EDF submits comments on Oregon’s proposed rules for lead testing in child care centers

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

EDF recently submitted comments to the Oregon Department of Education’s Early Learning Division regarding the state’s proposed rules for lead testing for water in licensed and regulated child care centers.

Children are particularly vulnerable to lead exposure: even very low blood lead levels can impair normal brain development, contribute to learning and behavioral problems and lower IQs.

While national attention on lead in drinking water has spurred action to address lead in schools, fewer states have addressed lead in water in child care settings – even though these centers serve children at their most vulnerable ages.

In October 2017, Oregon’s Governor Kate Brown directed the Early Learning Council to begin rulemaking to require that state licensed child care facilities undergo lead testing – reversing an earlier decision from the Council to not mandate testing. Oregon is one of six states that EDF has highlighted in a previous blog focusing on child care lead in water testing requirements.

Oregon’s draft rules would require all licensed and regulated facilities to test for lead once every six years using a state Health Agency-accredited laboratory and take mitigation actions if levels at or above 20 parts per billion (ppb) are detected.

While we commend Oregon for being a leader in this space, our comments encourage Oregon to make a number of changes to strengthen the final rule:

  • Incorporate lead service line (LSL) investigation. When present, LSLs are the largest source of lead in water – and can unpredictably release lead particulates into water. If identified, the facility should work with the local water utility to remove the LSL.
  • Use a more protective action level. The proposed action level of 20 ppb is not based on science or health. Results from an EDF pilot project suggest that 3.8ppb is an achievable action level.
  • Provide for additional lead remediation options. Facilities should take a tiered approach to corrective action, where stricter action is triggered by higher and more frequent lead readings.
  • Require follow-up testing after corrective action. Where initial results are above the established action level, a facility should conduct follow-up testing within three months and facilities with high levels should be subject to more frequent testing.

Check out our full comments for all of the details.

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