Protecting the most vulnerable: Lead in drinking water testing requirements for child care facilities

Lindsay McCormick, Project Manager and Tom Neltner, J.D.Chemicals Policy Director

[Updated April 2018] 

Children under the age of 6 are most vulnerable to the detrimental impacts of lead exposure. Even at low levels, lead exposure can harm the brain development of young children – resulting in learning and behavioral problems for the rest of their lives.

The recent national attention on lead in drinking water and reports of high levels in certain schools has spurred action to address the problem in schools. As a result of state-level requirements and voluntary state programs, many schools across the country are testing their drinking water for lead and taking actions to fix problems.

In contrast, child care (also called day care or early childhood education) has gone relatively unnoticed – even though such facilities serve children at their most vulnerable ages.

However, several states and cities have or are developing proactive programs requiring testing for lead in child care facilities’ drinking water and mandating action when high levels are found. Six states – ConnecticutIllinoisNew JerseyOregonRhode Island, and Washington – and one city – New York City– require licensed child care facilities to test their drinking water for lead.

Click here for more information on each requirement, including the types of facilities covered, frequency of testing, and relevant resources.

The requirements vary widely in terms of testing protocol, standard, corrective action, and notification to parents. Several of these differences deserve attention.

Each of the requirements takes a different approach to the standard used for testing – the lead level at which corrective action and/or notification is required. Connecticut, New Jersey, New York City, and Rhode Island use 15 parts per billion (ppb). Washington specifies 15 ppb in the quality standards for early learning programs, but uses 20 ppb in practice, and Illinois will likely use 2 ppb, though the current draft directive states that action is required “if lead is present” as detected by an approved laboratory.

These standards are not based on the health risk to children. In an earlier blog, we provide an assessment of a health-based benchmark for lead in drinking water. We derived our assessment from a recent EPA scientific analysis and suggest levels that would be more protective than EPA’s current guidelines.

Communicating with parents is a significant part of any testing program for lead in child care facilities, and EDF favors a transparent approach to testing. Not all of the regulations require notification of parents about testing results. New Jersey, Oregon, and Washington require notification of parents if the facility finds elevated levels of lead. Illinois, New Jersey, and Oregon also require posting the results inside the facility. All testing information and mitigation efforts must be provided in enrollment materials in Illinois. New York City goes even further and makes all results available in an online database (Child Care Connect) that allows parents to search records for any licensed child care program in the city.

In addition, the types of facilities covered by the requirement varies significantly. We provide those details here. In general, the requirements do not apply to unlicensed facilities, which often includes small family child care facilities based in a caregiver’s home.

With the renewed attention on lead in drinking water, we encourage other states to adopt requirements to better protect children from lead exposure in child care facilities.

 

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