Part II: Lead in Water Testing - actforchildren.org · Final rule anticipated in November 2018...

©2018 Elevate Energy

Part II: Lead in Water Testing Guidance for Illinois child care facilities to comply with new Department of Children and Family Services (DCFS) requirements and reduce lead in water

October 22, 2018


Agenda

Update on new rule requirements

How to prepare for lead in water sampling

Sample procedure

How to interpret test results

Notification requirements

Q&A


Update: New rule requirements


Illinois requirement for water sources

In 2017, the Illinois senate passed a new law requiring child care facilities to test their water for lead (Illinois Public Act 099-0922).

Starting in 2018, all licensed day care homes, day care centers, and group day care homes in Illinois serving children ages birth to six years and built on or before January 1, 2000, will need to test their water for lead.


New licensing standards (Proposed rule)

Any day care housed in a building constructed on or before January 1, 2000 shall be subject to water testing by an IEPA laboratory or an IEPA-certified laboratory.

A) Any home or center, upon receiving test results of 2.01 ppb or higher, must take immediate action to ensure a safe water supply until the mitigation plan is complete and repeat lead testing indicates the facility's water is 2.00 ppb or lower.

B) Results of testing shall be posted in a prominent location in the home or center and submitted to the local Licensing Office;

C) A mitigation plan shall be developed if testing results indicate lead in water of 2.01 ppb or higher;

D) Mitigation plan shall be made available to parents;

E) Retesting following mitigation activities shall be no later than six months following the identification of the presence of lead and the development of the mitigation plan, and then retesting annually until at least 2 consecutive annual tests indicate no lead present in the facility's water;

F) Retesting of any facility constructed on or before January 1, 2000 shall occur within 30 days after any change to the water profile of the building, including but not limited to, replacement of the hot water heater, change in the water source, change to or replacement of the water service lines;


New licensing standards (Proposed rule)

In other words…

Test water for lead using an IEPA lab or IEPA-certified lab

Post results in the facility and submit them to your Licensing Office

Take immediate action if test results are 2.01ppb or higher to ensure safe drinking water supply

Develop a mitigation plan if test results are 2.01ppb or higher and make the plan available to parents

Conduct follow-up testing under the following scenarios:

When lead is found during initial testing. In this case, retesting is required six months later and then annually after that.

After a change to the plumbing in the facility (e.g., new water heater, replaced water service lines)

Stop follow-up testing when:

Two consecutive annual tests find no lead


Timeline

Rules being reviewed on November 13, 2018

Final rule anticipated in November 2018

Current deadline for submitting test results is TBD. The November 30, 2018 is no longer in force.


Lead in Water Testing


Preparation for lead in water sampling

• Select a faculty or maintenance staff member to plan and implement water sampling, mitigation actions, and communications with parents

• Become familiar with the layout of your facility, including where drinking water sources are located


Preparation: Identify all sources to test

Kitchen Sink Bathroom Sink Classroom Sink

Water Fountain Water Dispenser Ice Machine


Preparation: Sampling order

Kitchen faucet Fridge water

dispenser Automatic ice

maker

Bathroom sink All other

drinking water outlets

You do not need to collect

samples from the tub or

shower


Preparation: Sample locations & supplies

• Record where each drinking water outlet (sample location) is located

• Determine the number of sample bottles you will need per fixture • Two bottles per fixture OR

• One, 1 liter bottle for your ice dispenser

• Give each location and sample a unique name, such as K_S1 (Kitchen, Sample 1)


• Contact an IEPA certified lab for lead in drinking water analysis (lab will provide sampling bottles and instructions)

• Sample cost per test: $15-$25 (does not include shipping)

• Ask to have sample instructions and a chain of custody form emailed or mailed to you

• A list of labs can be found online at https://sunshine.dcfs.illinois.gov/Content/Licensing/LeadTesting.aspx

Preparation: Contact an IEPA approved lab

https://sunshine.dcfs.illinois.gov/Content/Licensing/LeadTesting.aspx



Preparation: Night before

• Before collecting samples, your water will need to stagnate overnight for at least 6 hours but no longer than 18 hours.

• Do not collect samples after a long holiday or weekend (water will have stagnated for longer than 18 hours).

• Do not remove aerators prior to testing

• Remember to shut off icemakers and any devices that automatically use water.

Remember: No one should use water, including faucets, showers, toilets, dishwashers, laundry machines, or sprinklers during the 6 to 18 hour stagnation period


Preparation: Night before

• Tape off fixtures so your water is not disturbed prior to testing


Preparation: Day-of reminders

• Samples are usually collected in the morning before children and staff arrive

• Before collecting samples, ensure water has not been disturbed.

• Only collect cold water samples

• Collect samples using a pencil sized flow


Preparation: Type of samples you will collect

• All drinking water fixtures must be sampled 2 times (except the ice machine) using 250mL bottles

• First draw:

• If tests positive for lead there is probably lead in that fixture

• 30 second flush:

• If tests positive for lead there is probably lead in the immediate line to the fixture

• Icemaker: If you have an icemaker, collect the ice in one, 1 liter bottle using gloves or a non-metal scoop


Preparation: Day-of reminders

• To avoid contamination, do not open bottles until you are ready to collect a sample

• Make sure your bottles have a label with a unique naming convention that identifies the sampling location and type

• Fill out your Chain of Custody form for each sample.


Example: Chain of Custody form (top half)

A Chain of Custody form must accompany the water samples you collect and send to the lab.

Chain of Custody Form (top):


Example: Chain of Custody form (body)

No. Client

Sample ID

Collection Location

Collection Date Collection Time

Analyte

Lead

1 AM / PM

2 AM / PM

3 AM / PM

4 AM / PM

5 AM / PM

6 AM / PM

7 AM / PM

8 AM / PM

9 AM / PM

10 AM / PM

11 AM / PM

12 AM / PM

13 AM / PM

14 AM / PM

15 AM / PM

Released by: Signature: Date/Time:

Released by: Signature: Date/Time:

Enter your own unique label for each sample here. E.g., the first sample from the kitchen sink could be labeled “K_S1.”

Enter a location that you will remember later. E.g., kitchen, Classroom #3, bathroom.

A Chain of Custody form asks you to fill in information about the location where the sample was collected, type of sample collected, time of day, person collecting the sample, and when water was last used at your facility prior to beginning testing.

K_S1 Kitchen 6:30 9/07/18


Sample Collection: First Draw

• Position the first 250 mL sample bottle beneath the fixture and turn on the cold water using a pencil sized flow. Do not allow any water to spill.

• Fill the bottle completely and turn the water off.

• Cap the bottle tightly. Record the time you started collecting the sample.


Sample Collection: 30 Second Flush

• Turn the water back on at full force and allow the water to run for 30 seconds before filling the second 250 mL sample bottle to the top using a pencil-sized flow.

• Cap the bottle tightly and record the time.


Sample Collection: First Draw & 30 Second Flush

• Continue sampling each drinking water fixture until all samples are collected.

• Prepare the samples for shipping or delivery per IEPA certified laboratory instructions.


Sample Collection: Ice Dispenser

• Make sure the 1-liter collection bottle has a label.

• Fill the one liter collection bottle with ice using plastic disposable gloves or a non-metal ice scoop.

• Ensure at least 250 mL of liquid is collected.

• Record time and other info. on the Chain of Custody form for the sample.


Procedure Video: First Draw & 30 Second Flush

Click Here for Video

https://www.dropbox.com/s/ihgychgivvpixpx/Lead in Water Sampling v5.mp4?dl=0

https://www.dropbox.com/s/ejww10nen8m0t1x/Lead in Water Sampling_10.02.18.mp4?dl=0


Avoiding common errors

• Send your samples to the lab as soon as possible

• Keep a personal record of which sample ID corresponds to each fixture.

• Ensure that the sample ID on the bottle and the sample ID on the Chain of Custody form are identical.

• Tightly close bottle lids before mailing or delivering them back to the lab, as they can come loose in transit.


Sample Results

• Test results usually come back in 2-4 weeks (ask your lab for more details)

• Test results will be reported in either parts per billion (ppb) or micrograms per liter (µg/L). These are equivalent.

• If a sample is 2.01ppb or greater, mitigation is required.


Sample Results


Notification Requirements

• Results must be posted in a location where parents/guardians can easily see them

• Report results to your DCFS licensing representative

Don’t forget: Share your results with parents


Upcoming webinars

Part III: Mitigation Strategies, Monday, Nov. 19, 12 – 1pm

https://go.actforchildren.org/e/471011/register-1001044158030672899/49dnb/51801571

US EPA Resource on Mitigation for Schools and Child Care Facilities:

https://www.epa.gov/ground-water-and-drinking-water/3ts-module-6


















FAQs: Lead in Water Testing

Can I do the testing myself? Or do I have to hire an outside company?

Can I purchase a lead in water test kit from Amazon or Home Depot?

Can I ask my water utility to help with testing?

Where can I get a copy of the sampling procedure?

How do I ensure a “pencil size” flow at drinking fountains or sinks that automatically dispense water?

Can I use any bottle at home to collect my water samples?

Do I have to test the water from two sinks that are next to each

other?


Resources

Illinois government resources: • Department of Children and Family Services (DCFS) Sunshine website on lead in

water: https://sunshine.dcfs.illinois.gov/Content/Licensing/LeadTesting.aspx

• Illinois Department of Public Health (IDPH) resources for schools: http://dph.illinois.gov/topics-services/environmental-health-protection/lead-in-water

Additional lead in water resources: • U.S. EPA resources on lead in drinking water:

o Basic information on lead in water: https://www.epa.gov/ground-water-and-drinking-water/basic-information-about-lead-drinking-water

o EPA’s 3Ts guidance on lead in water testing in child care: https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water-toolkit

• Environmental Defense Fund: https://www.edf.org/health/lead-toxic-legacy

• Elevate Energy: https://www.elevateenergy.org/child-care-lead-in-water-testing-illinois/

• Factsheets for residents on lead in water: o http://ww2.wkkf.org/2016/digital/Water-FS-Homeowner4.pdf (English) o http://ww2.wkkf.org/2016/digital/Water-FS-Homeowner-Sp4.pdf (Spanish)


http://dph.illinois.gov/topics-services/environmental-health-protection/lead-in-water











https://www.epa.gov/ground-water-and-drinking-water/basic-information-about-lead-drinking-water



















https://www.epa.gov/ground-water-and-drinking-water/3ts-reducing-lead-drinking-water-toolkit



















https://www.edf.org/health/lead-toxic-legacy





https://www.elevateenergy.org/child-care-lead-in-water-testing-illinois/













http://ww2.wkkf.org/2016/digital/Water-FS-Homeowner4.pdf





http://ww2.wkkf.org/2016/digital/Water-FS-Homeowner-Sp4.pdf








QUESTIONS?

Caroline Pakenham

Program Manager, Energy and Sustainability

Lindsay McCormick

Project Manger, Chemicals and Health

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