*>EPA

Voluntary School and Child Care Lead Testing and

Reduction Grant Program:

Best Management Practices for States

Introduction

EPA hosted a workshop on May 17th, 2022 to bring the oversight agencies participating in the
program together to share the programs' success stories, challenges, and Best Management Practices
(BMPs). BMPs provide effective and practicable means to implement the grant program and
ultimately reduce lead in drinking water at schools and child care facilities. BMPs are illustrated in the
state case studies across the country that are removing and minimizing sources of lead in drinking
water. This document summarizes the best management practices learned from collaboration of
states during that meeting.

Best Management Practices

Recipients of the Water Infrastructure Improvements for the Nation Act (WIIN) are required to use
3Ts guidance or an equivalent guidance that is equally as stringent. Before testing, schools and child
care facilities need a plan to train staff and to react to results appropriately The testing plan must
be tailored and specific to the school or child care facility. This next section includes BMPs from the
workshop survey workshop presentations, and others identified during the workshop. The BMPs are
organized by the 3Ts categories: communication, training, testing, and taking action.

Voluntary School arid Child Care Lead Testing and Reduction Grant Program:
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COMMUNICATION

An effective communication plan is necessary to prepare and coordinate delivery of information
swiftly, professionally, and consistently. BMPs listed here include those that engage school and
child care facility personnel, parents, stakeholders, and partners. See Module 1: Communicating
the 3Ts for communication resources included in the 3Ts Toolkit.

Maintaining a program-specific website will ensure that all the program's information is in one place.
This can include information about the process, enrollment links, results, and contact information for
the program administration.

Creating simple and easy communication for teachers and child care providers can help them
better understand the process. Programs should make sure all materials are directed towards the
general public and use plain language to explain each step of the process.

Providing a tool that clearly communicates all steps of the program will help to simplify and outline
the process, so that no steps are skipped. Possible tools include a checklist, tables, interactive
documents, and databases.

Programs should have a marketing and communication strategy and be consistent throughout the
entire process. This will keep communities up to date with new information and any new changes.

Consistent branding should be a part of the programs marketing strategy. Keep colors and graphics
the same across the marketing campaign for a more appealing and cohesive look. The marketing
campaign can include postcards, email campaigns, and social media.

Programs should have an easy-to-access online enrollment form that schools and child care
providers can access at their convenience. Complicating the enrollment process could be a barrier to
enrollment, and a simple process could increase enrollment and participation.

Engaging and including stakeholders and provider
networks in the development of program plans
is a good communication tactic. Stakeholders can
include district personnel, department of education,
health departments, parent teacher associations, and
environmental groups. Including stakeholders in the
process keeps all parties informed and involved.

P

LESSONS FROM ILLINOIS

linois had a marketing effort
to help them establish a
brand. This included postcards, email
campaigns, and social media. See
the Success Stories section for more
information.

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Providing information to schools and child care providers in multiple ways is an important
outreach tactic. Communicating information by mail, email, online, and at in-person or virtual
information sessions can improve understanding and reach the most people.

Providing informational materials in languages other than English will increase access and spread
awareness. This can include handouts in multiple languages, a translated website, and/or resources for
those who speak languages other than English to have materials translated for them. These materials
can be designed for the specific audience/community.

Creating a hotline with personnel speaking multiple languages provides a place for people to ask
questions about the process. This can be designed for the specific audience/community.

Creating a partnership with multi-sectoral leaders can result in greater community access and
ultimately a larger audience reached. This may lead to multiple sources of funding. Many stakeholders
can encourage state regulatory action.

Figure 1 provides data on selected communication BMPs currently used by states.
The information displayed comes from survey responses following the May 2022
workshop. There were additional communication BMPs discussed during the
workshop and included in this document, but they were not in the survey.

COMMUNICATION BMPs

Creating a partnership with multi-sectoral leaders

Providing informational materials in langauges
other than English

Providing information to schools and providers in
multiple ways

Providing a tool that clearly communicates all
steps of the program

Maintaining a program-specific website

Having a marketing and communication strategy

Engaging stakeholders and provider networks in
development of plans

Figure 7: Communication BMPs Currently Used by States,

Voluntary School arid Child Care Lead Testing and Reduction Grant Program:
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TRAINING

Programs should train staff and parents about the sources and health effects of lead in
drinking water and provide the tools they need to protect children. BMPs listed here include
those that deal with training program administration and testing personnel. See Module 1:
Communicating the 3Ts and Module 2: Learning About Lead in Drinking Water for training
resources included in the 3Ts Toolkit.

Having standardized training materials and templates is needed for effective training. This will
ensure all staff are trained consistently. In addition, it will make mistakes easier to catch during the
testing process.

Creating and posting instructional videos online can be beneficial. Instructional videos on how to
sample, how to turn in samples, and how to fill out the forms are some examples that can be useful.
This is another area to implement standardization across the training.

Providing onsite training and support is vital to ensure testing is successful. Trained staff should be
available to help with training and sampling. Having clear explanations of the rules may be beneficial,
as some programs have found that people are more cooperative if they realize why things are set up
the way they are. It is important that all members of the community have access to this training. This
would include making the materials and training more accessible by offering multManguage options,
depending on community needs.

Holding free virtual and/or in-person informational events, such as webinars and information
sessions, to explain the program and its importance in the community. Some programs have
implemented filter giveaways to promote their events. A possible training event is a pre-enrollment
webinarto review the program process. The pre-enrollment webinar could review the program
process, instructional videos, and weekly webinars. This live webinar could walk participants through
the entire process. Hosting ongoing webinars throughout the program could maintain retention rates.

Providing resources and distributing information to parents and guardians about the lead testing
program before testing begins is vital to limiting confusion about the program. Programs should
provide information on lead, its health effects on children, why testing is occurring, and where they can
access the results when they are available. Having materials available in multiple languages will help
community involvement.

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Utilizing pilot studies can ensure states
are completely prepared for rollout before
the program launches. Having a strong
base in training and communication is
vital for the program's launch. However,
programs should be ready for possible
changes and be ready to overcome any
issues that may arise. These issues can
be identified and corrected by utilizing
pilot studies. It is possible for programs to
improve after their first launch. Pilot studies
will help determine program effectiveness
before the full program launch.

LESSONS FROM NORTH
CAROLINA

O

When North Carolina first began
their statewide program in 2020,
they quickly realized they had to
adjust how they approached training with
the COVID-19 pandemic. They added a pre-
enrollment webinar with a virtual Q&A session
to minimize enrollment, sample collection, and
shipping issues. See the Success Stories section
for more information.

Figure 2 provides data on selected training BMPs currently used by states. The
information displayed comes from survey responses following the May 2022
workshop. There were additional training BMPs discussed during the workshop
and included in this document, but they were not in the survey.

TRAINING BMPs

Providing resources for parents

Providing onsite training and support

Holding free virtual and/or in-person
informational events

Having standardized training materials
and templates

Creating and posting instructional videos online

Figure 2: Training BMPs Currently Used by States.

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TESTING

It is important to test drinking water in child care facilities to identify potential lead sources
and to take action, if necessary. BMPs listed here include those used to make the collection and
testing of samples go smoothly. See Module 5: Planning Your 3Ts Program. Module 4: Developing
a Sampling Plan, and Module 5: Conducting Sampling and Interpreting Results for testing
resources included in the 3Ts Toolkit.

Providing user-friendly tools is crucial for testing. This could include schools building plumbing
profiles and drinking water management plan workbooks with automatic calculations that are specific
to each facility. Guidance documents related to sample types and how to sample each type of drinking
water fixture can also be helpful. As a starting place, check out the resources available as part of the
STs Toolkit. Guidance documents can be developed for every type of drinking water test. Guidance on
the severity of the results and advise for next steps would limit confusion on understanding the results.

Creating an easy to find database with a public facing portion is an option for publishing test results.
If the schools are collecting the data, once the data is submitted to the state program, the results
may be published on the public portion of the database. Having a standardized template for how the
results should be formatted would limit variability and confusion.

Maintaining accurate records is a vital component of testing. If there is a mistake, it will be easy
to determine if the mistake is in the reported data or the sample itself. Accurate records will make
mistakes easier to catch and determine whether retesting is necessary.

Creating and utilizing easy to read and accessible forms can improve the testing process. Testing
results delivered to schools and child care facilities as lab reports can be complicated to read and
interpret. Some programs have developed a "how to read a lab report" cheat sheet. This may include
information about how to interpret results, units of measure used, and instructions on what the facility
should do with each water tap. Presenting the information in an easy-to-read format will have the
important information stand out and will minimize errors in understanding the results.

Providing free test kits, shipping, sample analysis, and/or technical assistance may increase
participant enrollment and sample collection. Free testing materials may include those for initial and
follow up testing.

Providing on-site sample collection at the facility is an alternative to sending free kits. This "hands-
off" approach may increase participation and limit collection errors. For example, some facilities would
rather have a third party collect samples. This can provide additional reassurance to staff and parents
that testing was conducted correctly.

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Providing reimbursement for testing costs makes
testing accessible for many facilities. Testing costs
may include lab costs, shipping, mileage, and some
labor costs. To minimize reimbursement issues, the
lab may contract with the state directly.

P

LESSONS FROM OREGON

Oregon reimburses the costs
of testing (including shipping
and collection) as long as the
tester provides the state with a complete
reimbursement spreadsheet, invoices,
lab reports, and a summary of the testing
request. See the Success Stories section
for more information.

Consistent contracting for testing may streamline
the testing process. For some states, it might be
easier to use one contracted lab for testing. However,
that may not always be possible for all states. In order
to utilize multiple labs for testing, it is important
to simplify and set a standard process for all

participating labs to keep consistency. For example, one program may use six or seven labs, and they
provide a list of those labs to the facilities to choose from. The program works it out ahead of time with
the lab for procedures, and the labs follow set protocols. The lab contracts with the state directly to
minimize reimbursement issues. The state provides a chain of custody and an estimated delivery date
for the results to be published from the lab.

Spreading out testing to not overwhelm labs has been beneficial. Some states establish a set goal of
facilities to test in order to limit an already large undertaking and to prevent flooding the labs, which
could result in backups and delays.

Figure 3 provides data on selected testing BMPs currently used by states. The
information displayed comes from survey responses following the May 2022
workshop. There were additional testing BMPs discussed during the workshop and
included in this document, but they were not in the survey.

TESTING BMPs

Shipping free lead in water test kit

Providing user friendly online tools

Providing reimbursement for testing costs

Providing free testing and/or technical assistance

Providing free test kits and sample analysis

Figure 3: Testing BMPs Currently Used by States.

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TAKING ACTION

Programs should take action to reduce lead in drinking water, as well as communicate to parents,
staff, and the community about risks, testing results, and recommended actions. BMPs listed here
encompass all actions that could take place after receiving the lead test results. See Module 6t
Remediation and Establishing Routine Practices and Module 7: Recordkeeping for taking action
resources included in the 3Ts Toolkit.

Maintaining a system to track results and remediation actions at both the state and school/child
care facility level allows the state to track the data that is collected, for schools and child care facilities
to keep accurate records, and to see recorded remediation actions. For recordkeeping and reporting
purposes, EPA recommends using the 3Ts Sampling eTracker for Child Care Facilities and Small
Schools (PDF tillable form) or the 3Ts Sampling eTracker for Schools (Excel workbook). These tools track
testing results and any action taken following sample results. It is especially helpful for communicating
to staff, parents, school districts, or others that may request this information. In addition, this tool
contains the data elements needed for reporting to the state if the school or child care facility receives
funding from the state under the WIIN grant.

Providing user-friendly online tools can assist schools and child care facilities carry out and
document remediation activities after testing. These online tools should be easy to access, explained
in plain language, and easy to navigate. It is suggested that links to these tools are available on the
program webpage and included on any print materials.

Making lead testing results easy to access and understand by providing various avenues for schools
and child care providers to access their results (e.g., mail, webpage) is a useful BMP. They should also
describe what the results mean in relation to the action level, health outcomes, and follow up actions.

Connecting providers to funding for remediation is crucial for taking action. When lead levels are
found to be above the action level, provide the information for potential funding resources such as
grants or organizations that can help provide replacement and remediation funding. EPA's document

"Potential Funding Sources for Reducing Lead in Drinking Water in Schools and Child Care Facilities"
summarizes potential funding sources to remediate lead and water quality related projects for schools
and child care facilities.

States should provide clear instructions on actions schools or child care facilities should take
based on their testing results. When lead is above the program remediation trigger (which is set by
the state), states should provide step-by-step instructions in plain language explaining what a school
or child care facility should do and how to do it. These instructions should include options for what
actions should be taken based on the lead level.

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Consider low and no cost recommendations
where appropriate for taking action. When
providing options for remediation, ensure that
there are cost-effective ways for a school or
child care facility to reduce lead levels in their
water. Some examples include designating
taps for drinking and cooking with proper
signage and using only cold water for
drinking or cooking.

P LESSONS FROM NORTH
CAROLINA

North Carolina provides information
and flyers about low and no cost
efforts for reducing lead based
on the amount of lead found at each tap.
Practicing no cost clean water habits (e.g.,
only using cold water for eating or cooking)
and low-cost mitigation options are discussed
(e.g., lead-certified filter flyer). See the Success
Stories section for more information.

Creating regulatory changes at the state or
local level requiring lead testing in schools
and child care facilities helps increase

program involvement and can stimulate funding for schools and child care facilities testing and
remediation efforts.

Figure 4 provides data on selected testing BMPs currently used by states. The
information displayed comes from survey responses following the May 2022
workshop. There were additional testing BMPs discussed during the workshop and
included in this document, but they were not in the survey.

TAKING ACTION BMPs

Making lead testing results easy to access
and understand

Maintaining a system to track results and
remediation actions

Connecting providers to funding
for remediation

Figure 4: Taking Action BMPs Currently Used by States.

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Success Stories

State success stories implementing WIIN Grant funding and establishing lead testing
programs for schools and child care facilities are discussed below. Different elements of
these state programs comprise the BMPs mentioned above. Stories show struggles that
states had to overcome and showcase planning and preparation that states took. These
success stories can be used to inform decision making and serve as guidance for states
experiencing similar issues.

North Carolina

Photo Credit RTI International

North Carolina:

Understanding how the program will operate first is a key
element in launching a successful program. North Carolina
had problems when they first began the program in 2020
and quickly realized they had to adjust how they approached
training. Their pilot study results showed that there were
ways to optimize training to minimize testing mistakes,
which would limit the need for retesting. With extra time due
to shutdowns from the COVID-19 pandemic, the program
was able to identify specific roles and responsibilities before
initiating a program re-launch. This gave the program and its
members accountability and assigned responsibility to key
individuals to ensure that testing and follow-up actions were
completed.

States with successful remediation strategies are clear
in their directives to schools and child care facilities and
detailed in the actions that must be taken after lead
is identified in a drinking fountain, water tap, or other
drinking water fixture. North Carolina has a robust and clear
remediation strategy, which involves swiftly and effectively
responding to lead in drinking water in schools and child
care facilities. This plan includes posting "do not drink" signs
at the affected taps, identifying alternative water sources that
can be used, providing continued support to identify how to
remove the lead, and confirmation testing after remediation.
State and local health department staff visit taps with
elevated lead levels to resample. Recommendations provided
to schools and child care facilities include information on no
cost clean water habits (e.g., designate taps for cooking and
drinking or only use cold water for eating or cooking) and
improved habits that can minimize the amount of filters the
facility needs. It also recommends low-cost mitigation efforts
(e.g., fix clog, flushing water, filters).

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&

LeadCare
Illinois

Illinois:

Providing user-friendly tools is a BMP that allows school and child
care facility staff to log testing results, interpret the results, and
receive information on action items in a clear manner. Illinois has
user-friendly tools, including a unique test results webpage for
program participants that can be viewed on computers and on
mobile devices. These results are not only displayed in a clear,
understandable way, but they are more accessible because of
the different types of devices they can be viewed from. The tool
also outlines next steps to reduce lead in drinking water and
links to communication templates to help child care providers
communicate their results with parents and staff. To encourage
child care providers to participate in testing efforts, Illinois
established a brand for the testing program called LeadCare
Illinois. The program also conducts ongoing marketing efforts
with trusted partners which includes postcards, direct mailers,
email campaigns, and social media.

Illinois

Photo credit to LeadCare Illinois



"fPENNVEST

PENNSYLVANIA INFRASTRUCTURE INVESTMENT AUTHORITY

Pennsylvania:

Since Pennsylvania's testing program is 100% voluntary, it
presented some challenges getting participation for the
program. One BMP was connecting schools to remediation
funding. When schools know there is funding to remediate if
lead is found, they are more likely to test for it. Pennsylvania
stressed the benefits of partnerships with many different
organizations to increase funding. They had funding coming in
from multiple sources, including a nonprofit and a university.
Pennsylvania is looking for additional ways to increase
program participation including outreach efforts and pending
state legislation that would require lead testing in schools
every three years.

Pennsylvania

Photo credit to Pennsylvania
Infrastructure Investment Authority

Voluntary School and Child Care Lead Testing and Reduction Grant Program:
Best Management Practices for States

Montana:

Montana has a regulation requiring schools to test for lead
in their drinking water. Their first recommendation was to
have as much ready as possible before program rollout. Their
program had procedures, various forms of guidance, forms,
and templates finalized and on the program webpage ready to
go before rollout. Montana's program had schools submit the
initial setup information and collect their own samples. This was
made possible by the simple guidance documents, forms, and
templates provided to the schools to aid with sample collection.
For data collection and tracking, Montana uses an application
and accepts data via email for inventories and school information.
The program recommends having different ways of accepting
data to make data submission accessible for all schools and child
care facilities. For example, the different submission types may
include handwritten inventories, online via website, through an
application, electronic via email, or paper submission.


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Assistance Program for Lead in Schools and Childcare Facilities Drinking Water

Free Lead Testing for Schools and
Childcare Facilities

Massachusetts

Photo credit to MassDep (Mass. Dept
of Environmental Protection)

Massachusetts:

In Massachusetts, one main goal of the program is to make
testing straightforward for the facilities, including easy to read
forms that are available on the program website. On the website,
participants can also find data reporting tools that record and
track sampling procedures, locations, and results. Additionally,
Massachusetts utilized partnerships for program promotion.
The program has many partners, including the University of
Massachusetts at Amherst. These partnerships help to reach a
greater audience and can act as other sources of information
regarding testing and results. Massachusetts provides free
technical assistance that aids with sampling and interpreting
and responding to results. Program representatives can assist
participants in completing the plumbing profile, conducting
sampling, or taking follow-up action.

5S8! '.w s	jg

Michigan

Photo credit to Michigan Department
of Environment, Great Lakes, and
Energy (EGLE)

OREGON

DEPARTMENT OF

EDUCATION

Oregon

Photo credit to Oregon Department
of Education

Michigan:

Michigan attributed their program's success to three main
factors: program administration, partnerships, and consistency.
Their program administration was successful because they
had no application and no upfront costs for testing. Program
partnerships were essential for operations and keeping
consistency. Michigan had one contractor who completed
all of their lead testing, which helped streamline the testing
process. Michigan also developed a user-friendly tool, which
included school building plumbing profiles and drinking water
management plan workbooks with automatic calculations that
are specific to each facility. In addition, guidance documents
for each type of drinking water testing were created. Michigan
also emphasized outreach and training where they had
implemented webinars, conferences, and online tools for both
schools and their partners.

Oregon:

A BMP for improving program effectiveness is to create
regulatory changes. While some states only have voluntary
testing, states such as Oregon require lead testing in schools
and child care facilities. In 2017, Oregon passed a law requiring
mandatory testing. This testing consists of the state's "Healthy
and Safe Schools Plan" to ensure public transparency and
reimbursement for testing costs. This reimbursement
includes reimbursement for the testing and shipping costs
and additional reimbursement for collection costs. Oregon
reimburses the costs of testing as long as the tester provides
the state with a complete reimbursement spreadsheet, invoices,
lab reports, and a summary of the testing request. Additionally,
Oregon has online training modules that are available to the
public and offer training on lead testing and interpreting
lead results.

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Participation was a common issue across all states. Potential participants may be deterred by an overly
complicated process and/or the amount of work involved. One program indicated their overall process is too
complicated. This is discouraging facilities from participating. The program is looking into streamlining the
enrollment process and involving third parties for the sample collection process to minimize the burden on
participants.

The lack of a legal requirement is a common issue. The WIIN grants are voluntary and many states do not
have regulations requiring lead testing in drinking water at schools and child care facilities. This means some
states may not prioritize testing since it is not a regulatory program. Encouraging stakeholders and community
members to push for state regulatory changes to require testing may increase participation.

Another common issue is the low rates of return on sampling kits. There may be a large interest in receiving the
sample kits, but few facilities will return the samples for testing once they are collected. One possible solution is
to implement a return stipulation as an enrollment requirement. This could include requesting that the samples
be sent back within a certain number of days once sampling kits are received. Follow-up communication, in the
form of phone calls or emails, would serve as a reminder as well.

One common issue states faced was limited overall engagement. A lack of promotion of the program resulted
in a lack of program awareness. Promoting the program can take a great deal of time, but states have found that
word of mouth can be a useful tool. When there is success at one school district, they tell others and get them on
board. One program shared their biggest breakthrough was from reaching out to human service organizations
that operate several child care facilities across the state. Getting them on board and having their directors agree
to test all their facilities has been groundbreaking and helped build momentum.

As the grant program continues, new issues will arise. EPA plans to continue this dialogue with states to ensure
that lessons learned and BMPs are shared. This will assist states in improving program implementation and
effectiveness toward the main goal of reducing lead levels in drinking water at schools and child care facilities.

Related Resources

WIIN 2107 BMPs Workshop Recording and Presentation Materials: https://www.epa.gov/dwcapacity/wiin-grant-
volunta ry-school-and-child-care-lead-testinq-and-reduction-qrant-proqram#traininq

Voluntary School and Child Care Lead Testing and Reduction State Grant Program Contacts: https://

www.epa.qov/dwcapacitv/voluntarv-school-and-child-care-lead-testinq-and-reduction-state-qrant-proqram-

contacts

Lead Testing Program Results: https://www.epa.gov/qround-water-and-drinkinq-water/school-and-chiid-
care-lead-testinq-and-reduction-q rant-prog ram

Voluntary School and Child Care Lead Testing and Reduction Grant Program Website: https://www.epa.gov/
dwcapacity/wiin-grant-voluntary-school-and-child-care-lead-testing-and-reduction-g rant-prog ram

3Tsfor Reducing Lead in Drinking Water Website: https://www.epa.g0v/ground-water-and-drinking-water/3ts-
reducing-lead-drin king-water

Office of Water (4606M)	EPA 815-F-220-07	December 2022	13


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