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
188.8.131.52: Testing for and Remediating Lead Hazards
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 (http://www.cpsc.gov) 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:
● 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 Action, Remediation 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.gov, or 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.
TYPE OF FACILITYCenter, Early Head Start, Head Start, Large Family Child Care Home, Small Family Child Care Home
RELATED STANDARDS184.108.40.206 Testing for Lead and Copper Levels in Drinking Water
220.127.116.11 Construction and Remodeling
18.104.22.168 Product Recall Monitoring
Centers for Disease Control and Prevention. Lead in Paint. Reviewed November 24, 2020. Accessed March 9, 2021. https://www.cdc.gov/nceh/lead/prevention/sources/paint.htm
National Center for Healthy Housing. Lead-Safe Toolkit for Home-Based Child Care: General Resources. Accessed March 9, 2021. https://nchh.org/tools-and-data/technical-assistance/protecting-children-from-lead-exposures-in-child-care/toolkit/general/
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. http://www.cdc.gov/nceh/lead/acclpp/final_document_030712.pdf
Centers for Disease Control and Prevention. Blood Lead Levels in Children. Reviewed May 28, 2020. Accessed March 9, 2021. https://www.cdc.gov/nceh/lead/prevention/blood-lead-levels.htm
Centers for Disease Control and Prevention. Lead Poisoning Prevention. Reviewed May 30, 2019. Accessed March 9, 2021. https://www.cdc.gov/nceh/lead/prevention/default.htm
U.S. Environmental Protection Agency. Lead Abatement Versus Lead RRP. Accessed March 9, 2021. https://www.epa.gov/lead/lead-abatement-vs-lead-rrp
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. https://www.hud.gov/program_offices/healthy_homes/lbp/hudguidelines
Content in the standard was modified on 08/15/2014 and 04/27/2021.