Lead Testing in Drinking Water - What Child Care Providers Need to Do

Schools will collect drinking water samples from all taps that are currently or reasonably expected to be used for drinking or cooking in the buildings they own, control and operate. To simplify the testing process, the Health Department recommends that schools collect water samples for licensed child care programs that operate in their school.

However, it is the responsibility of the child care to be sure the law’s requirements for their facilities are met. This includes ensuring that taps within the child care area are tested, and that any taps found to have levels at or above 4 ppb are addressed.

The child care provider is also responsible for notifying their program’s parents, guardians and staff at least 5 days before water sample collection begins, and within 10 business days of receiving results from the lab.

Child care providers should talk to school administrators (principals and facilities managers) to be fully aware of the school’s plans and schedule for:

• collecting the water samples
• notifying parents, guardians and staff after receiving results
• implementing any required remediation plans

Child care providers may also ask to review the school’s tap inventory to ensure that taps in the child care areas are clearly identified in the location description.

Taps in your facility that are used for drinking, cooking, food prep, making bottles and brushing teeth must be tested every three years according to the schedule in the rule. 

To order lead in drinking water test kits for three-year testing, you’ll need to do a tap inventory and fill out an online form. You will receive an email from the Vermont Department of Health ([email protected]). The email will have the list of taps that were tested three years ago, which serves as your tap inventory. The email will also have a link to an online order form.

First, follow the instructions in the email to confirm whether these taps are still used for drinking, cooking, food prep, making bottles and brushing teeth, and if there are additional taps in your facility that need to be tested for the first time. Make sure you save the tap inventory for later. It will help when you’re collecting water samples.

You'll be collecting two samples at each tap—a “first draw” and a “flush.” Fixtures that have multiple taps (such as a sink with a faucet and a drinking fountain, or bottle fill station and drinking fountain) are called “combo fixtures.” You'll need to do two first draw samples, but only one flush sample. For ice machines, you will need to collect one first draw sample only.

Next, submit your order for test kits using the link to the online form in the email you received.

If you have any questions, please email [email protected].

These instructions are for lead in drinking water testing only. If you have a private drinking water source (drilled well, dug well, or spring) and need to order test kits for your six-year inorganic chemicals testing, you will need to complete a different order form. Information for this testing will be available on the Health Department website soon.  

See photo examples of fixture types

Sample bottles will be mailed to you. As soon as you get the box of sample bottles you’ll need to send a letter and an informational sheet to parents, guardians and child care program staff. Collect water samples 5 days after you send the notification. If you are a child care provider operating in a school, you are responsible for notifying parents, guardians and staff 5 days before the school begins collecting samples. We encourage you to talk to school administrators (for example principals and facilities managers) about the school’s schedule for collecting water samples.

The letter should include:

• your scheduled sample collection week
• why you’re being asked to test
• the requirements for testing
• the health effects of lead and other sources of lead (included on the informational sheet)
• how you will notify parents, guardians and staff about the results
• how you will respond to results that are at or above the action level

We have created a letter template and informational sheet with all of the elements listed above for you to use. They are translated into nine languages and posted below.

The yellow highlighted sections in all capital letters on the letter template (for example, DATE, CHILD CARE PROGRAM NAME, etc.) will need to be edited by you before sending out the letters.

Download the letter template
Download the informational sheet
Download translated versions of the letter template and informational sheet

In the box of sample bottles, you will find:

• pre-labeled sample bottles for each tap listed on your tap inventory
• a Water Sample Worksheet
• instructions on how to collect water samples
• return shipping instructions

You will need to collect two samples at each tap—a first draw and a flush. There is a unique Lab ID # on each line of the Water Sample Worksheet and a corresponding sample bottle with a matching Lab ID #. First draw sample bottles have a "FIRST DRAW" sticker on them, and flush sample bottles have a "FLUSH" sticker on them.

For combo fixtures (for example, a sink with a faucet and a drinking fountain or bottle fill station and drinking fountain), you will need to collect two first draw samples—one from each tap— but only one flush sample. The flush sample should be from the tap that is easiest to flush for 30 seconds. For ice machines, you will need to collect one first draw sample only.

Collect samples first thing in the morning after the water has been sitting in the pipes for 8 to 18 hours. Make sure you collect all of the samples before the water starts being used for the day. Don’t sample the first day back after a weekend, holiday or vacation.

Collect all samples from the taps listed on Water Sample Worksheet. Starting closest to where the water enters the building, collect all first draw samples first. Then go back and collect all flush samples.

Follow the instructions on how to collect water samples that are included in the box. Fill out the Collection Date and Collection Time (note AM or PM) on the Water Sample Worksheet for each sample.

Download instructions on how to collect water samples

Return your samples within 3 days of collecting your water samples.

• Screw the caps on tightly.  
• Pack the samples and the Water Sample Worksheet securely in any box(es) using packing material to make sure they don’t move around. 
• Seal the box with packing tape.
• Follow the return shipping instructions that were included in the box.

You will receive your results by email 8 to 12 weeks after the samples have been received by the lab.

All results will be posted on the Results Website one week after you receive them by email. Please note that results for a tap used by a licensed child care program that operates in a school may be listed under the school’s name.

If all of your results were BELOW 4 ppb, the only thing you need to do is complete Step #3 of this section. You may still choose to remediate taps with results below 4 ppb, however this is not required by law. Please note that there is no safe level of exposure to lead. The Health Department recommends that lead levels in water be as close to zero as possible. If you choose to complete voluntary remediation, enter the information ANR Online. These voluntary remediation actions will be posted to the Results Website.

go to the lead in drinking water results website

If any lead levels are found to be at or above 4 ppb, you are required to immediately stop using that tap for drinking, cooking, food prep, making bottles and brushing teeth.

Below are the immediate remediation actions you can take while you are figuring out the best permanent remediation action. Record these actions in the green section of your tap inventory and on ANR Online (see Step #3).

• Remove the fixture from service, which means to physically remove the fixture OR valve off the fixture by accessing the supply piping and shutting off the flow of water to the fixture.
• Post a sign that says, “Do Not Drink” or “For Handwashing Only.” Download "Do Not Drink" and "For Handwashing Only" signs
• Install a point-of-use filter after consulting with the Department of Environmental Conservation. Contact Josh Gravlin at 802-261-1360 or [email protected].

Download the Remediation Guidance

ANR Online is the system that tracks all lead in drinking water results and remediation actions. This information is searchable by the public on the Results Website.

First, you’ll need to create an account. Please use the same email address you provided when you submitted your tap inventory so your account can be linked with the correct school or schools. Then, you’ll need to enter the immediate remediation actions taken on all taps that had lead levels at or above 4 ppb.

See instructions on how to submit your Remediation Plan on ANR Online
Go to ANR Online

The best remediation action depends on the results for that tap and whether the first draw sample, flush sample, or both samples were at or above 4 ppb.

Below is a list of the remediation actions. For more details, see the Remediation Guidance starting on page 2. If you need to consult with the Department of Environmental Conservation (DEC), contact Contact Josh Gravlin at 802-261-1360 or [email protected].

Permanent FIXTURE Remediation Actions:

• Fixture Removal (you must physically remove the faucet or fountain and cap the supply pipes. Sink basins can stay in place so there aren’t holes in the countertop.)
• Fixture Removal – new fixture installation in other location (for example, centrally located bottle fill station installation)
• Fixture Replacement
• Point-of-use filter installation (after consultation with DEC)

Permanent PLUMBING Remediation Actions:

• Internal plumbing replacement or bypass
• Service line replacement
• Automatic flushing device installation
• Point-of-use filter installation (after consultation with DEC)
• Treatment Installation/Optimization (after consultation with DEC)

Download the Remediation Guidance
Download the Plumbing Profile Questionnaire
See instructions on how to submit your Remediation Plan on ANR Online

NOTE: If all of your results were BELOW 4 ppb, the only thing you need to do is complete Step #3 of this section. You may still choose to remediate taps with results below 4 ppb, however this is not required by law and there is no remediation funding for taps below 4 ppb. If you choose to complete voluntary remediation, enter the information in ANR Online. These voluntary remediation actions will be posted to the Results Website. Any fixture replacements will still require follow-up testing to make sure lead levels are below 4 ppb.

You’ll need to send a letter to parents, guardians and staff of the results within 10 business days of receiving your results.

For licensed child care programs that operate in a school, the child care provider is responsible for notifying their program’s parents, guardians and staff within 10 business days of receiving results from the lab. Therefore, we highly encourage you to talk to school administrators (principals and facilities managers).

We created letter templates for you to use. One is to use when all results were BELOW 4 ppb and the other is to use when one or more results were AT OR ABOVE 4 ppb. They are translated into nine languages and posted below.

The yellow highlighted sections in all capital letters on the letter template (for example, DATE, CHILD CARE PROGRAM/FACILITY, etc.) will need to be edited by you before sending out the letters. You may also include any additional information you want to share with your community. We recommend including the test results in the letter. You can do this by copying and pasting the summary of results table from your results email. We also suggest including the name of your program as it’s written above the table. That is the name used on the results website and will make it easier for parents, guardians and staff to find the results.

Download the BELOW 4 ppb letter template
Download the AT OR ABOVE 4 ppb letter template
Download translated versions of the letter templates

Please note that all results will be posted on the Results Website. Results for licensed child care programs that operate in a school may be listed under the school’s name.

Child care providers are required to submit a Remediation Plan. This is done through ANR Online. Follow these steps:

1. Sign in to ANR Online.
2. Enter your child care provider’s name.
3. Select the planned permanent remediation action for each tap.
4. Record your permanent remediation actions in the green section of your tap inventory.

By entering this information on ANR Online, you are submitting your Remediation Plan.

Download the Remediation Guidance
See instructions on how to submit your Remediation Plan on ANR Online

If the permanent remediation action you did was anything other than permanently removing the fixture, you are required to make sure that any remediation action you took has lowered the lead levels of that tap below 4 ppb.

Follow-up testing information and kits will be sent to you automatically once you have entered all of your permanent remediation actions.  See the next section “Follow-up Testing” for step-by-step instructions.

Once you have recorded your permanent remediation actions in ANR Online for all taps that were at or above 4 ppb, you will receive an email notifying you that you are ready for follow-up testing. 

• Your child care program will be sent follow-up test kits 1 to 3 weeks after getting the email notification. They will be sent to the same shipping address where your initial kits were sent. 
• The tap inventory included in the email will list which taps need to be re-tested. 

After getting the email notification, begin flushing the taps that will need to be re-tested. For 3 weeks, turn on the taps to run water through the new fixtures or plumbing for a few minutes twice per day every day until the day you begin collecting samples.

Follow the instructions on how to collect samples.

The tap information on the Water Sample Worksheet will already be filled out by the Lab. You will need to:

• Locate the tap that needs to be tested.
• Match the Lab ID # that's on the form to the sample bottle with the same Lab ID #. First draw sample bottles will have a "FIRST DRAW" sticker on them, and flush samples will have a "FLUSH" sticker on them.
• Follow the instructions that come with the sample bottles.
• Fill out the Collection Date and Collection Time (note AM or PM) on the Water Sample Worksheet for each sample.

Return your samples within 3 days of collecting your water samples.

• Screw the caps on tightly.  
• Pack the samples and the Water Sample Worksheet securely in any box(es) using packing material to make sure they don’t move around. 
• Seal the box with packing tape.
• Follow the return shipping instructions that were included in the box.

You will receive your results by email 8 to 12 weeks after the samples have been received by the lab.

• If the result is below 4 ppb, no further action is required.
• If the result is at or above 4 ppb, then go back and re-do Steps #4 – 7 under the Results and Remediation section above. Consult with the Department of Environmental Conservation (DEC) for help in determining the next best remediation action. Contact Josh Gravlin at 802-261-1360 or [email protected].

Follow the instructions to notify parents, guardians and staff of results within 10 business days of receiving the follow-up test results from the lab.