Lead Testing in Drinking Water - What Schools Need to Do

girls on track drinking water from bottle

Many Vermont schools are in older buildings, which means they are more likely to have lead in the plumbing. While a major source of lead poisoning 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 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 school districts, supervisory unions, independent schools and 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.

This law builds on the 2017 water testing pilot project in which several supervisory unions and districts participated.

go to the lead in drinking water results website

Go to the School Testing Schedule

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.

Is there a licensed child care program(s) (preschool or afterschool) that operates in your 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 (preschool or afterschool) 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.

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

Questions? Call Vermont211 by dialing 2-1-1 or 802-652-4636.

step-by-step instructions

TAP INVENTORY AND WATER SAMPLE COLLECTION

1. Choose a designated person(s).

There needs to be one or two designated people who will:

  • Complete the tap inventory.
  • Fill out the Water Sample Collection Information Form for each sample.
  • Collect water samples.
  • Prepare the samples for courier pickup.

If you’re a facility manager or the designated sample collector for your school, watch the School Facilities Manager Training video to learn more about the requirements of the law and the steps you will need to follow.

2. Prepare your tap inventory.

You’ll need to do a tap inventory to order lead in drinking water test kits. Complete only one tap inventory per school. Fill in the blue section titled "Tap Inventory for Schools and Child Care Providers Testing for Lead in Drinking Water." Make sure you save the tap inventory for later. It will help you fill out the Water Sample Collection Information Form that goes with each sample. You’ll also want to have this with you when you’re collecting water samples.

We created a video with step-by-step instructions and tips to help you fill out the tap inventory. Watch Video 1 - How to Complete Your Tap Inventory

Schools will need to 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. This includes taps in rooms that are used by all licensed child care programs (preschool or afterschool).

You'll be collecting two samples at each tap—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.

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. The flush sample should be from the tap that is easiest to flush for 30 seconds.

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

3. Complete the Lead in School Drinking Water: Kit Ordering and Registration Survey.

Be sure to have the blue section of your tap inventory completed and with you when you fill out the survey. See Step #2 for instructions on how to complete your tap inventory.

Go to the Lead in School Drinking Water: Kit Ordering and Registration Survey

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

Superintendents (public schools) and heads of school (independent schools) will be emailed when their school(s) have been scheduled. The school testing schedule will be updated as pickup dates are confirmed. Go to the School Testing Schedule

You’ll need to send a letter and an informational sheet to parents, guardians and school staff at least 5 days before you begin collecting samples. If there is a licensed child care program (preschool or afterschool) that operates in your school, talk to them about your testing schedule so they can send the letter and informational sheet to their program's parents, guardians and staff at least 5 days before you begin collecting 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 4 ppb.

We 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 (e.g. DATE, SCHOOL 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

5. Prepare to collect the water samples.

You'll be collecting two samples at each tap identified on the tap inventory—a first draw and a flush. A Water Sample Collection Information Form needs to be filled out for each sample. It is important to fill out every field on the form. Download instructions on how to fill out the Form

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.

The second section of Video 2 - How to Collect Water Samples has tips about how to prepare to collect samples and fill out the Forms.

  • You can fill out everything on the Form (except for the date, time and sampler’s comments) before you collect samples.
  • Use the blue section of your completed tap inventory to help you fill out the Forms.
  • Write the “Lab ID #” (found in the top right box on the Form) in the last column of the blue section of the tap inventory that says “Lab ID #.”
  • On the Form for a flush sample, write the first draw sample Lab ID # for the same tap in the box to the right of “Collection Type.” Note: This is a very important step. The first draw and flush samples for the same tap must be linked together. This ensures that the sample results are displayed correctly online and will help you track a result that is at or above 4 ppb.
  • Keep all first draw sample Forms together and all flush sample Forms together.

If you want to save time in filling out these forms, the following fields only need to be filled in on one form, and can be left blank on the rest of the forms:

  • Name of Person Collecting Sample
  • Daytime Phone No.
  • School Name
  • Town

Download instructions on how to fill out the Water Sample Collection Information Form
Watch Video 2 - How to Collect Water Samples

6. Collect water samples during your scheduled week.

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

  • Enough sample bottles for a first draw and flush sample for each tap used for drinking and cooking.
  • Water Sample Collection Information Forms for each sample.
  • A fluorescent pink notice that tells you when to collect water samples and when your scheduled pickup day is.
  • Instructions on how to collect water samples.
  • Instructions on how to fill out the Forms.
  • A copy of your tap inventory.

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 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 your tap inventory. Starting closest to where the water enters the building, collect all first draw samples first. 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. 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 and sampler’s comments).

Be sure to write the Lab ID # (found in the top right box of the Form) on the sample bottle label. Fold and rubber-band the Form around the bottle.

Download instructions on how to fill out the Water Sample Collection Information Form
Download instructions on how to collect water samples
Watch Video 2 - How to Collect Water Samples

7. Return samples to the Lab.

A courier will pick up the samples from your school on your scheduled pickup day. A fluorescent pink notice will be included in the box of sample bottles that will list your scheduled pickup day.

We created a video with step-by-step instructions and tips to on return water samples to the Lab. Watch Video 3 - Returning Your Water Samples

Be sure to:

  • Screw the caps on tightly and securely wrap the Form around each bottle.
  • Pack the samples securely in any box(es) using packing materials to make sure they don’t move around.
  • Put a copy of your completed tap inventory in the box.
  • Label the box(es) with your school name.
  • Leave the packed box(es) at the front desk or main office for pickup.

RESULTS AND REMEDIATION

1. Receive your test results.

You will receive your results by email 2 to 6 weeks after the courier picks up the sample bottles. Results will be emailed to school administrators and child care providers (if there is a licensed preschool or afterschool program that operates in your school).

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 (preschool or afterschool) that operates in your school will be listed under the school’s name.

If all of your results were below 4 ppb, the only thing you need to do is to complete Step #4.

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 or cooking.

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 Ben Montross at 802-498-8981 or ben.montross@vermont.gov or Jeff Girard at 802-585-0314 or jeff.girard@vermont.gov.

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

3. Register for an ANR Online account and enter immediate remediation actions.

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. 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 create an account and submit remediation actions on ANR Online
Go to ANR Online
Watch Video 5 - How to Complete Remediation

4. 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.

If there is a licensed child care program (preschool or afterschool) that operates in your school, talk to them about notifying their program's parents, guardians and staff within 10 business days of receiving results from the Lab and about implementing remediation plans if results at or above 4 ppb.

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 (e.g. DATE, SCHOOL/FACILITY, etc.) will need to be edited by you before sending out the letters.

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 (preschool or afterschool) that operate in a school will be listed under the school’s name.

5. 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. It may be helpful to fill out a plumbing profile and map your results on a floor plan. 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 Jeff Girard at 802-585-0314 or jeff.girard@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
  • 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
See instructions on how to submit remediation actions on ANR Online

6. Submit your Remediation Plan.

Schools 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 school’s name.
  3. Select the planned permanent remediation action for each tap.
  4. Record your immediate 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
Watch Video 5 - How to Complete Remediation
See instructions on how to submit your Remediation Plan on ANR Online

7. 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 and ice machines: $1,800.00
  • Taps used for cooking: $650.00
  • All other taps in schools: $350.00

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. Enter permanent remediation actions on ANR 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
See instructions on how to submit remediation actions on ANR Online

8. 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 the Health Department Laboratory to order follow-up test kits at 802-338-4736 or 800-660-9997 (toll-free in Vermont). Follow-up test kits and shipping costs to and from the Lab are covered by the State.
  • Discuss your return options with Lab customer service. Shipping costs to and from the Lab are covered by the State.
  • 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.

3. Collect water samples.

Follow the instructions on how to collect samples (see Steps #5 – 6 in the Tap Inventory and Water Sample Collection section above).

On the Water Sample Collection Information Form, check the box for “Post remediation follow-up” under Sample Type and write the Lab ID# for the initial sample on the line.

See instructions on How to Fill out the Water Sample Collection Information Form

4. Return samples to the Lab.

There are two ways to return your follow-up samples: courier pickup or UPS. When you ordered follow-up test kits, the Lab talked to you about which return option to use. Return shipping instructions will be included in the box of sample bottles sent to you. Please put a copy of your completed tap inventory in the box when you return the water samples.

Courier Pickup

  • Screw the caps on tightly and securely wrap the Water Sample Collection Information Form around each bottle.
  • Pack the samples securely in any box(es) using packing materials to make sure they don’t move around.
  • Label the box(es) with your school name.
  • Leave the packed box(es) at the front desk or main office for courier pickup.

UPS

  • On the same day you collect your water samples, call UPS to schedule a pickup at your school 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. (A pre-paid return shipping label will be included in the box of sample bottles mailed to you.)
  • 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 pay, say “bill to original shipper."
5. Receive your follow-up test results.

Results will be emailed to you within 2 to 6 weeks after the samples have been picked up by the courier or 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 #5 – 8 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 Jeff Girard at 802-585-0314 or jeff.girard@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 #4 under the Results and Remediation section above.

COST REIMBURSEMENT

1. Save receipts and invoices for remediation actions.

Schools need to pay upfront for all costs associated with remediating taps that were at or above 4 ppb. After the remediation is complete and follow-up test results show lead levels below 4 ppb, then you can submit a reimbursement request.

School districts, supervisory unions and independent schools 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. The maximum amount for each type of fixture is:

  1. Public drinking fountains and ice machines: $1,800.00
  2. Taps used for cooking: $650.00
  3. All other taps in schools: $350.00
2. Submit receipts and invoices to the Health Department.

Each location should send one reimbursement request once all remediation and follow-up testing has been completed and results are below 4 ppb. You can consolidate the invoices by school district or supervisory union. Be sure to:

  • Send a copy of all receipts and itemized invoices by fixture.
  • Write the initial first draw Lab ID# on the receipt and invoice to indicate which tap was remediated.
  • Itemize all costs by fixture, including parts and labor, using the initial first draw sample Lab ID # and school name. Note: This applies to anyone who submits an invoice.
  • Mail all receipts and invoices to:

Vermont Department of Health
Attn: Business Office
PO Box 70
Burlington, VT 05402
Or submit via email to AHS.VDHAccountsPayable@vermont.gov

3. Receive your reimbursement.

Payment will be received within 30 days after the Health Department receives an error-free invoice. If there is an error found on your invoice, the Health Department will reach out to request a new invoice. 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.

Materials you will need

Phase of the Process Title Description
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" to complete your tap inventory. Use the green section titled "Results and Remediation Actions for Schools and Child Care Providers" to track your remediation actions. To see an example of a completed tap inventory, click on the tab labeled "Example."
Water Sample Collection Photos of Fixture Types See images of the different types of fixtures for sample collection.
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 5 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 5 days before you begin collecting samples.
Water Sample Collection How to Fill Out the Water Sample Collection Information Form - 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.
Water Sample Collection How to Collect Water Samples - Instructions See how to fill out the Water Sample Collection Information Form for each sample.
Results Notification Letter to Parents, Guardians and School Staff - Results BELOW 4 ppb Use this letter template to send to parents, guardians and school staff within 10 business days of receiving results that are BELOW 4 ppb.
Results Notification Letter to Parents, Guardians and School Staff - Results AT OR ABOVE 4 ppb Use this letter template to send to parents, guardians and school 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 and log your remediation actions and submit your Remediation Plan.
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 Use this questionnaire if you need help with planning out your remediation actions before contacting DEC.


Translated Materials

Language Title
Arabic Before Sample Collection Notification Letter to Parents, Guardians and School Staff
Burmese Before Sample Collection Notification Letter to Parents, Guardians and School Staff
French Before Sample Collection Notification Letter to Parents, Guardians and School Staff
Kirundi Before Sample Collection Notification Letter to Parents, Guardians and School Staff
Nepali Before Sample Collection Notification Letter to Parents, Guardians and School Staff
Somali Before Sample Collection Notification Letter to Parents, Guardians and School Staff
Spanish Before Sample Collection Notification Letter to Parents, Guardians and School Staff
Swahili Before Sample Collection Notification Letter to Parents, Guardians and School Staff
Vietnamese Before Sample Collection Notification Letter to Parents, Guardians and School 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 School Staff
Burmese Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and School Staff
French Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and School Staff
Kirundi Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and School Staff
Nepali Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and School Staff
Somali Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and School Staff
Spanish Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and School Staff
Swahili Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and School Staff
Vietnamese Results AT OR ABOVE 4 ppb Notification Letter to Parents, Guardians and School Staff
Arabic Results BELOW 4 ppb Notification Letter to Parents, Guardians and School Staff
Burmese Results BELOW 4 ppb Notification Letter to Parents, Guardians and School Staff
French Results BELOW 4 ppb Notification Letter to Parents, Guardians and School Staff
Kirundi Results BELOW 4 ppb Notification Letter to Parents, Guardians and School Staff
Nepali Results BELOW 4 ppb Notification Letter to Parents, Guardians and School Staff
Somali Results BELOW 4 ppb Notification Letter to Parents, Guardians and School Staff
Spanish Results BELOW 4 ppb Notification Letter to Parents, Guardians and School Staff
Swahili Results BELOW 4 ppb Notification Letter to Parents, Guardians and School Staff
Vietnamese Results BELOW 4 ppb Notification Letter to Parents, Guardians and School Staff