A lead testing act was passed in Colorado mandating that all licensed child care facilities and public schools serving fifth grade and lower test all drinking water locations for lead by May 31, 2023. Colorado’s Water Quality Control Division created the Test & Fix Water for Kids program to implement this act. Aspects of the program included establishing a database, outreach and education, technical assistance, lead analyses at the Colorado State Laboratory, remediation, and reimbursement. Of a total of 6000 licensed child care providers and public elementary schools, 4500 entities enrolled and tested 53 000 water samples for lead at drinking water fixtures. Testing results showed that 93% (46 000 total) of the fixtures tested were below the 5 parts per billion (ppb) action level. As a result, 7% (3700) of the fixtures tested were above the action level. Of the fixtures that tested above 5 ppb, 47% were classroom faucets. Many of these faucets had not been used since COVID-19 when several schools switched to using bottle fillers. The program identified all fixtures associated with low usage as well as older fixtures to be replaced with lead-free options to reduce lead levels below 5 ppb. Almost 600 000 children have been protected from potential exposure to lead in drinking water through this program. This article outlines the methods of launching a statewide lead testing program and the importance of testing fixtures for lead in drinking water in early childhood education buildings.
The Colorado Testing of Drinking Water in Schools, Child Care Centers, and Family Child Care Homes Act was signed into law on June 7, 2022, mandating that all licensed child care facilities and public schools serving grades 5 and lower test all drinking water locations for lead by May 31, 2023. The legislative aim is to reduce the potential exposure of children to lead in drinking water in the locations where children spend most of their time outside the home. Testing and remediation of elevated lead fixtures was performed at no cost to the schools and child care facilities. The State of Colorado’s Water Quality Control Division created the Test & Fix Water for Kids program to implement this act through a series of deliberate steps beginning in August 2022. The division developed and executed the program quickly to meet the May 31, 2023, testing deadline across 6000 eligible schools and child care facilities statewide. To that end, the division identified resource needs and priorities and worked rapidly to create solutions including a functional database that could link data and results to a public-facing website. By the end of September 2022, the program database was thoroughly tested and functional, and the first laboratory sample results were reported publicly on October 29, 2022. This rapid program implementation overcame considerable challenges, including staff and contractor training, tool and database development, equipment ordering and installation at the laboratory, and the creation of program guidance, website, and data standard operating procedures.
Although lead exposure can occur from various sources (eg, air, soil, consumer products) the most likely source of lead in drinking water occurs from the corrosion of older lead or brass plumbing materials. The Lead and Copper Rule in the Safe Drinking Water Act addresses the corrosion of plumbing by requiring that water providers monitor lead and copper in drinking water and reduce water corrosivity if needed.1,2 In conjunction with the Lead and Copper Rule, the Safe Drinking Water Act 1986 Lead Ban and the subsequent 2011 Reduction of Lead in Drinking Water Act3,4 were enacted to reduce the amount of lead plumbing in facilities providing water for human consumption. Consequently, any plumbing installed before these acts is more likely to contain lead. This includes not only service lines (the piping connecting a building to the municipal water main), a priority to be removed and replaced under the new Lead and Copper Rule Revisions,2 but also plumbing within the building (eg, pipe solder, valves, faucets, drinking fountains).
Under Colorado’s Test & Fix Water for Kids program, sampling was required at every fixture used for drinking or cooking within elementary schools serving grades 5 and lower and licensed child care buildings. Action was required at every fixture that returned a result of 5 parts per billion (ppb) or greater. The current Safe Drinking Water Act requirement for lead in drinking water under the Lead and Copper Rule requires water systems to achieve a 90th percentile for lead sampling below 15 ppb.1 Standards beyond the Lead and Copper Rule vary with filters for lead removal third-party certified to reduce lead in drinking water to 5 ppb or less,5 the Federal Drug Administration (FDA) allowable limit for bottled water at 5 ppb6 and the Federal Drug Administration level for juice recommended at 10–20 ppb depending on the type of juice.7
By September 2023, the program had enrolled 4500 entities and tested 53 000 water samples at drinking water fixtures for lead. Testing results showed that 7% (3700) of the fixtures tested returned results above the action level of 5 ppb. The program identified all fixtures associated with low usage as well as older fixtures to be replaced with lead-free options to reduce lead levels. These results highlight the importance of testing all drinking water fixtures in a building to determine if there is a presence of lead at each fixture and to inform decision-making to determine the appropriate fixes for each facility.
Methods
The Environmental Protection Agency (EPA) 3Ts guidance8 describes best practices for lead testing in schools and child care programs. According to the 3Ts, a successful testing program includes components of outreach, education, planning, testing, remediation, and record-keeping. Because the Colorado legislation mandated rapid program implementation, resources used in similar programs by other states were considered. The state of Massachusetts implemented a similar program9 and provided Colorado with their database code. The adoption of this code into Colorado’s data management effort saved several months of database development time. Additionally, the program invested in technical assistance contractor support, development of an interactive online sampling plan tool specific to each facility type, a program brand and website, a communication plan and guidance documents, a memorandum of understanding with the state laboratory for testing supplies, analysis, and sample kit shipments, and integration of the laboratory electronic data into the program database.
Each entity that enrolled in the program received a link to an interactive online sampling plan tool with step-by-step instructions for identifying and sampling fixtures following the EPA 3Ts guidance.8 Once a sampling plan was created, sampling kits containing detailed instructions and all materials needed to sample were shipped directly to school and child care facilities with free prepaid return shipping labels. The sampling instructions required that the entities collect their samples at the beginning of the day after the water in the building had been unused for 8–18 hours. A contaminant-free 250 mL Nalgene sample bottle was filled to the bottleneck from the cold water tap at each fixture following the building sampling plan. Bottles were shipped to the Colorado State Laboratory for analysis under Method EPA 200.8.10
The Colorado Water Quality Control Division developed the Test & Fix results Web page11 to allow the public to search testing results by county, school district, facility name, or facility code. Additionally, because the database links facility licenses that are co-located in the same building (eg, child care programs located in elementary school buildings), parents and staff can search under any co-located facility name and see results. For example, a parent of a child at an afterschool program in an elementary school can search under the program or school’s name and see the results for the afterschool program and the school. Results were reported automatically to each school and child care by e-mail and posted online. If the results of a drinking water test returned a rounded lead result of 5 ppb or higher, a second round of sampling was conducted. This second round of sampling used a follow-up flush sample protocol.8 Collecting flush samples is an important step in determining the best long-term solution for a fixture because leaded solder or valves can also be a source of lead in drinking water.8 Similar to the initial sampling process, the follow-up flush sample collection occurred at the beginning of the day after the water in the building had been unused for 8–18 hours. The cold water tap was turned on at the fixture for 30 seconds and the sample was collected using a contaminant-free 250 mL Nalgene sample bottle filled to the bottleneck. Bottles were shipped to the Colorado State Laboratory for analysis under Method EPA 200.8.10 After initial and follow-up results were available, the program staff reached out to each facility to determine the best remedial action to reduce lead levels, typically either by replacing the plumbing with lead-free materials or posting permanent signage if the fixture was identified as a hand-washing-only location. Any fixture that was replaced required a confirmation result to determine if the lead levels had been successfully reduced below a rounded value of 5 ppb. If a confirmation result failed, further action was taken, typically either by further plumbing replacements or installing point-of-use filters certified to remove lead.
Outcomes
Of the almost 6000 licensed child care facilities and public elementary schools eligible, the program enrolled 4500 separate program licenses. Some facility locations contained multiple child care licenses or school programs in the same building. The 4500 enrolled licenses represent 2900 separate facility locations, including 232 family child care homes that enrolled and opted out (an allowable action for family child care homes under the act). Of the 50 000 fixtures sampled, 3700 total fixtures across 965 facilities returned results of 5 ppb or greater that require action. This equates to 7% of all fixtures tested returned lead results at or above the action level of 5 ppb.
The fixtures with lead results above the action level of 5 ppb are shown in Fig 1. Fixtures in the “Other” category include refrigerator water dispensers, ice machines, outdoor spigots, teachers’ lounge sinks, other types of sinks, and bottle fillers. Almost half (47%) of fixtures with results indicating that action was required were classroom faucets and bubblers attached to classroom faucets (Fig 1). The bubblers attached to classroom faucets are included in the “drinking water fountain” category and represent almost half of the fixtures in this category (Fig 1). The remedial actions for each fixture that required action as of September 15, 2023, in the program are shown in Fig 2.
Total number of fixture types with lead levels requiring action as of September 15, 2023.
Total number of fixture types with lead levels requiring action as of September 15, 2023.
Types of remedial actions approved for the total fixtures with action required as of September 15, 2023.
Types of remedial actions approved for the total fixtures with action required as of September 15, 2023.
Lessons Learned
The outcomes of the Colorado lead testing program revealed that the percentage of total fixtures that require action (7%) are consistent with findings from other states conducting similar programs. Specifically, 24% of the total samples tested in Massachusetts’ lead testing program as of December 2022 required follow-up at 1 ppb or greater,12 26% of the total samples tested in Montana as of June 2022 were above 5 ppb,13 6% of the total samples tested in North Carolina as of January 2024 were above 5 ppb,14 and 18% total samples tested as of January 2024 in Vermont were above 4 ppb.15 More sampling is needed nationwide to understand the full scale; however, the results across 5 states indicate an average of 16% of fixtures may need action to reduce lead levels below 5 ppb. This percentage could be a reflection of progress in lead reduction from the federal legislation banning lead in plumbing components more than a decade ago as newer plumbing installations continue. However, the persistence of some older plumbing components in child care facilities and schools could continue to be a potential source of lead exposure for children if testing is not implemented to pinpoint these older lead plumbing materials. Without comprehensive testing and remediation of these plumbing fixtures and fittings, this preventable exposure pathway cannot be addressed. The focus of the Colorado program moving forward is to achieve full remediation at all facilities with action required while also enrolling middle schools to begin testing in 2024.
Common challenges in the implementation of broad lead testing programs are funding availability to test all drinking water fixtures and remediate if results indicate action is required to reduce lead levels. As of September 15, 2023, laboratory analyses have totaled $1.2 million and remedial actions have averaged $2700 per facility requiring action. The financial burden can be reduced by focusing on fixtures intended for drinking and cooking only. Fixtures meant for hand washing should be designated as such for sanitation reasons and because these fixtures are often configured in a way that prohibits optimal lead reduction. For example, faucets with mixed valves and automatic flow commonly associated with hand washing are labeled as such in the program because hot water can dissolve lead more quickly and may increase lead levels in drinking water.8 As of September 15, 2023, more than 50% of the actions taken at fixtures with action required were posting signage at fixtures used for hand washing only and cleaning/replacing aerators (Fig 2).
Maintaining communication with facility management at each building can also be challenging in a broad lead-testing program. However, communication is critical for success in completing sample collection and determining the appropriate remedial action for each building requiring action. To complete remediation plans, facility managers and coordinators worked with program technical assistants to understand the results, the conditions of use, and age at each fixture. As a result, this process determined that in several cases the majority of fixtures requiring action were either original to the buildings and installed before the Reduction of Lead in Drinking Water Act,3,4 or were fixture types that had been used less frequently since COVID-19 in favor of using bottle fillers and individual water bottles for sanitation reasons. Fixture use and age are important details to consider during sample collection and remediation because long periods of low usage can increase lead corrosion levels at an individual fixture and return higher lead test results.16 Through these methods, the program identified fixtures associated with low usage as well as older fixtures to be replaced with lead-free options to reduce lead levels below 5 ppb.
Conclusions
From the results of this lead testing program in Colorado and similar programs in other states, it is estimated that less than one quarter of all fixtures in early childhood buildings could be potential sources of lead exposure and should be addressed. The only way to know if there is a presence of lead in a drinking water fixture is to test. This study provides the outline for a broad-reaching mandatory lead testing program that can efficiently determine the scope of lead risks in drinking water statewide. Constraints to the goal of reduced lead exposure in early childhood settings are largely exacerbated by a lack of funding at the facility level to remediate fixtures that require action. Funding methods that can support the full process from testing to remediation can greatly improve participation and success in a lead testing program.
Acknowledgments
The authors acknowledge the Colorado Department of Early Childhood and the Colorado Department of Education for their contributions to early data collection, the Colorado State Laboratory personnel for the shipping, processing, and analyses of samples, and the staff of the Colorado Department of Public Health and Environment, Water Quality Control Division communications and data teams for their assistance with outreach and data management.
Dr Leonard and Ms Talbott conceptualized and designed the study, coordinated and supervised data collection, drafted the initial manuscript, and critically reviewed and revised the manuscript.
References
Competing Interests
CONFLICT OF INTEREST DISCLOSURES: The authors have indicated they have no potential conflicts of interest to disclose. The funding sponsors dictated the general structure and timelines of the study.
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