Water Testing for Real Estate Transactions and Mortgage Refinancing – FHA Loans

Brian Oram, Licensed Professional Geologist
Featured Water Professional

FHA Mortgage Drinking Water Testing

In 1934, the United States founded the FHA (Federal Housing Administration) with the primary purpose of providing mortgage insurance on home loans made to a lender who was approved by the FHA. The main purpose of this change was to help stabilize the real estate market in the USA and its territories and to protect the lender, not the borrower. The typical lending requirements or terms are:

  • FICO® score at least 580 requires a 3.5% down payment.
  • FICO® score between 500 and 579 requires a 10% down payment.
  • MIP (Mortgage Insurance Premium ) is required.
  • Debt-to-Income Ratio < 43%.
  • The home must be the borrower's primary residence.
  • Borrowers must have a steady income and proof of employment.
  • A number of specific inspections are required, such as  the FHA drinking water test.

The FHA loan process may require an FHA water test (Level 4- Certified Testing).  The FHA water test does not guarantee that a home or building will have a “long-term safe drinking water source”, but it is a basic screening test to check the overall quality and “safety” of the drinking water.  The basic FHA loan water-screening testing includes testing for as few as three contaminants: Total Coliform, Nitrite, Nitrate, and Lead.   Because of the limited nature of this testing, this is one reason that the potential future homeowner may want to conduct a visual inspection of the system and water examination (Level 1) and conduct an informational water test (Level 3).

The following is part of the general provisions and requirements related to individual water supply systems and water wells from  the FHA Single-Family Housing Policy Handbook – Section B - Property Acceptability Criteria – Section 13 or Utility Services (View pdf).  The general requirements under Individual Water Systems are as follows:

Individual Water Supply Systems

1. If a public water supply system is available and the property is not connected, the mortgagee must determine whether the public water connection is feasible. 

a. Water Quality must meet the requirements of the health authority with jurisdiction. 

b. If there are no local or state water quality standards, then water quality must meet the standards set by the US EPA.  

Note:  The US EPA only enforces the “Primary” drinking water standards and not the “Secondary” standards. The “Secondary” standards are associated with aesthetic, cosmetic, and technical effects with the water and includes Iron, Manganese, Aluminum, Chloride, Copper, Foaming Agents, Silver, Sulfate, Total Dissolved Solids, Corrosivity, Zinc, pH, Fluoride, Color, Taste and Odor.

c. Termite control through soil poisoning may only be used in specific situations.  

d.  Well Locations and set-backs are set for New and Existing Construction and they are not the same (24 CFR §7 200.926d (View pdf

Water Wells 

For New Construction:

1. Minimum water system standards for new construction, such as lead-free piping (< 0.2 % lead for solders and flux and < 8 % for pipes and pipe fittings; this is an old standard that is in the current pdf).  Updated lead-free requirements (< 0.25 % lead in wetted surfaces of piping, pipe fittings, plumbing fittings, and fixtures and < 0.2 % lead in solder and flux – 40 CFR Part 143 Subpart B (up to date as of 8-11-2022).pdf). If there are no local chemical or biological water standards, state standards apply, but some states do not regulate “private wells”.

2. Connection “to” public water whenever feasible. 

3. Well must deliver a water flow of 5 gpm (gallons per minute) over a minimum of 4 hours of pumping. 

For Existing Construction:

1. Existing wells must deliver a water flow of 3 to 5 gpm.

2. No exposure to environmental contamination which is why we recommend the Neighborhood Environmental Hazard Report.

3. Continuing supply of safe and potable water.

4. Domestic hot water. Non-commercial hot water system

5. Water quality must meet requirements of local jurisdictions or the EPA if there is no local standard. 

KnowYourH20 Team Recommendations

The KnowYourH2O take on the FHA Water Testing Requirements and its provisions: In general, most states have limited regulations related to private wells and private or individual water systems.  In many areas the local health department does not have regulatory oversight of these wells, lacks the specific environmental or geological expertise, or even does not provide truly informed water quality testing requirements for individual private water systems or private water wells. 

We developed these recommendations after dealing with many projects that developed a problem, adding unnecessary expense to the “NEW” homeowner, because some very simple items were not done.  

Our example: 

Case Study: There was a home in a remote wooded area in Pennsylvania with an on-site septic system, propane tanks, and an on-site water well. The young family, i.e., wife, husband, young child, and an infant, bought their first home.  The system was serviced by a water well with no drilling log or information about the well construction and the home had a water treatment system that included Particle Filtration, Chlorination, and a particle filter. The new homeowners did a basic water test that included a raw water or untreated sample that was tested for Total Coliform, E. coli., Nitrate and Nitrite, and Lead and a treated water sample which was tested for Total Coliform and E. coli. 

Guess What! Everything was fine and even the raw water Total Coliform was negative.  

Homeowners Moved into the home – they went to take a shower and the water tasted like “Salt.” When we visited the home, they thought the problem was the chlorination system. We field-tested the water with a conductivity meter.  The reading was over 5000 uS/cm and the estimated total dissolved solids was over 2500 mg/L.  The salt problem was the well, which is over 140 miles and uphill of the ocean. The source of the salt was a “saline water-bearing zone” in the local bedrock, very old water because the local geology was associated with a coastal deposit over 300 million years old when the area was an inland sea.   If the initial inspection had included testing the water with a field meter or conducted an initial total dissolved solids test or tasted the water, this problem would have been identified before the homeowner had to spend over 

$10,000 on an R/O system with building and plumbing renovations. 

At a minimum, the KnowYourH2O Team recommends the following:

1. Complete a Neighborhood Environmental Hazard Report for the property in question. This will help to attempt to identify historical local problems with pesticides, industrial chemicals, arsenic, radionuclides,  contaminated sites, and historic environmental releases, spills, and clean-ups.   

2. Make an inspection of the plumbing or water system and look for evidence of Corrosion, lead piping, asbestos, leaky pipes, chemical scales and coating, and evidence of Nuisance Bacteria (slimy coatings, odors, or biological films / coatings in reservoir tanks, water filters, or fixtures). If your home inspector is not a “Water Treatment Professional,” you may want to have the inspection highlight the need for an inspection by this type of professional. Yes, give the water a taste, take a look and take a smell. Did you see, smell, taste any problems or nuisance issues?  You may want to check out our “Drinking Water Self-Diagnostic Tool.”

3. Conduct other inspections that may impact the on-site water source, such as a septic system inspection, termite inspection, radon-in-air testing, mold/ HVAC inspection, water treatment system inspection and testing, home construction, pest inspection, lead paint, and asbestos.  In some cases, it may be necessary to conduct a soil stability, foundation, and crawl space inspection.  The main goal is to Get Informed. If possible, the untreated and treated water should be field tested for pH, conductivity, estimated Total Dissolved Solids (TDS), Oxidation Reduction Potential (ORP), and temperature. 

3. Review minimum water-testing criteria with health departments, state agencies, well drillers, neighbors, and local professionals and not just the home inspector.   

4. Integrate the observations and information obtained from Items 1, 2, and 3 and conduct water testing that at least includes microbiological quality, Nitrate and Nitrite, Total Dissolved Solids, pH, conductivity, Copper (first flush and flush sampling), lead (first flush and flush sampling), and Turbidity.   

If the home has a Water Treatment System, it may be wise to collect an untreated and a treated water sample to make sure the water treatment system is working plus additional testing for other metals, Volatile Organics Compounds (VOCs), Forever Chemicals (PFOS), Synthetic Organic Compounds (SOCs), other Microbiological agents, and Radionuclides

We recommend the following test from our Partners.

National Testing Laboratory

Quick FHA / VA Kit (Bacteria: Total Coliform, E. coli., Iron, Manganese, Lead, Nitrate, pH, and Turbidity

The Quick FHA/VA testing package is designed for FHA/VA-required testing when there are no specific local or state testing requirements. You should always check with your local health department prior to testing”.
Order Test Kit


Quick Water Check Basic - Bacteria (Total Coliform and E. coli.), 22 heavy metals & minerals, 7 inorganic chemicals, and 5 physical factors 

The kit includes all the testing of the FHA/VA package, but covers more heavy metals, minerals, and inorganic parameters. “You should always check with your local health department prior to testing.”
Order Test Kit


Water Check Deluxe - Informational Testing Package for Well Water  

The “WaterCheck™ Deluxe is a comprehensive informational water analysis designed for the homeowner whose drinking water comes from a private well or spring. This water testing package tests for 107 items and is a more comprehensive version of the standard analysis adding 20 pesticides, herbicides, and PCBs.” 
Order Test Kit

Tap Score Laboratory

Certified Home Loan Water Test (Total Coliform, E. coli., Nitrate and Nitrite, Arsenic, and Lead) (Standard)
Order Test Kit


Certified Home Loan Water Test (Total Colifor, E. coli., Nitrate and Nitrite, Arsenic, and Lead)) (Rushed)
Order Test Kit


Upgraded Home Loan Water Test  (over 51 parameters, which include Alkalinity, conductivity, Total Dissolved Solids, 23 metals, 13 inorganic non-metals, Nitrate and Nitrite, Total Hardness, and some water indices.
Order Test Kit


Hanna Instruments Waterproof pH/EC/TDS Temperature Meter
Hanna Instruments Combination pH/ORP/Temperature Tester


Private Drinking Water Well Programs in Your State

FHA Single Family Housing Policy Handbook

Title 40- Protection of Environment
Chapter 1- EPA, Subchapter D- Water Programs, Part 143 other, Subpart B (lead)

Additional Info

When Buying A New Property, Remember: It’s Location, Location, And Water