan processor that demanded the tests be performed. I think the real estate agent may have been too lazy to argue the point for his customer. So what if it costs $400-$500 dollars and takes up to 15 days to get the results back?

I have not run across this yet, but all wells in my area must be certified by the local/state health department anytime a home is sold.

David Bell · 09-04-2010, 06:37 PM

I had to have mine tested but, I can't remember if it was for FHA or, for the DOH money I got.

**Stuart Brooks** · 09-04-2010, 07:30 PM

Originally Posted by David Bell

I had to have mine tested but, I can't remember if it was for FHA or, for the DOH money I got.

No mandatory state testing requirements for private wells in VA other than new wells have to be tested for coliform bacteria.

Bill Martin · 09-04-2010, 07:52 PM

Here is a website that can answer your questions on VA/FHA/HUD water testing. As usual with any government body it can be confusing as to by whom, and what is actually required.

http://www.hud.gov/offices/hsg/sfh/ref/sfh1-21b.cfm

Check with your lab, most have a FHA/VA test as part of there standard packages.

**Stuart Brooks** · 09-05-2010, 06:26 PM

Originally Posted by Bill Martin

Here is a website that can answer your questions on VA/FHA/HUD water testing. As usual with any government body it can be confusing as to by whom, and what is actually required.

HUD HOC Reference Guide Individual Water Systems

Check with your lab, most have a FHA/VA test as part of there standard packages.

Thanks Bill. 1) I've already been through all that info and more at the EPA, HUD, FHA, and VA sites. I've checked with my state and local health departments. The federal documents defer to locality requirements for testing. 2) I have asked the local labs and the response was "never heard of one". Real working labs where you walk in and people are busy running tests in the lab. I'm not talking about the labs that we see advertising on here and other HI media. The ones that are heavy into marketing their services

This paragraph is included in the info from the web page you cited:
2: Water Quality
A: Individual water wells are owned and maintained by the homeowner, and are subject to compliance with all requirements of the local and/or State Health Authority having jurisdiction.
B: Individual water systems no longer require automatic testing or inspection unless it is mandated by state or local jurisdictions; it is believed that the water may be contaminated or when the water supply relies upon water purification system due to the presence of contaminants. The lender also has the option to require testing.
When testing is required, the water well must meet the requirements of the local authority. If the local authority does not have specific requirements, the maximum contaminant levels established by the Environmental Protection Agency (EPA) will apply.

The red line is the killer, the "lender" can require anything.

**H.G. Watson, Sr.** · 09-05-2010, 08:16 PM

"Individual water systems no longer require automatic testing or inspection unless it is mandated by state or local jurisdictions; it is believed that the water may be contaminated or when the water supply relies upon water purification system due to the presence of contaminants. The lender also has the option to require testing."

The presence of a water treatment system, such as chlorination, etc. a septic system dye test that the results indicate or tend to indicate that the system and well were "purified" (household bleach disables the dye and can lead to false and/or suspicous results), or a "belief" = this could be generated by a septic system report, the photos or report from the FHA "appraisal report", i.e. topography of the lot, geographic or regional history, (flood plain, USGS survey reports, etc.) "smell of bleach", simple things such as older un-protected from backflow or cross contamination potential hose bibs/spigots, local grazing or farming activities, evidence of recent repair/replacement in the system without evidence or proof of system sanitization processes, recent "winterization" or time periods with a lack of electrification (maintain pressure to system) regional or local contamination issues; OR a lender requirement. HUD/FHA and VA are insurance underwriting in the event of a default - the lender/producer is not limited to the FHA underwriting requirements those are the minimum.

Private well, should be SOP for a water quality test, don't see why you as a HI would be complaining, esp. for a buyer's inspection...unless you're waiting to closing for your fee. Private well owner should SOP at least annual testing, more extensive panels depending on region, aquafer, local/regional issues, nearby hazards, frequency depending. My "northern" I get nitrates and bacteria twice a year, TLCPs, heavy metals and isotopes every 2.

If on a private sewage treatment system (septic) its pretty much SOP for any lender to require water quality testing for coliform at a minimum if private well.

Two weeks for a turn-around certified water quality report?!? use a different certified laboratory!

**Jim Luttrall** · 09-05-2010, 09:13 PM

When testing is required, the water well must meet the requirements of the local authority. If the local authority does not have specific requirements, the maximum contaminant levels established by the Environmental Protection Agency (EPA) will apply.

What are the epa drinking water standards:

Private Drinking Water Wells | Private Wells | US EPA

EPA regulates public water systems; it does not have the authority to regulate private drinking water wells. Approximately 15 percent of Americans rely on their own private drinking water supplies, and these supplies are not subject to EPA standards, although some state and local governments do set rules to protect users of these wells.

Typical double speak

**Stuart Brooks** · 09-06-2010, 08:15 AM

Originally Posted by H.G. Watson, Sr.

"Individual water systems no longer require automatic testing or inspection unless it is mandated by state or local jurisdictions; it is believed that the water may be contaminated or when the water supply relies upon water purification system due to the presence of contaminants. The lender also has the option to require testing."

The presence of a water treatment system, such as chlorination, etc. a septic system dye test that the results indicate or tend to indicate that the system and well were "purified" (household bleach disables the dye and can lead to false and/or suspicous results), or a "belief" = this could be generated by a septic system report, the photos or report from the FHA "appraisal report", i.e. topography of the lot, geographic or regional history, (flood plain, USGS survey reports, etc.) "smell of bleach", simple things such as older un-protected from backflow or cross contamination potential hose bibs/spigots, local grazing or farming activities, evidence of recent repair/replacement in the system without evidence or proof of system sanitization processes, recent "winterization" or time periods with a lack of electrification (maintain pressure to system) regional or local contamination issues; OR a lender requirement. HUD/FHA and VA are insurance underwriting in the event of a default - the lender/producer is not limited to the FHA underwriting requirements those are the minimum.

Private well, should be SOP for a water quality test, don't see why you as a HI would be complaining, esp. for a buyer's inspection...unless you're waiting to closing for your fee. Private well owner should SOP at least annual testing, more extensive panels depending on region, aquafer, local/regional issues, nearby hazards, frequency depending. My "northern" I get nitrates and bacteria twice a year, TLCPs, heavy metals and isotopes every 2.

If on a private sewage treatment system (septic) its pretty much SOP for any lender to require water quality testing for coliform at a minimum if private well.

Two weeks for a turn-around certified water quality report?!? use a different certified laboratory!

I don't complain if the person paying for the test wishes to have the tests done- I'll be glad to do what ever they wish. Unless it is a hardship case, I get paid up front at the time of sampling. If it is a normal sale, it's the seller who usually must pay for the well test. The buyer pays when the transaction is a foreclosure.

I do inform the person who asks for a FHA or VA well test that those agencies do not have specific test requirements beyond what is required by the locality, which in this area is coliform. I recently ran into a case where a loan processor was demanding the FHA test to include bacteria, e-coli, nitrates, nitrites, lead, turbidity and a few more.

I can't speak for where ever you may be from or have been or the market condition in the your time frame HG. But most of these sales are still foreclosures and short sales. Buyers are given typically 7 days, sometimes 10, to obtain any and all inspections or tests. To most of these buyers, there's a big difference between $275 and $500 to pay for well test alone. Thanks to their foot dragging agent, a lot are left hanging with only 1-3 days to get things done. I have never been asked for well or septic inspections as part of a HI. It may come. Would I, Do I recommend all the tests and a few others depending on the specific location of the well? Yes-sir-ree-bob.

Labs? There is one state certified lab in the area. Okay, another one is 35 miles away. Neither do lead or organics on site, they ship it to another lab. I would guess that had something to do with what is required in the state. The other factor is a bacteria sample has to stay chilled (not frozen) and be delivered to the lab within 24 hours of sampling.

Time - its more than lab time. The time includes fitting into my schedule, shocking the well if ordered, collection, preparation, delivery to the lab, and time to prepare the final report. The lab states a 24-48 hour TAT for coliform test, 4 days for nitrate/nitrite, and 7 for lead. That's business days not calendar. I'm sure the extended times are because they have to ship to another lab. Now, could I have the bacteria done locally and ship anything else to another lab? Yes - but, not too many of these people want to pay for overnight delivery shipping and I'd still have to get it to a pickup point in time.

The septic dye test as specified by HUD-FHA-VA, is a joke dreamed up by a bureaucrat that had no idea how a septic system works. But, it's required, and I follow the procedure. I do recommend having a real, dig it up, inspection (not by me) on septic systems more than a few years old. In this part of the country, which is part of the Chesapeake Bay watershed, septic tanks have to be pumped every 3 years.