Mitigation Planning
Create A Plan
If lead is present at or above 2.01 parts per billion (ppb) in any samples, child care providers are required to develop and implement a mitigation plan. We strongly recommend that school leaders also develop and implement a mitigation plan to help safeguard children.
Getting Started
To help you create a mitigation plan, use the LeadCare Illinois mitigation plan template. A mitigation plan should include:
- A list of each drinking and cooking water source that tested at or above 2.01 ppb.
- Immediate actions taken to ensure children at your school or facility have a safe water supply until long-term strategies can be implemented.
- The planned long-term mitigation strategies you will implement at each water source where lead is present to reduce the levels below 2.01 ppb, as well as when these mitigation strategies will begin and end.
- Dates when you plan to retest your water to ensure the long-term mitigation strategies worked (i.e., did your chosen strategies reduce lead levels below 2.01 ppb). Child care providers are required to retest their water until two consecutive rounds of testing show lead levels below 2.01 ppb. While retesting is not required for school leaders, we recommend you do so to ensure reduced lead levels.
- You’ll also want to make your mitigation plan available to parents, caregivers, and staff so they can understand the actions you are taking to protect the children in your school or child care facility.
Immediate Strategies
Place a “Do Not Drink” or “Handwashing Only” sign at each water fixture where lead levels are at or above 2.01 ppb. This strategy is a low-cost way to take immediate action at problem fixtures. It will also allow you to continue to use the fixture for handwashing purposes.
The drawback of this approach is that it doesn’t remove the source of lead and relies on your staff and children to follow the “Do Not Drink” instructions. This strategy may not be appropriate at drinking water sources frequently used by children who are unable to read. Also, if you post “Do Not Drink” signage at one of your main drinking water sources, you will want to educate staff on why these signs are in place. If you post signage at a drinking water fountain, you may also need to find an alternative source of drinking water for your children such as bottled water or a drinking water station.
Temporarily shut off the water supply at problem fixtures. This can be done by closing the on/off valve of your water fixture. This action may be preferred if you have a particularly high lead result at a fixture. If you temporarily remove a fixture from service, you will need to designate a staff member to regularly flush the water at the outlet and maintain a flushing log. This log should include the date of flushing, name or initials of the person performing the flushing, and any observations or notes. You may also need to find an alternative drinking water source if the fixture is a main drinking water source for your children.
Install an NSF/ANSI 53 and 42 certified filter at problem fixtures. A filter with these certifications meets strict standards to reduce lead in drinking water (NSF 53) and to help with particulate lead reduction (NSF 42). The advantage of using filters at problem fixtures is that they ensure lead levels are low. You should always follow the manufacturer’s instructions when using filters, assign a staff person to conduct regular and timely filter replacements, and maintain a log.
Various types of NSF 53 and 42 filters include: faucet mount, fridge, under-sink, and countertop. You can also purchase water pitchers and water bottle filling stations with an NSF 53 and 42 filter. Please note that you will need to hire an Illinois licensed plumber if you choose to install a water bottle filling station, under-sink filter, or countertop filter.
If your test results showed that your 30 second flush sample is below 2.01 ppb, flushing, or running the water, at problem fixtures can help lower lead levels. Start each day with a flush at each problem fixture and flush each fixture for 30 seconds before each use. Flushing is only a temporary solution because you rely on staff to make a behavior change (running water before each use). To help remind staff of this behavior change, place instructions above each fixture where flushing is recommended.
In extenuating circumstances, your facility may consider using bottled water for cooking and drinking as a mitigation action, especially if many drinking water sources contain lead. Although bottled water is expensive and not ideal, it could help provide a safe drinking water source for your children if other mitigation options are unavailable. Note that child care providers must obtain DCFS approval to use bottled water. The US EPA also recommends you ask for a written statement from the bottled water provider, “guaranteeing that the bottled water meets FDA and state standards.” You should also check that the bottled water has been certified by an independent testing organization and ensure that the bottled water is sealed.
When using bottled water, it is important to routinely flush or run the water at drinking and cooking water sources that are not in use. Flushing your water will help prevent lead from building up in your pipes.
Long-Term Mitigation Strategies
Replacing faucets and fountains may be a good option if your first draw sample shows high lead levels. To replace your faucet or fountain, contact a registered plumbing contractor. Be sure to ask your plumber to use lead-free plumbing materials. To learn more about markings that indicate plumbing materials meet lead-free requirements, visit this US EPA resource. This certification means the faucet adheres to strict lead-free standards. After your faucet has been replaced by a plumber, we encourage you to flush your new faucet for several weeks – or to use an NSF 53 certified filter for a few weeks – since lead levels can temporarily increase post replacement.
In some situations, faucet replacement may not result in a reduction in lead levels. This could happen if an upstream fitting or valve is the source of lead. The US EPA recommends that if you are considering having multiple faucets replaced, try one faucet replacement first and see what the follow up tests reveal before moving forward with the other replacements.
If you decide to permanently remove a fixture from service that you use regularly, you could install a new drinking water fixture – such as a water bottle filling station with an NSF 53 and 42 filter, in a central location at your facility. You would need to use a registered plumbing contractor to remove the problem fixture and install a new fixture.
Automatic/mechanical flushing devices can be installed at the end of pipes or inside water fountains to automatically flush water at predetermined times to reduce lead levels. Speak with a professional with experience installing these devices for more details on the feasibility of this mitigation strategy for your facility.
Installing NSF 53 and 42 certified point-of-use filters at problem fixture/s can be a long-term strategy if you designate a staff person to regularly replace filters according to the manufacturer’s instructions and maintain a replacement log.
When present, a lead service line can be the largest contributor of lead in drinking water. Service lines deliver water to your home/facility from the water main in the street or source of water. These lines are more likely to be made of lead if your home or building was constructed before 1987; this is because the Safe Drinking Water Act banned the use of lead service lines in 1986. It is also important to remove and replace service lines made of galvanized steel since they can contain lead particles. To find out if a lead or galvanized service line exists at your child care facility, contact your facility’s water supplier or a licensed plumber. You can also investigate the material of your facility’s service line by using a visual inspection guide like the one developed by National Public Radio at npr.org/pipes.
If your facility is connected to a lead service line, work with a registered plumbing contractor and your local water utility to replace your entire lead pipe (from the building to the water main). While lead service line replacement can be expensive, you can contact your local water utility to see if any resources exist to assist with the cost of full lead service line replacement. If you are unable to replace your lead service line, install filters at drinking water faucets or use water pitchers with filters that are NSF 53 and 42 certified.
A registered plumbing contractor can help you determine if your internal plumbing contains lead and the cost of bypassing or replacing the leaded plumbing. Older plumbing is more likely to contain lead. If you decide to replace the internal plumbing, ensure your registered plumbing contractor uses lead-free plumbing materials.