Your Filter First Drinking Water Management Plan: What Michigan Schools Need to Know Before August 31

If you've been working through Michigan's Filter First requirements this spring, you've probably run into the Drinking Water Management Plan requirement and wondered exactly what it takes to get one done right. You're not alone. The DWMP is one of the pieces districts are most likely to have incomplete heading into summer, and it's also one of the pieces that needs to be in place before you can confidently certify your compliance status in MiEHDWIS by August 31.

Here's a plain-language breakdown of what the DWMP is, what it needs to cover, and where districts tend to get stuck.

What Is a Drinking Water Management Plan?

The Drinking Water Management Plan is a building-level document required under Michigan's Clean Drinking Water Access Act (2023 PA 154). It lays out how your facility identifies, monitors, and reduces exposure to lead and other contaminants in your drinking water system. Along with filter installation and post-installation water testing, it's one of the three core things Filter First requires.

Think of it as a living record of your building's drinking water setup. It documents your fixtures, your filters, your maintenance schedule, how you handle water stagnation, and how you communicate water quality information to staff and families. EGLE and MiLEAP have both provided a DWMP template to help districts structure their plans, and using it is strongly recommended since it's built around what the state expects to see.

What the Plan Needs to Cover

Every building's plan will look a little different depending on its plumbing and how it's used, but a compliant DWMP generally needs to address the following areas:

Fixture Inventory

This is your complete list of every water source in the building. That means every drinking fountain, bottle filler, food prep sink, handwashing sink, and anything else that delivers water. Each one needs to be identified by location and fixture type, and you need to note whether it has an approved filter installed. The fixture inventory is the foundation everything else in the plan gets built on, so if it's not accurate, the rest of the plan isn't either.

Filter Documentation

For each consumptive source, the plan should document what filter is installed, what certification standard it meets (NSF/ANSI 53 for lead reduction, NSF/ANSI 42 for particulates), when it was installed, and when it needs to be replaced. EGLE maintains a list of approved filter products. If you're using something that isn't on that list, it won't count toward your Filter First compliance.

Sampling Plan

Post-installation water testing is required after filters go in, and annual sampling for schools is coming down the road as part of future certification requirements. Your DWMP needs to document which outlets you'll sample, how sampling will be done, and how you'll track and share the results.

Flushing Procedures

Schools see extended periods of low water use over summers, weekends, and breaks, and stagnant water in pipes can cause lead levels to spike. Your plan should describe how your buildings handle flushing before students return, especially at the start of the school year. This is a straightforward piece to document, but it's easy to overlook.

Communication Plan

Filter First includes a public notification piece. Your DWMP should spell out how your district communicates water quality information to parents, staff, and the community, including filter installation status and any sampling results.

Roles and Responsibilities

Someone has to own this at each building. Your plan should name who is responsible for keeping the DWMP up to date, scheduling filter replacements, coordinating sampling, and handling communication. Without a clear owner, plans tend to drift out of date within a year or two.

A Few Rules Worth Knowing

Where Districts Are Getting Stuck

Based on what we're seeing with Michigan school districts this spring, a few common problems are slowing things down:

• 1 No fixture inventory completed. You can't write a compliant DWMP without knowing exactly what water sources are in each building. A lot of districts haven't done a formal room-by-room inventory yet, which means they're missing the data they need to get started.
• 2 Plans written before installation was finished. If your DWMP was drafted in 2024 or early 2025, it may not reflect what was actually installed. Filter models, installation dates, and outlet locations that changed during installation all need to be updated in the plan.
• 3 One district-wide document instead of building-specific plans. Certification in MiEHDWIS happens at the building level, and the DWMP requirement follows the same logic. A single district document isn't going to cover it.
• 4 No designated owner at the building level. Plans without a clear point person tend to go stale fast. Figure out who owns the DWMP at each building and make sure they understand what's expected of them going forward.

How ETC Can Help

We've been helping Michigan school districts and child care facilities work through drinking water compliance for over 35 years. We can take the DWMP piece off your plate as part of a full Filter First compliance package, including:

• ✓ Fixture inventories — Room-by-room documentation of every consumptive and non-consumptive source in your buildings, with a gap analysis against the 1-per-100 requirement.
• ✓ Drinking Water Management Plan development — Whether you're starting from scratch or need to update a draft, we build accurate, compliant plans that align with EGLE guidance and the state template.
• ✓ Post-installation water testing — EGLE-certified sampling and lab analysis after filter installation, with complete documentation and results reporting.
• ✓ Ongoing annual testing — We handle scheduling, sampling, and recordkeeping so your district stays current year after year without the administrative headache.