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

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

girl drinking from water bottle

Lead in drinking water testing is now available to child care providers for initial and post-remediation follow-up samples. To submit a request for lead in drinking water testing materials, please contact your Department of Children and Families, Child Development Division (CDD) Licensing Technician. 

Why Test for Lead

While a major source of lead exposure in Vermont children is paint, lead in older plumbing and fixtures can add to a child’s overall lead exposure.

Lead exposure poses a special risk to young children because they absorb lead into their systems more easily than adults do. Lead can slow down growth, impair development and learning, and can cause behavior problems.

To address these risks, Act 66 (2019) requires all Vermont schools and licensed or registered child care providers to test their drinking and cooking water for lead. If lead is found in an amount at or above the action level of 4 parts per billion (ppb), the school or child care provider must immediately take the fixture out of service and take steps to eliminate or reduce the amount of lead to below 4 ppb.

go to the lead in drinking water results website

Who is affected

Some child care providers may have already tested their drinking water under current child care regulations. Because the new law requires standards for lead in drinking water testing that are different from what is required in the child care regulations, all child care providers—including those that have already tested—will need to test for lead under the standards of the new law. The child care regulations will be updated to match the new law.

The State of Vermont will cover all testing costs. The State will also reimburse for the actual costs to replace fixtures up to a certain amount.

What happens next

If you are a child care provider applying for a new license, your CDD licensing technician will call you to collect information about which taps you use for drinking, cooking, food prep, making bottles and brushing teeth, to confirm your contact information, and to order your drinking water test kits. If you are a current provider and need to do lead in drinking water testing, please contact your CDD licensing technician.

Below you will find step-by-step instructions, instructional videos, and all the materials you will need to help you through this process. See Frequently Asked Questions

If you have any questions about this process, call the Lead in School and Child Care Drinking Water Program at 802-863-7220 or 800-439-8550 (toll-free in Vermont).

Child Care Providers operating in a school

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.

STEP-By-Step instructions
 

WATER SAMPLE COLLECTION

1. Complete a tap inventory and order test kits with your licensing technician.

It will be necessary to identify which taps you use for drinking, cooking, food prep, making bottles and brushing teeth to prepare for the call. Also, have contact information ready for who the sample bottles should be sent to and who should receive the test results.

The licensing technician will email you a copy of your completed tap inventory. Make sure you save the tap inventory to refer back to when you start collecting samples. A copy will also be included in the box with your sample bottles.

Download the tap inventory and example
See photo examples of fixture types
Watch Video 1 - How to Complete Your Tap Inventory

2. Send a letter and informational sheet to parents, guardians and program staff at least 5 days before you begin collecting samples.

You’ll need to send a letter and an informational sheet to parents, guardians and child care program staff at least 5 days before you begin collecting samples. 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 beginning of Video 2 - How to Collect Water Samples talks about how to notify your community.

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

3. Prepare to collect the water samples.

Sample bottles will be mailed to you. You'll be collecting two samples at each tap identified on the tap inventory—a “first draw” and a “flush.” The first draw sample collects the first water that comes out of the tap after a period of inactivity (between 8 and 18 hours). The flush sample collects water after the tap has been running for 30 seconds. See an example of a tap inventory

Water Sample Collection Information Forms will be included in the box of sample bottles mailed to you. There will be one for each sample. 

The tap information on the Water Sample Collection Information Form will already be filled out by the lab. Once you 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 green sticker on them, and flush samples will have a red sticker on them.

You will need to fill out the highlighted portion of the Water Sample Collection Information Form with the name of the person collecting the sample, any sampler’s comments, and the date and time the sample was taken. In the Sampler's Comments box, write if there is anything unusual or unique about collecting the sample or about the fixture.

To make collecting water samples easier, keep all first draw forms and matching bottles together and all flush forms and matching bottles together.

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

Watch Video 2 - How to Collect Water Samples

4. Collect water samples.

Sample bottles will be mailed to you. In the box of sample bottles, you will find:

  • A copy of your tap inventory
  • Pre-labeled sample bottles for each tap listed on your tap inventory. First draw bottles have green stickers on them, and flush bottles have red stickers on them.
  • Water Sample Collection Information Forms for each tap listed on your tap inventory
  • Instructions on how to collect water samples
  • UPS pre-paid return shipping label or courier information

As soon as you get the box of sample bottles:

  1. Notify parents, guardians and staff by following instructions in Step #2.
  2. Collect water samples 5 days after you send the notification.
  3. Follow the return shipping instructions in Step #5.

We created a video with step-by-step instructions and tips on how to collect water samples. Watch Video 2 - How to Collect Water Samples

Collect samples from all the taps listed on your tap inventory. Collect samples first thing in the morning after the water has been sitting in the pipes for 8 to 18 hours.

  • Collect all first draw samples first. For center-based child care facilities, start with taps that are closest to where the water comes into the building. If you have taps on multiple floors, start with the taps on the lower floors before moving up.
  • Then go back and collect all flush samples. For combo fixtures (for example, a sink with a faucet and a drinking fountain or a bottle fill station and a drinking fountain), you will collect two first draw samples—one from each tap—but only one flush sample from one of those taps. The flush sample should be from the tap that is easiest to flush for 30 seconds.
  • Follow the instructions that come with the sample bottles and fill out the remaining fields on the Water Sample Collection Information Form (date, time, name of the person collecting sample, and sampler’s comments).

Download instructions on how to collect water samples
Watch Video 2 - How to Collect Water Samples

5. Return samples to the lab.

Be sure the bottle caps are screwed on tightly and pack the bottles securely in any box(es) using packing materials to make sure they don’t move around. 

On the same day you collect your water samples, call UPS to schedule a pickup at your site or drop off the box(es) at a UPS Store. Water samples must reach the lab within one week of collection. Follow the instructions below, which are also included in the box:

  • Schedule a pickup or drop off the box(es) at a UPS Store Monday through Thursday (not on a Friday, a weekend, or a holiday).
  • Seal the box with packing tape and place the return shipping label on the box, covering the original shipping label.
  • If you are scheduling a pickup: Call UPS at 1-800-742-5877.
    • When calling UPS, say “schedule a pickup” to get a live representative.
    • Provide your tracking number and the date and the time you want the driver to do the pickup.
    • There is no cost for shipping. If you are asked to provide an account number, use the number provided in the return shipping instructions included in the box.

RESULTS AND REMEDIATION

1. Receive your test results.

You will receive your results by email 8 to 12 weeks after the samples have been sent via UPS.

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

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, ask your CDD licensing technician to enter the information for you online. These voluntary remediation actions will be posted to the Results Website.

go to the lead in drinking water results website

2. Complete immediate remediation actions.

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.

  • 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 Ben Montross at 802-498-8981 or ben.montross@vermont.gov or Catharine Bartone at 802-272-0411 or catharine.bartone@vermont.gov.

Download the Remediation Guidance
Watch Video 5 - How to Complete Remediation

3. Send a letter to parents, guardians and staff within 10 business days of receiving your results.

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 a video with step-by-step instructions and tips on how to notify your community. Watch Video 4 - Receiving and Sharing Results with Your Community

We also 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
Watch Video 4 - Receiving and Sharing Results with Your Community

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

4. Determine the best permanent remediation action.

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 Ben Montross at 802-498-8981 or ben.montross@vermont.gov or Catharine Bartone at 802-272-0411 or catharine.bartone@vermont.gov.

We created a video with step-by-step instructions and tips on how to complete remediation actions. Watch Video 5 - How to Complete Remediation

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
Watch Video 5 - How to Complete Remediation

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, ask your CDD licensing technician to enter the information for you online. These voluntary remediation actions will be posted to the Results Website.

5. Submit your Remediation Plan

Child care providers are required to submit a Remediation Plan. This is done by contacting your CDD licensing technician. Your CDD licensing technician will document your remediation plan online. You should also record your planned remediation actions in the green section of your tap inventory.

By providing this information to your CDD licensing technician, you are submitting your Remediation Plan.

Download the Remediation Guidance
Watch Video 5 - How to Complete Remediation

6. Take permanent remediation actions.

You are eligible for reimbursement when you remediate a tap that is at or above 4 ppb. You will be reimbursed for the actual cost of replacing a drinking water fixture up to a maximum amount. Receipts or invoices will need to be submitted to the Health Department. The maximum amount for each type of fixture is:

  • Public drinking fountains: $1,800.00
  • Taps used for cooking: $650.00
  • All other taps in child care settings: $400.00

Here is what you need to do:

  1. Complete all necessary work.
  2. Record the permanent remediation actions in the green section of your tap inventory.
  3. Keep all receipts and invoices to submit for reimbursement.
  4. Inform your CDD licensing technician of your permanent remediation actions. They will enter your remediation actions for you online.
  5. See the Cost Reimbursement section below for more details on how to submit a reimbursement request.

Download the Remediation Guidance
Watch Video 5 - How to Complete Remediation

7. Do follow-up testing.

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. See the next section “Follow-up Testing” for step-by-step instructions.

FOLLOW-UP TESTING

1. Order follow-up test kits for the taps that were at or above 4 ppb.

If the permanent remediation action you did was anything other than permanently removing the fixture, order follow-up test kits for the taps that were at or above 4 ppb.

  • Call your CDD licensing technician to order follow-up test kits.
  • Follow-up test kits and shipping costs to and from the lab are covered by the State.
  • Once the order is placed with the lab, sample bottles will be mailed to you within 2 to 3 weeks.
2. Flush the taps for 3 weeks before collecting water samples.

For 3 weeks, turn on the remediated 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.

3. Collect water samples.

Follow the instructions on how to collect samples (see Steps #3 – 4 in the Water Sample Collection section above).

The tap information on the Water Sample Collection Information Form will already be filled out by the lab. Once you 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 green sticker on them, and flush samples will have a red sticker on them.

You will need to fill out the highlighted portion of the Water Sample Collection Information Form with the name of the person collecting the sample, any sampler’s comments, and the date and time the sample was taken. In the Sampler's Comments box, write if there is anything unusual or unique about collecting the sample or about the fixture.

4. Return samples to the lab.

Be sure the bottle caps are screwed on tightly and pack the bottles securely in any box(es) using packing materials to make sure they don’t move around.

Return samples to the lab using UPS. A UPS pre-paid return label and shipping instructions will be included in the box of sample bottles sent to you. 

  • On the same day you collect your water samples, call UPS to schedule a pickup at your site or drop off the box(es) at a UPS Store. Water samples must reach the lab within one week of collection.
  • Schedule a pickup or drop off the box(es) at a UPS Store Monday through Thursday (not on a Friday, a weekend, or a holiday).
  • Seal the box with packing tape and place the return shipping label on the box, covering the original shipping label.
  • If you are scheduling a pickup: Call UPS at 1-800-742-5877.
    • When calling UPS, say “schedule a pickup” to get a live representative.
    • Provide your tracking number and the date and the time you want the driver to do the pickup.
    • There is no cost for shipping. If you are asked to provide an account number, use the number provided in the return shipping instructions included in the box.
5. Receive your follow-up test results.

You will receive your results by email 8 to 12 weeks after the samples have been sent via UPS.

  • 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 Ben Montross at 802-498-8981 or ben.montross@vermont.gov or Catharine Bartone at 802-272-0411 or catharine.bartone@vermont.gov.
6. Notify parents, guardians and staff of results.

Notify parents, guardians and staff of results within 10 business days of receiving the follow-up test results from the lab. Follow the instructions in Step #3 under the Results and Remediation section above.

COST REIMBURSEMENT

1. Save receipts and invoices for remediation actions.

Child care providers need to pay upfront for all costs associated with remediating taps that were at or above 4 ppb. After the remediation is complete, you can submit a reimbursement request.

Child care providers will be reimbursed for the actual cost of replacement—including parts and labor—of a drinking water fixture if an itemized invoice is received with the initial first draw Lab ID # written on it. (You can find the initial first draw Lab ID # by looking up your results on the Results Website and clicking on “Tap Summary Cards.”) The maximum amount for each type of fixture is:

  1. Public drinking fountains: $1,800.00
  2. Taps used for cooking: $650.00
  3. All other taps in child care facilities: $350.00
2. Submit reimbursement request to the Health Department.

It is recommended that each child care provider send one reimbursement request once all remediation has been completed, but multiple requests will also be accepted. Use the online Reimbursement Request to submit your request.

Before you begin, please make sure you can:

  • Send a copy of all receipts and invoices electronically (combining them into a single file is recommended, if possible). You will be asked to attach them when prompted. 
  • Enter total replacement costs by fixture (including parts and labor). 
  • Identify each tap you are requesting reimbursement for by its initial first draw Lab ID#.  You can find the initial first draw Lab ID# by looking up your results on the Results Website and clicking on "Tap Summary Cards."

    NOTE: The online form is easier to complete on a computer than on a mobile device.

    If you are unable to complete the request using the online form, you may use the Reimbursement Request document to submit your request instead. Mail this document with accompanying receipts and invoices to: 

    Vermont Department of Health
    Attn: Business Office
    PO Box 70
    Burlington, VT 05402
3. Receive your reimbursement.

Payment will be received within 30 days after the Health Department receives an error-free reimbursement request. If there is an error found, the Health Department will reach out to request a new one. The Health Department will use your State of Vermont Vendor ID to issue payment, which will be made in your preferred method of payment.

If you are unsure if you already have a State of Vermont Vendor ID, please email AHS.VDHAccountsPayable@vermont.gov.

Instructional Videos

Materials you will need

Phase of the Process Title Description
Water Sample Collection Photos of Fixture Types See images of the different types of fixtures for sample collection.
Tap Inventory / Results and Remediation Tap Inventory - Template and Example Use the blue section titled "Tap Inventory for Schools and Child Care Providers Testing for Lead in Drinking Water" for your tap inventory. To see an example of a completed tap inventory, click on the tab labeled "Example."
Water Sample Collection Notification Letter to Parents, Guardians and School Staff Use this letter template to send to parents, guardians and school staff at least five days before you begin collecting samples.
Water Sample Collection Informational Sheet - Lead Poisoning in Children Include this informational sheet with the notification letter sent to parents, guardians and school staff at least five days before you begin collecting samples.
Water Sample Collection How to Collect Water Samples - Instructions Follow these instructions to collect first draw and flush water samples. These instructions will be included in the box of sample bottles mailed to you.
Results Notification Letter to Parents, Guardians and Program Staff - Results BELOW 4 ppb Use this letter template to send to parents, guardians and program staff within 10 business days of receiving results that are BELOW 4 ppb.
Results Notification Letter to Parents, Guardians and Program Staff - Results AT OR ABOVE 4 ppb Use this letter template to send to parents, guardians and program staff within 10 business days of receiving results that are AT OR ABOVE 4 ppb.
Remediation Remediation Guidance When you receive your results, use this flow chart to plan out your immediate, planned, and permanent remediation actions.
Remediation "Do Not Drink" and "For Handwashing Only" signs Post these signs at taps that had results at or above 4 ppb as an immediate remediation action.
Remediation Plumbing Profile Questionnaire For child care centers, use this questionnaire if you need help with planning out your remediation action before contacting DEC.
Reimbursement Reimbursement Request Use this document if you need to submit your reimbursement request by mail.


Translated Materials

Language Title
Arabic Before Sample Collection Notification Letter to Parents, Guardians and Program Staff
Burmese Before Sample Collection Notification Letter to Parents, Guardians and Program Staff
French Before Sample Collection Notification Letter to Parents, Guardians and Program Staff
Kirundi Before Sample Collection Notification Letter to Parents, Guardians and Program Staff
Nepali Before Sample Collection Notification Letter to Parents, Guardians and Program Staff
Somali Before Sample Collection Notification Letter to Parents, Guardians and Program Staff
Spanish Before Sample Collection Notification Letter to Parents, Guardians and Program Staff
Swahili Before Sample Collection Notification Letter to Parents, Guardians and Program Staff
Vietnamese Before Sample Collection Notification Letter to Parents, Guardians and Program Staff
Arabic Informational Sheet - Lead Poisoning in Children
Burmese Informational Sheet - Lead Poisoning in Children
French Informational Sheet - Lead Poisoning in Children
Kirundi Informational Sheet - Lead Poisoning in Children
Nepali Informational Sheet - Lead Poisoning in Children
Somali Informational Sheet - Lead Poisoning in Children
Spanish Informational Sheet - Lead Poisoning in Children
Swahili Informational Sheet - Lead Poisoning in Children
Vietnamese Informational Sheet - Lead Poisoning in Children
Arabic Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and Program Staff
Arabic Results BELOW 4 ppb Notification Letter to Parents, Guardians and Program Staff
Burmese Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and Program Staff
Burmese Results BELOW 4 ppb Notification Letter to Parents, Guardians and Program Staff
French Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and Program Staff
French Results BELOW 4 ppb Notification Letter to Parents, Guardians and Program Staff
Kirundi Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and Program Staff
Kirundi Results BELOW 4 ppb Notification Letter to Parents, Guardians and Program Staff
Nepali Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and Program Staff
Nepali Results BELOW 4 ppb Notification Letter to Parents, Guardians and Program Staff
Somali Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and Program Staff
Somali Results BELOW 4 ppb Notification Letter to Parents, Guardians and Program Staff
Spanish Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and Program Staff
Spanish Results BELOW 4 ppb Notification Letter to Parents, Guardians and Program Staff
Swahili Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and Program Staff
Swahili Results BELOW 4 ppb Notification Letter to Parents, Guardians and Program Staff
Vietnamese Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and Program Staff
Vietnamese Results BELOW 4 ppb Notification Letter to Parents, Guardians and Program Staff