Caring for Our Children (CFOC)

Chapter 5: Facilities, Supplies, Equipment, and Environmental Health

5.2 Quality of the Outdoor and Indoor Environment

5.2.9 Prevention and Management of Toxic Substances Use and Storage of Toxic Substances

Content in the STANDARD was modified on 1/12/2017 and 1/31/2023.

Programs should use the following items only in the way the manufacturer recommends, and store them away from children in the labeled, child-proof container they came in:1–3

  • Cleaning materials
    • Detergents (in all forms, including pods)
    • Automatic dishwasher detergents (liquid or solid, including pods)
    • Aerosol cans
    • Paints, solvents, paint removers
    • Floor polish or stripper, furniture polish
    • Liquid soap, hand sanitizers, disinfectants
    • Pesticides
    • Health and beauty products
    • Lawn care chemicals
  • Medications/Substances
    • Medications (prescription and over-the-counter)
    • Marijuana –medical and recreational
      • all forms, including oils, liquids, and edible products and equipment
    • Liquid nicotine and tobacco products
    • Alcohol
  • Other toxic materials

Many of the chemicals and toxic substances listed above will not be found in child care centers. Many of these items may be present in small and large family child care homes. In states that allow recreational or medicinal marijuana, use extra care to store edible marijuana products securely¾and away from other foods and from the children’s medications¾to avoid accidentally giving them to children or children finding and ingesting them. State regulations usually require these products to be clearly labeled as an intoxicating substance and to be stored in the tamper-proof, child-resistant package they came in. In an early childhood program that takes place in a family home, keep all edible, adult medications, including nicotine, marijuana products and other substances, in a locked or child-resistant storage container. Accidentally eating these products can lead to serious adverse events, especially in children.4

Early care and education programs should store any potentially toxic substances behind doors/cabinets with child-resistant locks/latches.  A locked cabinet or room that children cannot open or enter is best, but it must be locked all the time. Storing potentially toxic substances in child-resistant containers is another level of protection.

Safety data sheets (SDSs) must be available on site for each hazardous chemical that the program has. When you use chemicals, don’t let them contaminate play surfaces, food, or food preparation areas. Don’t use them in a way that is dangerous to children or staff. Chemicals for lawns must be safe for children if children use those areas of the lawn. When you are not using chemicals, keep them away from children by storing all chemicals in a locked room or cabinet with a child-resistant lock or latch. Store them separately from medications and food.

Medications can be toxic if taken by the wrong person or in the wrong dose. Store medications safely in child-resistant containers¾preferably in a locked cupboard or cabinet¾away from children nd discard them properly (see Standard

Post the telephone number for the poison control center in a place where it is immediately available in emergencies. Poison control centers are open 24 hours a day, 7 days a week, and their number is 800-222-1222 (see Standard


Over 2 million human poisonings are reported to poison centers every year. Children under 6 make up more than half of those poisonings. The most common sources of childhood poisonings are health and beauty products, cleaning products, and medications.5 A safety data sheet, or SDS, is a standardized document that has occupational safety and health information. The International Hazard Communication Standard (HCS) orders chemical manufacturers to inform the users of a chemical’s potential danger by giving the user an SDS. SDSs usually list chemical properties, health and environmental hazards, protective measures, and safety advice for storing, and handling of chemicals.6 The SDS explains the risk of exposure to products so that users can be careful.

Many child-resistant locks or latches can be put on doors or cabinets to keep young children from getting to poisons. Many of these devices lock automatically when the door is closed, and they need an adult’s hand or skill to open the door.

Many adult medications, vitamins, marijuana, and other products now look like candy or gummies. Using separate, locked medication cabinets helps prevent child exposure and mistakes that early care and education program staff can make.

Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS Use of Tobacco, Electronic Cigarettes, Alcohol, and Drugs Medication Administration Labeling, Storage, and Disposal of Medications Integrated Pest Management Use of a Poison Center Informing Staff Regarding Presence of Toxic Substances Pool Equipment and Chemical Storage Rooms Chlorine Pucks Policies Prohibiting Smoking, Tobacco, Alcohol, Illegal Drugs, and Toxic Substances
Appendix J: Selection and Use of a Cleaning, Sanitizing or Disinfecting Product
Appendix K: Routine Schedule for Cleaning, Sanitizing, and Disinfecting
  1. Jung L, Fan N-C, Yao T-C, et al. Clinical spectrum of acute poisoning in children admitted to the pediatric emergency department. Pediatrics & Neonatology. 2019;60(1):59-67

  2. Davis MG, Casavant MJ, Spiller HA, Chounthirath T, Smith GA. Pediatric exposures to laundry and dishwasher detergents in the United States: 2013–2014. Pediatrics. 2016. doi: 10.1542/peds.2015-4529
  3. United States Environmental Protection Agency. Pesticides and their impact on children: key facts and talking points. 2015. Accessed August 3, 2022

  4. United States Food and Drug Administration. FDA warns consumers about the accidental ingestion by children of food products containing THC. June 16, 2022. August 3, 2022

  5. American Association of Poison Control Centers’ National Poison Data System. Annual Reports. Poison center data snapshots (2012-2020). Web site. Accessed August 3, 2022

  6. Chemical Safety. Safety Data Sheet Search. Web site. Accessed September 19, 2022


Content in the STANDARD was modified on 1/12/2017 and 1/31/2023. Use of a Poison Center

Content in the STANDARD was modified on 8/27/2020.

The Poison Control phone number, 1-800-222-1222, should be called for advice about any exposure to toxic substances or potential poisoning as soon as possible after exposure. Toxic substances could include medications, plants, berries or mushrooms, bites or stings, cleaning products, consumer products, and other chemicals. Exposure to toxic substances can happen if children swallow, inhale, or splash a product on their eyes or skin. Some common poisoning symptoms include dermatitis, dizziness, drowsiness, disorientation and/or sudden changes in behavior, nausea/vomiting, diarrhea, trouble breathing, pain, headaches, and feeling faint.1,2 If a child is unconscious, has a seizure, or is having trouble breathing, call 911 immediately.

Caregivers/teachers should feel comfortable calling Poison Control about medication dosing errors. The caregiver/teacher should not induce vomiting unless instructed by Poison Control.

The caregiver/teacher should be prepared for the call by having the following information for the Poison Control specialist:

  • The child’s age and sex
  • The substance involved
  • The estimated amount
  • The child’s condition
  • The time elapsed since ingestion or exposure

The national help line for Poison Control is 1-800-222-1222, and specialists will link the caregiver/teacher with their local poison center.3 The national help line number should be posted in a visible location or be added to a phone/contact list. Poison centers provide free, confidential advice on how to handle the situation. The advice should be followed and documented in the early care and education program’s files.

Depending on the cause prompting a call to poison control there may be a need for updated education on the subject for caregivers/teachers and/or children as well as implementation of improved health and safety practices.


Toxic substances, when ingested, inhaled, or in contact with skin, may react immediately or slowly, with serious symptoms occurring much later.3 It is important for the caregiver/teacher to call Poison Control immediately after the exposure and not “wait and see.”4 Symptoms of poisoning vary with the type of substance involved.


Caregivers/teachers should be knowledgeable and intentional about keeping all potential poisonous or harmful substances out of reach of children so that poisonings or ingestion of harmful substances are not treated as possible maltreatment cases, resulting in false, inappropriate criminal and protective services investigations of the ECE program.5


Caregivers/teachers can go to or for additional information on poisoning and poison safety. They can also access a variety of services that poison centers have, such as poison prevention; poison control; information about toxic substances, including lead and chemicals that may be found in consumer products; and assistance with disaster planning.


Early care and education programs can also use the webPoisonControl online tool ( or for questions about a poison or to obtain poison prevention information.5

Poison Prevention & Treatment Tips

Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS Pre-service Training Topics Covered in Pediatric First Aid Training Use and Storage of Toxic Substances Prohibition of Poisonous Plants
Appendix P: Situations that Require Medical Attention Right Away
  1. NorthShore University HealthSystem. NorthShore medical toxicology. Symptoms of poisoning, exposures & treatments. Accessed May 18, 2020
  2. KidsHealth. First aid: poisoning. Reviewed July 2018. Accessed May 18, 2020
  3. Poison Control, National Capital Poison Center. Get help from Poison Control online or by phone. Accessed May 18, 2020
  4. American Academy of Pediatrics. Poison prevention & treatment tips. website. Updated March 15, 2019. Accessed May 18, 2020

  5. Hines, E. (2016). Child abuse by poisoning. Clinical Pediatric Emergency Medicine, 17(4), 296-301.


Content in the STANDARD was modified on 8/27/2020. Informing Staff Regarding Presence of Toxic Substances

Employers should provide staff with hazard information, including access to and review of the Safety Data Sheets (SDS) as required by the Occupational Safety and Health Administration (OSHA), about the presence of toxic substances such as formaldehyde, cleaning and sanitizing supplies, insecticides, herbicides, and other hazardous chemicals in use in the facility. Staff should always read the label prior to use to determine safety in use. For example, toxic products regulated by the Environmental Protection Agency (EPA) will have an EPA signal word of CAUTION, WARNING, or DANGER. Where nontoxic substitutes are available, these nontoxic substitutes should be used instead of toxic chemicals. If a nontoxic product is not available, caregivers/teachers should use the least toxic product for the job. A CAUTION label is safer than a WARNING label, which is safer than a DANGER label.
These precautions are essential to the health and well-being of the staff and the children alike. Many cleaning products and art materials contain ingredients that may be toxic. Regulations require employers to make the complete identity of these materials known to users. Because nontoxic substitutes are available for virtually all necessary products, exchanging them for toxic products is required.
The U.S. Department of Labor, which oversees OSHA, is responsible for protection of workers and is listed in the phone books of all large cities. Because standards change frequently, the facility should seek the latest standards from the EPA. Information on toxic substances in the environment is available from the EPA. For information on consumer products contact the U.S. Consumer Product Safety Commission (CPSC). For information on art and craft materials, contact the Art and Creative Materials Institute (ACMI). The local health jurisdiction can also be a resource for information on hazardous chemicals in child care.

The SDS explains the risk of exposure to products so that appropriate precautions may be taken.

Center, Early Head Start, Head Start, Large Family Child Care Home
RELATED STANDARDS Integrated Pest Management Use and Storage of Toxic Substances Proper Use of Art and Craft Materials Pool Equipment and Chemical Storage Rooms Chlorine Pucks
  1. Wargo, J. 2004. The physical school environment: An essential component of a health-promoting school. WHO Information series on School Health, document 2. Geneva: WHO.
  2. Fiene, R. 2002. 13 indicators of quality child care: Research update. Washington, DC: U.S. Department of Health and Human Services, Office of the Assistant Secretary for Planning and Evaluation. Radon Concentrations

Content in the STANDARD was modified on 05/17/2016.


Radon concentrations inside a home or building used for child care must be less than four picocuries (pCi) per liter of air. All facilities must be tested for the presence of radon, according to U.S. Environmental Protection Agency (EPA) testing protocols for long-term testing (i.e., greater than ninety days in duration using alpha-track or electret test devices). Radon testing should be conducted after a major renovation to the building or HVAC system (1,2). 
Radon is a colorless, odorless, radioactive gas that comes from the natural breakdown of uranium in soil, rock and water, and gets into the air you breath. It can be found in soil, water, building materials, and natural gas. Radon from the soil is the main cause of radon problems. Radon typically moves up through the ground to the air above and into a home or building through cracks and other holes in the foundation. Radon can get trapped inside the home or building where it can build up. In a small number of homes, the building materials can give off radon, but the materials themselves rarely cause problems. If radon is present in the water supply, most of the risk is related to radon released into the air when water is used for showering or other household purposes (1). When radon gas is inhaled, it can cause lung cancer. Radon levels can be easily measured to determine if acceptable levels have been exceeded. The risk can be reduced by lowering the levels of radon in the home or building. Fixing buildings to reduce radon exposure may entail sealing cracks in the foundation or ventilating the area under the foundation.
The average indoor radon level is estimated to be about 1.3 pCi per liter of air, and about 0.4 pCi per liter is normally found in the outside air. Most homes today can be reduced to two picocuries per liter or below (1).

Common test kits include: charcoal canisters, e-perm, alpha track detectors, and charcoal liquid scintillation devices. To find radon resources near you, see  U.S. EPA Radon Hotlines and Information Resources or contact the National Radon Program Services.

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RELATED STANDARDS Use of Basements and Below Grade Areas Heating and Ventilation Equipment Inspection and Maintenance Construction and Remodeling
  1. U.S. Environmental Protection Agency (EPA). 2012. A citizen’s guide to radon: The guide to protecting yourself and your family from radon.
  2. U.S. Environmental Protection Agency (EPA). 1993. Radon measurement in schools: Revised edition.      

Content in the STANDARD was modified on 05/17/2016. Carbon Monoxide Detectors

Carbon monoxide detector(s) should be installed in child care settings if one of the following guidelines is met:

  1. The child care program uses any sources of coal, wood, charcoal, oil, kerosene, propane, natural gas, or any other product that can produce carbon monoxide indoors or in an attached garage;
  2. If detectors are required by state/local law or state licensing agency.

Facilities must meet state or local laws regarding carbon monoxide detectors. Detectors should be tested monthly. Batteries should be changed at least yearly. Detectors should be replaced at least every five years.

Carbon monoxide (CO) is a deadly, colorless, odorless, poisonous gas. It is produced by the incomplete burning of various fuels, including coal, wood, charcoal, oil, kerosene, propane, and natural gas. Products and equipment powered by internal combustion engine-powered equipment such as portable generators, cars, lawn mowers, and power washers also produce carbon monoxide. Carbon monoxide detectors are the only way to detect this substance.

Carbon monoxide poisoning causes symptoms that mimic the flu; mild symptoms are typically headache, dizziness, fatigue, nausea, and diarrhea. Prolonged exposure can cause confusion, shortness of breath, unconsciousness, and even death.

On average, about 170 people in the United States die every year from carbon monoxide produced by non-automotive consumer products (1). These products include malfunctioning fuel-burning appliances such as furnaces, ranges, water heaters, and room heaters; engine-powered equipment such as portable generators; fireplaces; and charcoal that is burned in homes and other enclosed areas. In 2005 alone, the U.S. Consumer Product Safety Commission (CPSC) staff was aware of at least ninety-four generator-related carbon monoxide poisoning deaths (1). Still others die from carbon monoxide produced by non-consumer products, such as cars left running in attached garages. The Centers for Disease Control and Prevention (CDC) estimate that several thousand people go to hospital emergency rooms every year to be treated for carbon monoxide poisoning (1).

Carbon monoxide detectors should be installed according to the manufacturer’s instructions. One carbon monoxide detector should be installed in the hallway outside the bedrooms in each separate sleeping area. Carbon monoxide detectors may be installed into a plug-in receptacle or high on the wall. Hard-wired or plug-in carbon monoxide detectors should have battery backup. Installing carbon monoxide detectors near heating vents, locations that can be covered by furniture or draperies, above fuel-burning appliances or in kitchens should be avoided (1).

There are a number of safety steps that child care programs can do to help prevent carbon monoxide exposure (1-3):

  1. Make sure major appliances are professionally installed and inspected according to local building codes and have older appliances checked for malfunctions and leaks;
  2. Choose vented appliances when possible;
  3. Have heating systems inspected and cleaned by a qualified technician annually and make sure the chimney is clean and with a proper draft control to ensure a proper vent for flue gases;
  4. Check the color of the flame in the burner and pilot light (a yellow-colored flame indicates the fuel is not burning efficiently and could be releasing more carbon monoxide) (4);
  5. Never use a gas oven to heat your facility;
  6. Do not burn charcoal indoors;
  7. Never operate gasoline-powered engines or generators in confined areas in or near the building;
  8. Never leave a vehicle running in a garage or closed area. Even if the garage door is open, normal circulation will not supply enough fresh air to prevent a buildup of CO gas;
  9. If the CO alarm goes off or if you have symptoms of CO poisoning, exit the building and call 9-1-1.

For other questions on CO poisoning call the poison center.

Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
  1. U.S. Consumer Product Safety Commission (CPSC). 2008. Carbon monoxide questions and answers. Document #466. Bethesda, MD: CPSC.
  2. Cowling, T. 2007. Safety first: Carbon monoxide poisoning. Healthy Child Care 10(5): 6-7.
  3. Safe Kids Worldwide.  Home Safety Fact Sheet.
  4. Tremblay, K. R., Jr. 2006. Preventing carbon monoxide problems. Colorado State University Extension. Preventing Exposure to Asbestos or Other Friable Materials

Any asbestos, fiberglass, or other friable material or any material that is in a dangerous condition found within a facility or on the grounds of the facility should be repaired or removed. Repair usually involves either sealing (encapsulating) or covering asbestos material. Any repair or removal of asbestos should be done by a contractor certified to do in accordance with existing regulations of the U.S. Environmental Protection Agency (EPA). No children or staff should be present until the removal and cleanup of the hazardous condition have been completed.

Pipe and boiler insulation should be sampled and examined in an accredited laboratory for the presence of asbestos in a friable or potentially dangerous condition.

Non-friable asbestos should be identified to prevent disturbance and/or exposure during remodeling or future activities.

Removal of significant hazards will protect the staff, children, and families who use the facility. Asbestos dust and fibers that are inhaled and reach the lungs can cause lung disease (1,2).
The mere presence of asbestos in a child care facility, home, or a building is not hazardous. The danger is that asbestos materials may become damaged over time. Damaged asbestos may release asbestos fibers and become a health hazard (2,3). The best thing to do with asbestos material that is in good condition is to leave it alone. Disturbing it may create a health hazard where none existed before (1).

Asbestos that is in a friable condition means that it is easily crumbled (2).

The National Asbestos School Hazard Abatement Act of 1984 specifies requirements for removal of asbestos. Contact your local health department for additional information on asbestos regulations in your area. For more information regarding asbestos and applicable EPA regulations, contact regional offices of the EPA.

Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
  1. U.S. Consumer Product Safety Commission (CPSC). Asbestos in the home.
  2. U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry. 2001. Toxicological profile for asbestos.
  3. Fiene, R. 2002. 13 indicators of quality child care: Research update. Washington, DC: U.S. Department of Health and Human Services, Office of the Assistant Secretary for Planning and Evaluation. Proper Use of Art and Craft Materials

Only art and craft materials that are approved by the Art and Creative Materials Institute (ACMI) should be used in the child care facility. Art and craft materials should conform to all applicable ACMI safety standards. Materials should be labeled in accordance with the chronic hazard labeling standard, ASTM D4236.

The facility should prohibit use of unlabeled, improperly labeled old, or donated materials with potentially harmful ingredients.

Caregivers/teachers should closely supervise all children using art and craft materials and should make sure art and craft materials are properly used, cleaned up, and stored in original containers that are fully labeled. Materials should be age-appropriate. Children should not eat or drink while using art and craft materials.

Caregivers/teachers should have emergency protocols in place in the event of an injury, poisoning, or allergic reaction. If caregivers/teachers suspect a poisoning may have occurred they should call their poison center at 1-800-222-1222. Rooms should be well ventilated while using art and craft materials.

Only ACMI-approved unscented water-based markers should be used for children’s art projects and work.

Contamination and injury may occur if art and craft materials are improperly used or labeled. Labels are required on art supplies to identify any hazardous ingredients, risks associated with their use, precautions, first aid, and sources of further information (1).

Art material, approved by the ACMI, has been tested for both chronic and acute health hazards. The ACMI AP (Approved Product) Seal, with or without Performance Certification, identifies art materials that are safe and that are certified in a toxicological evaluation by a medical expert to contain no materials in sufficient quantities to be toxic or injurious to humans, including children, or to cause acute or chronic health problems. This seal is currently replacing the previous non-toxic seals: CP (Certified Product), AP (Approved Product), and HL Health Label (Non-Toxic) over a ten-year phase-in period. Such products are certified by ACMI to be labeled in accordance with the chronic hazard labeling standard, ASTM D4236, and the U.S. Labeling of Hazardous Art Materials Act (LHAMA). Additionally, products bearing the AP Seal with Performance Certification or the CP Seal are certified to meet specific requirements of material, workmanship, working qualities, and color developed by ACMI and others through recognized standards organizations, such as the American National Standards Institute (ANSI) and ASTM International. Some products cannot attain this performance certification because no quality standard currently exists for certain types of products (1).

Children have been known to try and eat fruit-scented markers. Solvent-based/permanent markers can trigger headaches and/or asthma (3).

Non-toxic art and craft supplies intended for children are readily available.

Some products labeled “non-toxic” are not necessarily a safer alternative; thus the need to check for the proper labeling.

Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS Ventilation When Using Art Materials
  1. Art and Creative Materials Institute. 2010. Safety - what you need to know.
  2. Fiene, R. 2002. 13 indicators of quality child care: Research update. Washington, DC: U.S. Department of Health and Human Services, Office of the Assistant Secretary for Planning and Evaluation.
  3. U.S. Consumer Product Safety Commission (CPSC). Art and craft safety guide. Bethesda, MD: CPSC. Use of Play Dough and Other Manipulative Art or Sensory Materials

The child care program should have the following procedures on the use and life span of manipulative art or sensory materials such as clay, play dough, etc:

  1. If handmade, these materials should be made fresh each week, labeled, dated and stored in airtight containers;
  2. If purchased, these products should be stored in their original packaging;
  3. Products that are labeled as toxic are prohibited;
  4. The surface upon which they are used and the tools used with these materials should be cleaned and sanitized before and after use;
  5. Children should practice hand hygiene before and after each use;
  6. Material should be discarded if it is sneezed upon, put into a child’s mouth, or in any other way possibly contaminated;
  7. Children with latex or gluten allergies should be given their own portion of the material and that individual portion should be stored separately if for repeat use.
  8. Children with cuts, sores, scratches and colds with sneezing and runny noses should be given their own portion of the material and that individual portion should be stored separately if for repeat use.
Hand hygiene, supervision of children, and discarding material that is contaminated are appropriate hygienic practices when using these materials. Providing children with their own portion of modeling material helps prevent cross-contamination (1).
Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS Situations that Require Hand Hygiene
  1. Life Tips. Cutting down on playdough germs.
    -coping/cutting-down-on-playdough-germs.html. Plastic Containers and Toys

The facility should use infant bottles, plastic containers, and toys that do not contain Polyvinyl chloride (PVC), Bisphenol A (BPA), or phthalates. When possible, caregivers/teachers should substitute materials such as paper, ceramic, glass, and stainless steel for plastics.
Plastics can contain chemicals and metals, which are used as additives and stabilizers. Some of these additives and stabilizers can be toxic, such as lead (e.g., toys, vinyl lunchboxes). Plastics can release chemicals into food and drink; some types of plastics are more likely to do so than others (polycarbonate, PVC, polystyrene). Effects are not fully studied or understood, but in animal studies, some plastics have been tied to a wide range of negative health effects including endocrine (hormone) disruption and cancer (1,11).

PVC, also known as vinyl, is one of the most commonly used types of plastics today. PVC is present in many things used daily, from water bottles and containers, to wallpaper, wall paneling, credit cards, and children’s toys. Some of the substances added to PVC are among the hormone-disrupting chemicals that may pose hazards to human health and child development. PVC products, including certain toys, may have chemicals such as lead, cadmium, and phthalates, which can flake, leach, or off-gas, causing the release of these chemicals into the surroundings (2).

Phthalates is a class of chemicals used to make plastics flexible (3,4,11). Phthalates are used in many products: vinyl flooring, plastic clothing (e.g., raincoats), detergents, adhesives, personal-care products (fragrances, nail polish, soap), and is commonly found in vinyl (PVC) plastic products (toys, plastic bags) (13). In a national study, some phthalates have been found in 97% (5) of the people tested with generally higher concentrations found in children (6). In animal studies, health effects range from developmental and reproductive toxicity to damage to the liver (7,8).

Bisphenol A (BPA) is used when making polycarbonate and other plastic products. BPA is widely used in consumer products (infant bottles, protective coating in food cans, toys, containers, and personal care products) (13). It can leach from these products and potentially cause harm to those in contact with them. It can also have estrogen (female hormone)-like effects, which may impact biological systems at very low doses. Children may be exposed via: ingestion (diet and sucking/mouthing plastics), inhalation (of dust), and dermal contact. A national study found BPA in the urine of over 90% of people tested; children were found to have higher levels than adults (9). BPA has been found in pregnant women, umbilical cord blood, and placentas at levels demonstrated in animals to alter development (10).

The Consumer Product Safety Improvement Act (CPSIA) empowers the U.S. Consumer Product Safety Commission (CPSC) to set regulations protecting consumers of these products with testing and labeling. As of this writing new CPSC requirements are under development. Consumers of products for children should look for products that state “phthalate-free” or “BPA-free” or certification by Toy Safety Certification Program (TSCP) or American National Standards Institute (ANSI).

Following are guidelines by which caregivers/teachers may reduce exposure to phthalates and BPA:

  1. When possible, opt for glass, porcelain or stainless steel containers, particularly for hot food or liquids (12);
  2. If using plastic, do not use plastic or plastic wrap for heating in microwave (try substituting a paper towel or waxpaper for covering foods) (12);
  3. Check the symbol on the bottom of the plastic items including toys before buying. The plastics industry has developed identification codes to label different types of plastic. The identification system divides plastic into seven distinct types and uses a number code generally found on the bottom of containers. For a table that explains the seven code system, go to Contact the manufacturer if there is a question about the chemical content of a plastic item;
  4. Best plastic choices are 1 (PETE), 2 (HDPE), 4 (LDPE), 5 (PP) and plastics labeled “phthalate-free” or “BPA-free”;
  5. Avoid plastics labeled 3 (V), 6 (PS), and 7 (PC). Polycarbonate containers that contain BPA usually have a number 7 on the bottom;
  6. Use alternatives to polycarbonate “7” infant bottles. Alternatives include glass infant bottles, BPA free, and products made of safer plastics such as polyethylene and polypropylene that are less likely to release harmful plasticizers (12) (safer non-polycarbonate bottles are usually cloudy and squeezable);
  7. Do not use latex rubber nipples or plastic bottle liners;
  8. Avoid canned foods when possible;
  9. If infant formula is used, it is best to use powdered formula in a can;
  10. Do not place plastics in the dishwasher;
  11. If using hard polycarbonate plastics (PC) such as water bottles/infant bottles, do not use for warm/hot liquids;
  12. Dispose of plastic bottles when they are old and scratched;
  13. Toys should be certified by the Toy Safety Certification Program (TSCP) or American National Standards Institute (ANSI).

For more tips on safer food use of plastics, see the Institute for Agriculture and Trade Policy (IATP) Website: Smart Plastics Guide: Healthier Food Uses of Plastics, available at

For more tips on safer alternatives to PVC plastics, see the Center for Health, Environment, and Justice (CHEJ) Website: The Campaign for Safe Healthy Consumer Products, available at

For general information on plastics and on how to recycle them, see the U.S. Environmental Protection Agency (EPA) Website: Common Wastes and Materials: Plastics, at

Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS Product Recall Monitoring
  1. Eco-Healthy Child Care. 2010. Plastics and plastic toys. Children’s Environmental Health Network.
  2. BE SAFE. The dangers of polyvinyl chrloride (PVC).
  3. Huff, J. 1982. Di(2-ethylhexyl) adipate: Condensation of the carcinogenesis bioassay, technical report.Environ Health Perspectives 45:205-7.
  4. Kluwe, W. M. 1986. Carcinogenic potential of phthalic acid esters and related compounds: Structure-activity relationships. Environ Health Perspectives 65:271-78.
  5. Silva, M. J., D. B. Barr, J. A. Reidy, et al. 2004. Urinary levels of seven phthalate metabolites in the U.S. population from the National Health and Nutrition Examination Survey (NHANES), 1999-2000. Environ Health Perspectives 112:331-38.
  6. Kolarik, B., K. Naydenov, M. Larsson, et al. 2008. The association between phthalates in dust and allergic diseases among Bulgarian children. Environ Health Perspectives 116:98-103.
  7. Centers for Disease Control and Prevention (CDC). 2009. Fourth national report on human exposure to environmental chemicals. Atlanta, GA: CDC.
  8. Blount, B. C., M. Silva, S. Caudill, et al. 2000. Levels of seven urinary phthalate metabolites in a human reference population. Environ Health Perspectives 108:979-82.
  9. Calafat, A. M., X. Ye, L. Wong, et al. 2008. Exposure of the U.S. population to bisphenol A and 4-tertiary-octylphenol: 2003-2004. Environ Health Perspectives 116:39-44.
  10. Ikezuki, Y., O. Tsutsumi, Y. Takai, Y. Kamei, Y. Taketani. 2002. Determination of bisphenol A concentrations in human biological fluids reveals significant early prenatal exposure. Human Reproduction 17:2839-41.
  11. American Academy of Pediatrics. 2007. Technical report: Pediatric exposure and potential toxicity of phthalate plasticizers. Pediatrics 119:1031.
  12. California Childcare Health Program (CCHP). 2008. Banning chemicals called phthalates in childhood products. Berkeley, CA: CCHP.
  13. U.S. Consumer Product Safety Commission. 2009. Prohibition on the sale of certain products containing specified phthalates. Prohibition of Poisonous Plants

Poisonous or potentially harmful plants are prohibited in any part of a child care facility that is accessible to children. All plants not known to be nontoxic should be identified and checked by name with the local poison center (1-800-222-1222) to determine safe use.
Plants are important to our health and well-being and are a great lesson in learning to understand and respect our environment. However, some plants can be harmful when eaten or touched (1,2). Plants are among the most common household substances that children ingest. Determining the toxicity of every commercially available household plant is difficult. A more reasonable approach is to keep any unknown plant out of the environment that children use. All outdoor plants and their leaves, fruit, and stems should be considered potentially toxic (1).
Cuttings, trimmings, and leaves from potentially harmful plants must be disposed of safely so children do not have access to them.

For toxic, frequently ingested products and plants, see the American Academy of Pediatrics’ (AAP) Handbook of Common Poisonings in Children, available at

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Appendix Y: Non-Poisonous and Poisonous Plants
  1. American Academy of Pediatrics. 2011. Handbook of common poisonings in children. 4th ed. Elk Grove Village, IL: AAP.
  2. Fiene, R. 2002. 13 indicators of quality child care: Research update. Washington, DC: U.S. Department of Health and Human Services, Office of the Assistant Secretary for Planning and Evaluation. Chemicals Used to Control Odors

Content in the STANDARD was modified on 8/25/2016.


The use of the following should be prohibited:

  1. Incense;
  2. Moth crystals or moth balls;
  3. Air fresheners or sanitizers (both manmade and natural, e.g. essential oils); and
  4. Toilet/urinal deodorizer blocks (1,2).
Many chemicals are sold to cover up noxious odors or ward off pests. Many of these chemicals are hazardous (3). As an alternative, caregivers/teachers should remove the source of noxious odors to the extent possible by dissipating noxious odors through cleaning and ventilation (e.g., opening windows) and controlling pests using nontoxic methods.

Toilet/urinal deodorizer blocks commonly contain para-dichlorobenzene (PDCB), a toxic chemical, designated as a possible human carcinogen (4), that has no cleaning function. These deodorizers only serves to mask odors that should be eliminated by proper cleaning.

Contact the poison center at 1-800-222-1222 or the U.S. Environmental Protection Agency (EPA) Regional offices listed in the federal agency section of the telephone directory for assistance in identifying hazardous products.
Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS Ensuring Access to Fresh Air Indoors Integrated Pest Management
  1. Potera, C. (2011). Scented Products Emit a Bouquet of VOCs. Environmental Health Perspectives 119(1), a16.  
  2. Fiene, R. 2002. 13 indicators of quality child care: Research update. Washington, DC: U.S. Department of Health and Human Services, Office of the Assistant Secretary for Planning and Evaluation.
  3. U.S. Centers for Disease Control and Prevention. The National Institute for Occupational Safety and Health (NIOSH). 2015.Indoor environmental quality.
  4. Suhua, W., L. Rongzhu, Y. Changqing, X. Guangwei, H. Fangan, J. Junjie, X. Wenrong, M. Aschner. 2010. Lipid peroxidation and changes of trace elements in mice treated with paradichlorobenzene. Biol Trace Elem Res 136:320-36.
  5. Focus (1998). Scents and Sensitivity. Environmental Health Perspectives 106(12), A594-A599.
  6. Children’s Environmental Health Network. (March 2016). Fragrances. Retrieved from

Content in the STANDARD was modified on 8/25/2016. Treatment of CCA Pressure-Treated Wood

Content in the STANDARD was modified on 8/25/2016.


Two coats of waterproof stain or sealant (e.g., semi-transparent stain, but not paint) should be applied at least once a year if it is oil-based, and twice a year if it is water-based - to all chromated copper arsenate (CCA)-treated surfaces (playground equipment, benches, decks, picnic tables) to which a child may have access. High-traffic areas may require more frequent treatments. Children should not be allowed to eat while playing on the equipment, and should be instructed to wash their hands after playing on CCA-treated surfaces. Cover picnic tables with a plastic coated (non-PVC) tablecloth; avoid contact of food and drink with CCA-treated wood. These precautions should be followed even if a protective coating has been applied to CCA treated wood (1,2).

Care must be used in the handling and maintenance of any CCA-treated wooden structures. For instance, burning CCA-treated wood will release arsenic into the air, and sanding or cutting CCA-treated wood will create toxic dust. Do not power wash or apply harsh cleaning products, such as bleach or acidic cleansers to CCA treated wood. Use a mild soap and water solution and disposable cleaning supplies. When disposing of items made of CCA-treated wood, they should be taken to a hazardous waste facility (1,2).
The Consumer Product Safety Commission advises that arsenic exposure in children from contact with CCA-treated wood playground structures is estimated to be about 3.5 micrograms each day that includes a playground visit (3).The health effects related to arsenic include irritation of the stomach and intestines, birth or developmental effects, cancer, and infertility and miscarriages in women (1,3). Children can be exposed to the arsenic in CCA-treated wood by touching surfaces made from this material (3). Based on limited data, applying certain penetrating coatings may reduce the amount of arsenic that comes out of the wood (3).

The Safety Data Sheet (SDS) for every chemical product that the facility uses should be checked and available to anyone who uses or who might be exposed to the chemical in the child care facility to be sure that the chemical does not pose a risk to children and adults.
CCA-treated wood is found extensively in outdoor structures, furniture, and play equipment built prior to December 31, 2003 when manufacturers of CCA reached a voluntary agreement with the Environmental Protection Agency (EPA) to end the manufacture of CCA-treated wood for most consumer applications. EPA has indicated that some stocks of wood treated with CCA before this date might have been found on shelves until mid-2004. If a wooden structure was built prior to December 31, 2003 and is not of a rot-resistant type of wood (e.g., redwood, cedar) it is safe to assume it does contain arsenic. If the date the equipment was built is unknown or was built shortly after December 31, 2003, test kits are available from many common retailers.

While available data are very limited, some studies suggest that applying certain penetrating coatings (e.g., oil-based, semi-transparent stains) on a regular basis may reduce the migration of wood preservative chemicals from CCA-treated wood (4). In selecting a finish, caregivers/teachers should be aware that, in some cases, “film-forming” or non-penetrating stains on outdoor surfaces such as decks and fences are not recommended, as subsequent peeling and flaking may ultimately have an impact on durability as well as exposure to the preservatives in the wood.

To eliminate the risk of children’s exposure to arsenic from CCA-treated wood it is recommended it be replaced. If this is not feasible, replacing the components children come in contact with the most (e.g., handrails, retaining walls) will limit their exposure.

Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS Enclosures for Outdoor Play Areas Play Equipment Requirements Inspection of Indoor and Outdoor Play Areas and Equipment
  1. Children’s Environmental Health Network. (March 2016). Chromated Copper Arsenate (CCA). Retrieved from
  2. Gray, S., J. Houlihan. 2002. All hands on deck: Nationwide consumer testing of backyard decks and playsets shows high levels of arsenic on old wood. Washington, DC: Environmental Working Group.
  3. U.S. Consumer Product Safety Commission (CPSC). Fact sheet: Chromated copper arsenate (CCA)-treated wood used in playground equipment.
  4. U.S. Environmental Protection Agency. 2008. Chromated copper arsenate (CCA): Consumer advice related to CCA-treated wood.

Content in the STANDARD was modified on 8/25/2016. Testing for and Remediating Lead Hazards

Content in the standard was modified on 08/15/2014 and 04/27/2021.

Lead can be found in all parts of our environment-the air, the soil, the water, and even inside our homes. Because of the highly toxic nature of lead, early care and education (ECE) programs should test and remediate lead hazards in paint and dust, water, soil, and consumer products.

Paint and Dust: Paint and other surface-coating materials used in ECE facilities, including family child care homes (both rental and owned), should be labeled for residential (not industrial) applications only.

All ECE facilities built before 1978

  • Should be inspected and tested for lead-based paint hazards by a certified lead inspector or certified risk assessor for the following reasons 
    • If lead is identified in either the interior or exterior paint of the facility, ECE facilities should consult their state or local childhood lead poisoning prevention program, public health agency, and/or a certified risk assessor to determine the best steps for lead hazard control work.
    • Surfaces found to have lead-based paint hazards should not be used and should be made inaccessible to children and staff until remediated.
    • ECE facilities should hire a certified lead abatement contractor to do lead hazard control work. ECE facilities should be sure to test for lead dust clearance to ensure proper cleanup was done after lead hazard control work. 
    • ECE facilities should implement an occupant protection plan during lead remediation work.
  • Should conduct annual inspections of paint and perform routine maintenance to ensure that paint remains intact 
  • Should use an Environmental Protection Agency (EPA)-certified lead-safe contractor (also known as a renovation, repair, and painting, or RRP, contractor) if any repair or renovation work (not lead hazard control work) is needed

Water: ECE facilities should learn the source (public or private) of their water and determine whether the facility has a lead service line or lead-containing pipes, fixtures, or solder. They should test water for lead and take steps to remediate sources if the water contains lead.

Soil: Bare soil around ECE facilities should be tested by an EPA-recognized National Lead Laboratory Accreditation Laboratory (NLLAP) or covered with mulch, plantings, or grass.

Consumer Products: Caregivers/teachers should check the U.S. Consumer Product Safety Commission’s website ( for warnings of potential lead exposure to children and recalls of play equipment, toys (especially antique and imported), jewelry used for play, imported vinyl mini-blinds, and food contact materials. If they are found to have lead, the items should be removed from the facility.

Only a certified lab can accurately test toys and products for lead contamination. “Test it yourself” kits or lead wipes (often purchased online or from large home improvement stores) are not recommended. Kits and wipes do not show how much lead is present, and their reliability at detecting low levels of lead has not been established.

Caregivers/teachers should not give children in their care imported candy, herbal remedies, or folk medicines.



Lead is especially dangerous to children, because their brains and nervous systems are more sensitive to lead’s damaging effects, and their young bodies are able to absorb more lead. Plus, babies and young children often put their hands and other objects in their mouths. These objects may have lead dust on them, particularly if a child is crawling on floors contaminated with lead dust. Once ingested, lead competes with calcium and can be stored in bones, teeth, and organs for decades, making lead poisoning difficult to treat. Lead-based paint is the most common source of lead exposure and poisoning in children.1,2

Children under the age of 6 are at the greatest risk for lead poisoning. Most children with lead poisoning do not look or act sick. A blood lead test is the only way to know if children are being lead poisoned. The U.S. Centers for Disease Control and Prevention (CDC) uses a blood lead reference value of 5 micrograms per deciliter (mcg/dL) to identify children with blood lead levels that are much higher than most children’s levels.3,4 Lead is a neurotoxin. Even at low levels of exposure, children can suffer seriously from lead poisoning, leading to behavior and learning problems, lower IQ, hyperactivity, slowed growth, hearing problems, and anemia. There is no safe blood lead level in children.5

Lead may be present in paint, dust, water, or soil. It may also be present in consumer products like food, candies, spices, pottery/dishes, traditional medicines, cosmetics, toys, jewelry, and painted furniture.

Paint and Dust:The manufacture of residential lead-based paint was banned in the United States in 1978, but many older homes around the country still contain it. When lead-based paint inside a home deteriorates or is located on a friction surface, chips and dust settle on surfaces children can easily reach, such as windowsills and floors. Contaminated dust can be inhaled or ingested and is hazardous even if the particles are too small to see. 

Water:ECE facilities built after 1986 likely do not have a lead service line; however, all ECE facilities, regardless of age, may have pipes and fixtures that contain lead (such as brass fixtures). In addition, unforeseen events (such as the one that occurred in Flint, MI, in 2014) may cause public drinking water to become contaminated with lead.

Soil:Lead can be found in soil as a result of the historic use of lead-based paint on building interiors and exteriors and leaded gasoline for cars, the current use of leaded gas by small airplanes, and industries that put lead into the environment. Soil on the property could be contaminated if the facility is next to a busy highway or high-traffic road or if it was built before 1978. In addition, if the facility is located in or near a current or former industrial area, the soil could be contaminated with lead.

Children may be exposed to lead-contaminated soil by playing in bare dirt. The main way children get lead from soil into their bodies is ingestion, most commonly by touching dirt and putting their hands in their mouths.

Consumer Products: Certain children’s products are known to have a higher risk of containing lead such as inexpensive children’s jewelry, imported pottery, antique toys, and imported toys. The use of lead in plastics has not been banned, so certain plastic toys made with vinyl/ polyvinyl chloride (PVC) [including bath books, teethers, rubber duckies, bath toys, dolls, beach balls, backpacks, pencil cases, and shower curtains] may contain lead. Lead may also be present in certain herbal remedies, folk medicines, and imported spices and foods.


A state or local childhood lead poisoning prevention program, health department, and/or a certified risk assessment professional can help ECE facilities write a remediation plan to reduce any identified paint, water, or soil hazards. This plan may call for one of two types of lead hazard control work

      Interim Controls: These are measures that minimize lead hazards and include dust removal, paint stabilization, and/or control of friction/abrasion points. These measures ensure no one is exposed to lead-based paint hazards. Some intact lead-based paint may remain in the facility if it will not pose a hazard. These controls have been found to be effective, while less expensive than full abatement.

      Lead Abatement: These are measures that permanently remove lead-based paint and include component replacement (such as windows and windowsills), paint removal, enclosure, or encapsulation of lead-based paint. Lead abatement involves specialized techniques and must be conducted by EPA-certified lead abatement contractors.6,7

EPA certifies lead abatement contractors to conduct either interim controls or lead abatement. These lead hazard control activities disturb lead-based paint and can create lead dust. Lead clearance testing will determine if contractors properly cleaned up after lead hazard control work and if work areas are safe for reoccupancy.7

For RRP work conducted independently from lead hazard control work in pre-1978 homes, EPA certifies lead-safe contractors, also known as RRP contractors. RRP contractors are trained to use lead-safe work practices when conducting tasks that may disturb lead-based paint, but they are not trained to perform lead hazard control work.

State-level programs and local funding resources may be available if financial support is needed for inspection, risk assessment, or remediation services.

Below is a list of general contact information and resources to answer questions, locate lead professionals, and handle other issues:


General Contacts

      EPA regional offices can respond to inquiries about lead and lead poisoning. A list of regional contacts is on at EPA’s Contacts in EPA Regional Offices for Lead Poisoning Prevention Efforts website.

      ECE facilities can call the National Lead Information Center and speak with an information specialist Monday through Friday, 8:00 am to 6:00 pm Eastern, at 800-424-LEAD.

      The CDC has a list of state and local childhood lead poisoning prevention programs.

      More resources available on the Lead-Safe Toolkit for Home-Based Child Care: General ResourcesWeb page.

Lead in Paint Contacts

      An EPA booklet called Protect Your Family from Lead in Your Home explains the dangers of lead and how to protect your family and those in your care from lead-based paint hazards.

      EPA’s webpage, Locate Certified Renovation and Lead Dust Sampling Technician Firms, can help ECE facilities find an inspection or risk assessment firm. This website also contains RRP contractor information.

      A local health department or childhood lead poisoning prevention program may be able to provide information on lead-based paint inspection and testing. The National Association of County and City Health Officials maintains a searchable Directory of Local Health Departments.

      RRP contractors must provide a copy of the EPA pamphlet The Lead-Safe Certified Guide to Renovate Rightto ECE facilities and general renovation information to families whose children attend those ECE facilities.

      A description of steps to identify if ECE facilities have lead in paint hazards and more lead in paint resources are in The Lead-Safety Toolkit for Home-Based Child Care: Lead in Paint.

Lead in Soil Contacts

Labs for soil analysis are on EPA’s list of NLLAP labs. The lab may go to the facility and collect the soil samples, or it may provide instructions, sampling materials, and forms so the facility can collect and submit the samples. State and local lead poisoning prevention programs may have more instructions. A description of steps to identify if ECE facilities have lead in soil hazards and more lead in soil resources are in The Lead-Safe Toolkit for Home-Based Child Care: Lead in Soil.

Lead in Water Contacts

      ECE facilities can call EPA’s Safe Drinking Water Hotline at 800-426-4791 to find local contact information for testing water.

      If facility water comes from a community water system, local water utility staff may be able to test the water or provide a referral to an EPA-accredited lab in your region (see the NLLAP website).

      Module 6 of EPA’s 3Ts: Training, Testing, Taking ActionRemediation and Establishing Routine Practices, lists short- and long-term (permanent) measures to reduce exposures to lead-contaminated drinking water. The document also contains information about how to hire a licensed contractor to replace lead service lines or other lead-containing pipes and fixtures.

      EPA’s pamphlet How to Identify Lead Free Certification Marks for Drinking Water System & Plumbing Products contains information on how to identify lead-free plumbing.

      A description of steps to take when identifying if ECE facilities have lead in water hazards and more lead in water resources can be found in The Lead-Safe Toolkit for Home-Based Child Care: Lead in Drinking Water.

Lead in Consumer Products Contacts

      ECE facilities are encouraged to consult the United States Consumer Product Safety Commission (CPSC)’s web site, www.cpsc.govor more information on product recalls.

      ECE programs are encouraged to consult CPSC recall notices, as well as state and local governments, for more information about proper disposal of lead-contaminated consumer products.

      A description of steps to take to identify if ECE facilities have lead in consumer products hazards and a list of additional lead in consumer product resources can be found in The Lead-Safe Toolkit for Home-Based Child Care: Lead in Consumer Products Worksheet.

      The CDC provides more information on potential lead levels in spices, herbal remedies, and ceremonial powders in Lead in Spices, Herbal Remedies, and Ceremonial Powders Sampled from Home Investigations for Children with Elevated Blood Lead Levels — North Carolina, 2011–2018.

Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS Testing for Lead and Copper Levels in Drinking Water Construction and Remodeling Product Recall Monitoring
  1. Centers for Disease Control and Prevention. Lead in Paint. Reviewed November 24, 2020. Accessed March 9, 2021.

  2. National Center for Healthy Housing.  Lead-Safe Toolkit for Home-Based Child Care: General Resources. Accessed March 9, 2021. 

  3. Advisory Committee on Childhood Lead Poisoning Prevention, Centers for Disease Control and Prevention. Low Level Lead Exposure Harms Children: A Renewed Call for Primary Prevention. Published January 4, 2012. Accessed March 9, 2021.

  4. Centers for Disease Control and Prevention. Blood Lead Levels in Children. Reviewed May 28, 2020. Accessed March 9, 2021.

  5. Centers for Disease Control and Prevention. Lead Poisoning Prevention. Reviewed May 30, 2019. Accessed March 9, 2021.

  6. U.S. Environmental Protection Agency. Lead Abatement Versus Lead RRP. Accessed March 9, 2021.

  7. Department of Housing and Urban Development. Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing. 2012 Edition. Accessed March 9, 2021.


Content in the standard was modified on 08/15/2014 and 04/27/2021. Shoes in Infant Play Areas

Adults and children should remove or cover shoes before entering a play area used by a specific group of infants. These individuals, as well as the infants playing in that area, may wear shoes, shoe covers, or socks that are used only in the play area for that group of infants.
When infants play, they touch the surfaces on which they play with their hands, and then put their hands in their mouths. Lead and other toxins in soil around a facility can be a hazard when tracked into a facility on shoes (1).
Facilities can meet this standard in several ways. The facility can designate contained play surfaces for infant play on which no one walks with shoes. Individuals can wear shoes or slippers that are worn only to walk in the infant play area or they can wear clean cloth or disposable shoe covers over shoes that have been used to walk outside the infant play area.

This standard applies to shoes that have been worn outdoors, in the play areas of other groups of children, and in toilet and diaper changing areas. All of these locations are potential sources of contamination.

Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
  1. U.S. Environmental Protection Agency. 2009. Lead in paint, dust and soil: Basic information.
    leadinfo.htm. Construction and Remodeling

Content in the STANDARD was modified on 05/17/2016 and 09/27/2022.

Early care and education programs should protect children and staff from injury or illness caused by building construction and renovation.

Programs should do the following:

  • Review applicable zoning, building, fire codes; environmental assessments; child care licensing; and other governmental requirements before beginning a project.1 For more information on building construction, see the ATSDR Chose Safe Places Program.
  • Schedule construction, renovation, repair, painting, or other updates of facilities when no children are present (e.g., weekends) if possible.
  • Keep the areas undergoing construction, renovation, repair, painting, or other updates separate from the areas that children are using.
  • Keep the required minimum number of exit/escape paths while the work is being done.
  • Choose products and methods that prevent exposure to fumes, dust, paint chips, and other safety hazards, especially if work must occur while children are present, by:
    • Minimizing use of shared pathways between work areas and children’s areas to reduce spread of dust and debris 
    • Using nontoxic materials or the least toxic materials available
    • Using only paint and surface-coating materials that are labeled for residential use, not industrial use
    • Using low volatile organic compounds (VOC) paints and materials, or odorless, VOC-free products in child care areas 
    • Ventilating painted areas until fully dry and odor-free before allowing children in the areas

All early care and education programs in facilities built before 1978, including home-based programs, should reduce potential exposure to lead dust contamination,2 by: 

  • Having a certified lead inspector or certified risk assessor find lead-based paint hazards before beginning renovation, including painting
  • Consulting a state or local childhood lead poisoning prevention program, public health agency, or certified risk assessor to decide on the best steps for lead hazard control work if the inspection finds lead in interior or exterior paint, soil, or water
  • Using a certified lead-safe contractor/renovator for current and future repairs, renovation, or painting Being aware of any construction and renovation plans, and sharing plans with ECE staff and families

Home-based ECE programs in buildings built before 1978 should also review The Lead-Safe Toolkit for Home-Based Child Care before planning or starting construction and renovation projects.3

Construction and renovation of early care and education program facilities must comply with all applicable building and zoning codes of the state and locality, as well as any federal requirements. Depending on the extent of the project, consulting with an architect or qualified contractor may be needed to make sure the project will be safe.1

During a project, programs must protect children from potential injury or illness from exposure to project equipment, materials, activities, fumes, dust, and debris by following the steps in this standard. Many construction and renovation products have VOCs that are released as gases from some products (e.g., sealants). These gases can cause eye irritation, nose and throat discomfort, headache, allergic skin reaction, difficulty breathing, nausea, vomiting, nose bleeds, fatigue, and dizziness.4 Some VOCs cause significant health problems such as asthma.5,6 

Lead was often added to paint before 1978, so older buildings are likely to have lead-based paint.2 Lead has toxic effects on the nervous system, and there is no safe level of lead exposure for young children.7,8,9 Those under age 6 are at the greatest risk for the extremely harmful effects of lead poisoning on health, intelligence, and behavior.10,11 For a pre-1978 facility, federal law requires hiring firms, contractors, electricians, plumbers, or maintenance staff who are lead-safe certified and trained in lead-safe work practices:
When work will disturb painted surfaces (more than 6 square feet of interior surfaces or 20 square feet of exterior painted surfaces)
When windows will be replaced
This federal requirement also applies to the renovation of home-based ECE programs (see The Lead-Safe Toolkit for Home-Based Child Care). 

Before renovation begins, contractors must give the EPA pamphlet The Lead-Safe Certified Guide to Renovate Right to early care and education programs in the building, and must give general project information to families of children under age 6 who live or are served in the building.2 

For more information on lead hazards in early care and education programs, see Standard Testing for and Remediating Lead Hazards.
When it is not possible to schedule construction and renovation activities outside the hours of program operation, or children live in a home-based program, temporary barriers can be put up around the work area to limit children’s access. Plastic vapor barrier sheeting may be used to reduce, but not totally prevent, dust moving into areas where children are present. For a useful resource, see Indoor Air Quality, by the California Childcare Health Program, University of California San Francisco.12,13

To find qualified lead-safe firms and contractors, also known as RRP (renovation, repair, and painting) contractors, see the EPA service Locate Certified Inspection, Risk Assessment, and Abatement Firms.13 A list of lead-safe work practices, from investigation and planning through clean-up and waste disposal, that contractors and renovators must follow is in Steps to Lead-Safe Renovation, Repair and Painting, by the EPA.14 
Center, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS Inspection of Buildings Structurally Sound Facility Radon Concentrations Preventing Exposure to Asbestos or Other Friable Materials Treatment of CCA Pressure-Treated Wood Testing for and Remediating Lead Hazards Indoor and Outdoor Equipment, Materials, and Furnishing Surfaces of Equipment, Furniture, Toys, and Play Materials Inaccessibility of Hazardous Equipment
  1. Fund for Quality. Childcare center design development recommendations. Fund for Quality Web site. Published July 2017. Accessed December 17, 2021.

  2. U.S. Environmental Protection Agency. The lead-safe certified guide to renovate right. Web site. Accessed December 21, 2021.

  3. Children’s Environmental Health Network, National Center for Health Housing, National Association for Family Child Care. Lead-safe toolkit for home-based child care. National Center for Healthy Housing Web site. Published 2019. Accessed December 21, 2021.

  4. U.S. Environmental Protection Agency. Volatile organic compounds’ impact on indoor air quality. Web site. Accessed December 20, 2021.

  5. Alford KL, Kumar N. Pulmonary health effects of indoor volatile organic compounds¾a meta-analysis. Int J Environ Res Public Health. 2021;18(4):1578. doi:10.3390/ijerph18041578

  6. Saif NT, Janecki JM, Wanner A, Colin AA, Kumar N. Pediatric asthma attack and home paint exposure. Int J Environ Res Public Health. 2021;18(8):4118. doi:10.3390/ijerph18084118

  7. American Academy of Pediatrics, Council on Environmental Health. Prevention of childhood lead toxicity. Pediatrics. 2016;138(1):e20161493. doi:10.1542/peds.2016-1493
  8. Ruckart PZ, Jones RL, Courtney JG, et al. Update of the blood lead reference value - United States, 2021. MMWR Morb Mortal Wkly Rep. 2021;70(43):1509-1512. doi:10.15585/mmwr.mm7043a4

  9. Centers for Disease Control and Prevention. Lead poisoning prevention. Web site. Updated November 4, 2021. Accessed December 20, 2021.

  10. U.S. Environmental Protection Agency. Learn about lead. Web site. Accessed December 21, 2021.

  11. Delgado CF, Ullery MA, Jordan M, Duclos C, Rajagopalan S, Scott K. Lead exposure and developmental disabilities in preschool-aged children. J Public Health Manag Pract. 2018;24(2):e10-e17. doi:10.1097/PHH.0000000000000556

  12. California Childcare Health Program. Indoor air quality. University of California San Francisco. California Childcare Health Program Web site. Revised June 2016. Accessed January 7, 2022.

  13. U.S. Environmental Protection Agency. Locate certified inspection, risk assessment, and abatement firms. Web site. Accessed January 7, 2022.

  14. U.S. Environmental Protection Agency. Steps to lead-safe repair, renovation, and painting. Web site. Updated March 2021. Accessed January 7, 2022.


Content in the STANDARD was modified on 05/17/2016 and 09/27/2022.