Lead FAQ for Child Care Facilities

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Also see the EPA’s Glossary of Terms.

COVID-Related

My facility is now open after an extended period of closure that resulted in non-routine operations. Can I collect my samples right away?

No, you must wait 2-3 weeks to establish a normal usage before collecting.

Can I complete this testing while my facility is closed?

No, you must wait until your facility is open and operating for at least 2-3 weeks with normal water usage.

About Lead

What is lead?

Lead is a toxic heavy metal. Although lead is naturally occurring, it can be very dangerous.

Where can lead be found?
  • Drinking Water
  • Lead based paint in homes
  • Lead based paint on toys and costume jewelry
  • Dust or contaminated soil which then goes into the air (from the paint chips)
  • Lead-glazed ceramics
  • Imported foods, candies, or foods in cans
  • Hobbies such as refinishing old furniture, working with car batteries or home repair
  • Firearms with lead bullets
How does lead get into your body?

Lead gets absorbed into the body numerous way; breathing air contaminated with lead dust or lead fumes, swallowing lead contaminated paint chips, or drinking water. Once lead enters our body it is then stored in our bones, blood, and tissues. Repeated exposure to lead causes lead to accumulate in our bodies which keeps us continuously exposed. Young children, including infants and fetuses are more vulnerable to lead because they have a higher absorption rate.

Why is lead dangerous?

Lead levels can have a detrimental impact on children causing many physical and behavioral effects. These effects include damage to their nervous systems, learning disabilities, impaired hearing, behavior dysregulation, slowed growth, anemia, and hyperactivity. If the lead is accumulated in a pregnant woman, it can impact the fetus and result in reduced growth and premature birth. There is no known safe level of lead.

How does lead get into drinking water?

Lead enters drinking water from a contaminated water supply and/or due to corrosion in the pipes. Corrosion is when the pipes break down and/or dissolve creating a chemical reaction that occurs inside the plumbing. This allows lead to leach into the water supply.

What should I do if I think my family has been exposed to lead in drinking water?

Contact your health care provider.

Should families or staff test their home’s water for lead?

It is recommended that all families test their home drinking water for lead. NYS offers a free pilot program where families can test their home for lead in their drinking water. To find out more about this program, check out the Free Lead Testing Pilot Program offered by the DOH.

Do water filters remove lead?

There are water filters that can remove lead but not all water filters do. The EPA has detailed information on which filters to use: A Consumer Tool for Identifying Point of Use Drinking Water Filters Certified to Reduce Lead

Program/Eligibility

Do I pay for anything?

The lead testing in drinking water program pays for an approved facility’s lead testing for drinking water as well as follow-up testing at the facility. This includes the shipping and handling of all samples. This program does not pay for your time to collect the sample, any educational material that you wish to print for your facility, or for any remediation (e.g. lead service line replacements).

Is this an OCFS requirement?

This program is voluntary. Lead cannot be detected through smell or taste, so testing is the only way to know if lead is present in your drinking water.

I am applying for a license and have a private well which needs testing, can I still apply for this program?

You must already be licensed or registered with OCFS to apply for this opportunity. However, when testing your well prior to licensing, it is best practice to request lead testing for your drinking water. To find out more information about well water, please visit the EPA’s webpage on Private Drinking Water Wells.

My facility is located inside a school; do I still need to test?

New York State Public Schools and Boards of Cooperative Educational Services (BOCES) are required to test for lead in their drinking water per regulation, Subpart 67-4 Lead Testing in School Drinking Water. They are also required to act if they have elevated lead levels at or above the actionable level. To find the test results of your school, refer to the DOH Lead Testing of School Drinking Water page.

My facility is located inside a building (ex. Church) or rented space; can I still test?

You are eligible to request testing from this program. It is recommended that you test your drinking water for lead even if you are in a rented/borrowed/leased space. Please work with your property owner regarding this program.

What can I do if I am not a licensed or registered facility?

NYSDOH has a free lead test pilot program for homeowners where New York State homeowners can get a free lead test. You can also check your Public Water System's Annual Water Quality Report.

Sample Collection

What is a fixture manifest?

This is a will be a blank template that you fill in listing all the water outlets that you are going to be testing with identifying information. OCFS will send the fixture manifest with approval via email.

What is a chain of custody form?

For this program, a chain of custody form is a legal document that tracks the handling of sample containers. This will pre-filled by the laboratory, New York Environmental using data from your request form. You must record date of collection and if desired, observational notes of the outlet such as automatic sensors, odors, change in water color, low pressure, water leaks, irregular water spray, presence of an in-line filter, whether the outlet aerator has been removed, or if the water becomes hot/cold after turning on the cold water.

Does someone come into my facility?

No one will enter your facility for sample collection. The samples will be collected by the child care facility. Chain of custody forms will be used regarding collection monitoring data and an instruction sheet will be mailed with the sample kit. The sample collector should be confident in their understanding of collection directions, the chain of custody forms and must watch, understand, and attest that they have completed the required training video.

Who collects the samples?

A responsible member of your facility will collect the samples. It is required that this person understands the EPA’s 3Ts for lead testing in water guidance manual and follows all the instructions supplied by the lab. The sample collector must watch and understand the collection training videos. This includes correctly completing the chain of custody forms. Refer to the EPA's instructions from the 3Ts module 5 on collecting samples.

Do I need to test ALL my water?

It is recommended that you test all potable water outlets that could reasonably be used for drinking and or cooking.

I am in a school. Am I responsible for collecting the sample?

Facilities located within schools are not eligible for this opportunity. It is best to work with your building’s administration to guarantee that the water outlets in your classroom have been tested.

What taps or water outlets do I NOT need a sample from?

Any water outlet that would not be reasonably used for drinking and/or cooking. This could include a trough sink in a garage, eye wash stations, and showerheads (the CDC has stated that human skin does NOT absorb lead in water therefore it is considered safe to use a shower with an elevated lead level).

What does first draw mean?

A first draw is a sample collection of water that has been sitting motionless, inside the interior plumbing with a stagnation period of at least 8 hours, but no more than 18 hours. This represents the first use of consumption that would occur if you weren’t collecting the water in a sample bottle.

What does flush mean?

A flush sample is also known as 2nd draw. This is a collection of water that is tested after a “flush” to the system. The collection of water is taken after a 30-second flush of the water pipes. This can identify lead in the plumbing behind the fixture. In a two-step sampling process, the sample collector collects the first draw first, then the flush (2nd draw) sample after.

What is a tap and a fixture?

A tap is where you would most commonly pour “tap” water- it is where the water comes out of the faucet. A fixture is considered the mechanical part where the actual plumbing pieces are located.

I have a sink that has both a water fountain and a bottle filler, do I need to test both?

This is called a combination fixture. You need to test both water outlets in the first draw. Make sure to note this on your fixture manifest.

How do I apply for my sample containers?

Submit the OCFS request form. OCFS will then review your request and if approved, you will receive instructions on the next steps, including how to request sample containers.

What if I forgot some taps and have already ordered or sent in my samples?

Please email OCFS at ocfs.sm.watertest@ocfs.ny.gov.

How do I get my samples to the lab?

A prepaid mailing label will be provided with your sample kit. Samples can be returned by ordering a pickup from the USPS or by normal mailing procedures (i.e., mailbox utilization). Please note you must return your samples within one week of receiving your kits from the certified laboratory and within 36 hours of sample collection.

What needs to be included in the box before sending it back?

Your sample containers and the original copy of the chain of custody forms.

I didn’t receive a return label, what do I do?

Please contact the laboratory via email at requests@nyenvironmental.com.

What is a Field Reagent Blank (FRB)?

FRBs are used to determine whether the container type, field conditions (facility environment) or other sample transport procedures contaminated samples. A Field Reagent Blank (FRB) consisting of reagent water placed in a sample container will be supplied by the laboratory in each sample kit and will be treated as a sample in all aspects, including shipment to the sampling site, exposure to the sampling site conditions, storage, preservation, and all analytical procedures. Child care facilities will follow the instructions on the sample collection instruction sheet for this. Facilities will merely open the container, then close it up again after a set amount of time determined by the laboratory. The FRB then ships with the other samples.

Results

What is an action level?

This term was created by the EPA from the “Lead and Copper Rule” which was established from the Safe Drinking Water Act (1991). This rule limits the concentration of lead and copper that is allowed in the public drinking water supply. It also sets a limit on what lead and copper levels are allowed coming from the plumbing to the outlet. The limitation to that amount is called an Action Level. Simply put, if the lead level goes over this limit, there must be Action taken. This could be remediation such as replacement of lines, or the instillation of a point of use (POU) filter. The EPA has an action level of 15 ppb, or parts per billion. This can also be shown as 0.015 mg/L or milligrams per liter. However, even if your results are not at or above the action level it is important to note that there are no known safe levels of lead.

What can I do if the results show I have lead?

Remove these water outlets from use, post signs around the outlets to inform staff, families, and children that this water is not safe for drinking or cooking or remove the outlet physically. Printable signs created by NYS DOH are available. Once the effected water outlets have been removed from use, Point of Use (POU) systems or filters for water can be used. Another option is to bring in bottled water for drinking, cooking, and preparing infant bottles. Do not return these water outlets to use until they have been retested and have results below the action level. Reminder: There are no known safe levels of lead. The last option would be to replace any lead-based pipes in your facility. It is OCFS’s intent to work with programs in creating an acceptable remediation plan, as well as offer free follow-up testing.

My results said I don’t have lead in my water, do I need to retest?

No. If you don’t have lead levels at or above the action level it is not required that you retest. However, it is recommended that you test at least once per year, or at a timely increment during your facility’s span in the building, as plumbing and pipes can corrode over time.

Can I drink my water if my results show lead levels are present?

OCFS requires that if you have results that show a water outlet at or above the action level, you must remove that outlet from use until remediation, resampling, and retesting occurs with results under the action level. Removal of the outlet could be done by placing a ‘keep out of use’ sign over the outlet or the physical removal of the outlet. If you have lead levels in your water, the CDC recommends using bottled water for your drinking, cooking, and preparing infant formula or using a water filtration system that is certified to remove lead from water. This is especially important if you have children or pregnant women in the facility. It is also not recommended that animals or pets drink any water that is contaminated with lead.

How long does it take to get results?

You should receive your results within fifteen days from the day the laboratory received your sample kit. Your results will be emailed to you unless specifically requested to be mailed. If you would like to request mailed results you must contact NYE at requests@nyenvironmental.com.

I still haven’t received my test results, what do I do?

Due to the ongoing COVID response and impacts, there may be a delay in the return shipping of samples and or the mailing of results. If you have not received your results by day 20, please email OCFS at ocfs.sm.watertest@ocfs.ny.gov.

Do I need to tell OCFS my results?

No. The laboratory will provide OCFS with your results.

Where are the results being posted?

The results of your facility’s lead testing in drinking water will be posted on the OCFS website.

What happens if my results are over the action level?

If your facility has elevated lead levels which put your levels into “action” level, you are required to stop use of the affected outlets immediately and begin remediation. OCFS can support facilities in the planning of remediation. Please contact us at ocfs.sm.watertest@ocfs.ny.gov for support.

What does it mean if my first draw result is over the level, but the 2nd Draw (flush) sample result is not?

This could mean the source of lead is the fixture itself.

What does it mean if the first draw result is not over, but the 2nd Draw (flush) sample is?

This could mean the source of lead is the plumbing.

What does it mean if both the results from first draw and 2nd Draw (flush) are over the action level?

This could mean the source of lead is coming from both plumbing and fixtures.

What happens if lead is found in the water, but it is below the action level?

There is no action to be required. You may use the outlets which are shown with results below action level. Please be advised however that no level of lead is safe.

Follow-up Testing

My water outlets have been remediated, what do I do now?

Email your fixture manifest, with marked outlets for follow-up to OCFS. Follow-up testing will be provided to approved facilities at no cost and OCFS will accept requests for follow-up testing until September 1st, 2023. Please email OCFS at ocfs.sm.watertest@ocfs.ny.gov.

When will I receive my follow-up sample results?

Follow-up samples will follow the same procedures outlined above.

Do I need to tell OCFS my follow-up results?

No. The laboratory will provide your results to OCFS. However, OCFS will support providers in creating a plan for remediation; if your program would like support, please send an email to ocfs.sm.watertest@ocfs.ny.gov.

Remediation

Do I have to pay for remediation?

The Lead Testing in Drinking Water Program at Child Care Facilities Program offers free testing only. Remediation costs are the responsibility of the facility/provider. It is OCFS’s intent to work with programs in creating an acceptable remediation plan, as well as offer free follow-up testing.