Model Plan to Test for Lead in Early Care and Education Settings

A program to assess and sample for lead in drinking water must: 

• Designate who will inventory water fixtures and collect water samples. 
• Inventory drinking water fixtures. Identify how each fixture is used and identify those used for consumption that will need to be tested (i.e., drinking water and food preparation). 
• Determine a schedule for sampling. All fixtures used for drinking water or food preparation must be tested a minimum of once every five years. Determine logistics for sampling. 
• The water in the facility should undergo normal water usage the day before sampling. DO NOT plan to sample during or immediately following an extended closure. DO NOT conduct pre-stagnation flushing in advance of testing if flushing is not part of your daily building practices.

Sampling must be conducted according to the established schedule and priority. Prepare and plan for a 2-part sample collection process consisting of an initial 250 mL first draw and a follow-up flushed sample (if needed). Take into consideration any special circumstances or special fixtures such as ice machines, coffee makers and sprayers which may require additional steps. 

Preparation and Planning 

• It may be necessary to collect samples over a number of days to ensure only first draw samples are collected. 
• Do not use sampling fixtures for a minimum of eight hours. The Minnesota Department of Health (MDH) recommends not exceeding 18 hours.
• Do not remove aerators or attachments. 

Sample Collection 

Part 1 

Collect a 250 mL first draw sample. Be sure to start sampling at fixtures closest to where the water enters the building so that other fixtures are not accidentally flushed.

Part 2 

If the result from Part 1 is high, collect a repeat 250 mL first draw sample as in Part 1. In addition, collect a 30-second flush sample to attempt to identify if the lead is coming from the plumbing behind the fixture or if flushing will help reduce lead. To collect a 30-second flush sample, after the water has been stagnant, as in the sample in Part 1, turn on the fixture and allow the water to run for 30 seconds and then fill the sample container. If not taking these samples at the same time, and elevated lead levels are found in Part 1, the water should not be consumed while preparing follow-up actions. 

For guidance on additional samples or sampling after high results the EPA 3Ts Module 5 has information on how to find sources of lead in plumbing using advanced sampling techniques to evaluate fixtures.

• 3Ts Module 5

Public schools, charter schools, and child care centers MUST remediate when lead is 5 parts per billion (ppb) or higher. The Minnesota Department of Health (MDH) recommends that other facilities serving children clearly identify their policy for remediating. 

As there is no safe level of lead, it is important to incorporate lead hazard reduction options and communicate at all levels of lead in order to raise awareness and reduce exposure. 

Mitigation strategies used will depend on the site-specific conditions of the facility. Facilities may consider prioritizing strategies to prevent exposures to students and staff most at risk. 

In order to facilitate reasonable action steps at every level MDH has created an Actions at Every Level (PDF) document to identify potential actions facilities can take to reduce lead in drinking.

MDH recommends taking action to minimize lead exposure at every level using a tiered approach as in Actions at Every Level (PDF). Since facilities vary tremendously across the state and there is not a "one size fits all" solution, decisions on actions need to be made locally taking long term effectiveness into consideration. 

Potential remediation actions include: 

• Removal and/or replacement of lead sources. 
• Implementation of a flushing program. 
• Cleaning aerators regularly. 
• Treatment/Filters. 

Even when lead is detected at very small levels it shows that there is room to examine best practices such as changing or implementing routine maintenance strategies. For additional information, see Appendix D: Detailed Fixture Evaluation found on page 59 of the 2018, 3Ts Revised Manual (PDF). 

To minimize the introduction of lead into drinking water systems, go to the United States Environmental Protection Agency’s website to identify lead free certification marks for drinking water systems and plumbing materials. More information can be found in How to Identify Lead Free Certification Marks for Drinking Water System & Plumbing Products.

All fixtures affected by a lead hazard reduction action must be retested to confirm the remediation action was effective at lowering the level of lead below 5 parts per billion (ppb). A first draw sample is to be taken using the procedure outlined in Step 2. If a flushing program was not implemented as part of the remediation, you may also want to collect a flushed sample(s) to identify if flushing would be helpful for reducing lead in the facility. 

• If results show persistent elevated lead levels, testing/remediation should continue until the lead source is found and hazard reduction options implemented. 
• The overall goal is to have state agencies, early care and education settings (ECES), parents, and students all work together to ensure that available resources are best targeted to minimize exposure to lead in drinking water.

School and child care centers must share results with the people they serve. The purpose of a comprehensive communication plan is to provide a process for employees, students, and parents to address questions, report results, share remediation actions and provide ongoing, up-to-date information regarding sampling efforts: 

• Education and Communication Toolkit A Technical Guidance and Model Plan for Minnesota's Public Schools (PDF) to aid schools in implementing this technical guidance/model plan. 
• The Education and Communication Toolkit: Reducing Lead in Drinking Water in Child Care Settings (PDF) will assist child care settings in implementing this technical guidance/model plan.

Public schools, charter schools, and child care centers must report lead results and remediation actions to the Minnesota Department of Health (MDH) annually beginning July 1, 2024. Schools and child care centers have different reporting requirements. Use the spreadsheet template and instructions to report results to MDH.

• Results Reporting Instructions and FAQ (PDF)
• Lead Results and Remediation Reporting Spreadsheet (Excel)

Other facilities are encouraged to make results readily available to parents and staff but are not required to report the results to MDH.

A water management plan is a tool to maintain and improve facility water quality. Water management plans can be included within your lead testing plan or written as a separate document. 

A water management plan addresses the following:

• Identifies all water fixtures and identify how they are used.
• Identifies areas of concern within building plumbing.
• Decide what routine maintenance strategies should be used and how to assess their effectiveness.
• Decide how you will intervene based on water quality concerns.
• Make sure the program is running as designed and is effective.
• Document and share results.

Resources for building water management plans include:

• Developing a Water Management Program to Reduce Legionella Growth & Spread in Buildings.
• Ensuring Drinking Water Quality in Schools During and After Extended Closures (PDF).