Lead in School Drinking Water Program Checklist

This checklist is provided to public schools and BOCES to ensure compliance with the regulations outlined in Public Health Law 1110 and corresponding Subpart 67-4. This checklist outlines all the steps schools must take under the legislation. Schools should utilize this checklist and maintain proper documentation of actions regarding school lead in drinking water.

More detailed information about the steps below can be found in our guidance manual: Lead in School Drinking Guidance Document

Sampling

  • Review previous compliance period materials, including but not limited to: sampling plan, remediation, results, parent notification letters, etc.
  • Assign and update roles in the Health Commerce System (HCS) to include an active HCS Coordinator and active School Lead in Drinking Water Reporter: Template for Assigning Roles in Health Commerce System .
  • Identify/determine outlets requiring sampling (Applicable or Non-Applicable).
  • Place consumption prevention methods on all non-applicable outlets prior to sampling applicable outlets, including but not limited to: permanent removal, engineering controls, signage/supervision/education.
  • Develop a detailed sampling plan: Sampling Plan Template.
  • Conduct first-draw sampling of all applicable outlets using Sampling and Remedial Action Plan Template. If you are conducting your own sampling, follow the recommended sampling instructions here: Recommendations for Sampling Lead in NYS School Drinking Water.

Reporting

  • Within 1 business day: Report results of all outlets that exceed the action level to Local Health Department or Environmental Health Regional District Office, as applicable.
  • Within 10 business days: Report summary of results to the Department of Health using the Health Commerce System (HCS) under the HERDS (Health Electronic Record Data System) application.
  • Within 10 business days: Report exceedances, in writing, to staff/parents/guardians: Parent Letter Template. ‘In Writing’ means that schools may choose to mail physical letters with paid postage or send ‘backpack’ mail home with students. If choosing backpack mail, schools must notify staff/parents/guardians via social media, newsletter blurb, parent square, etc. that the letter is coming. Ensure you maintain documentation of when and how this notification was sent.
  • Within 6 weeks: Update school website to include: summary reports, numerical lab reports, and remedial action plan.
  • As needed: update HERDS and Remedial Action Plan as new/post-remediation sampling results come in. For samples that are identified as fully remediated, reporting for post-remediation sampling must follow the same timeline as initial sampling: 1 business day, 10 business days, and 6 weeks. If post-remediation samples indicate a continued exceedance, reporting Is not required until successful remediation is achieved. The outlet must remain out of service with appropriate controls in place to prevent consumption.
  • Retain copies of all documents, including reports, and remediation for a minimum of 10 years.

Remediation

  • Within 1 business day: Remove all outlets exceeding the action level from service, including posting clear “Do Not Consume” signage and educating students and staff. Education can include, but is not limited to, the following: paragraph in the Student Handbook, Science Lab rules contract signed by students, school morning/afternoon announcement, email to staff, blurb in a newsletter, etc. Any education must be documented.
  • Remediate any outlet exceeding the action level of 5 ppb to include: permanent removal, installation and maintenance of filters, installation/replacement of taps, installation/replacement of fountains, installation/replacement of plumbing and materials, installation of signage with continuing supervision and education, other engineering controls, and more.
  • Update remedial action plan on the school website, as needed.
  • Re-sample all remediated outlets and confirm they are below the action level before returning to service. If you remediate an outlet using only signage/supervision/education you do not need to re-sample, as the outlet will still test over the action level.

Reimbursement

Do not begin entering reimbursement information into HERDS unless remediation for the building is fully complete and you have all cost information, including but not limited to invoices and receipts, in front of you. The Department of Health may contact you to provide invoices/receipts of reported remediation costs. Do not estimate costs. Enter only actual costs. Round to the nearest dollar.

  • Ensure that all remediation for the building, including post remediation sampling, is fully complete. This means that all outlets have tested below the action level of 5 ppb or have adequate controls to prevent use for drinking and cooking.
  • Update remediation status for HERDS Question 13 to reflect “Complete”.
  • Enter the requested cost information, rounded to the nearest dollar, under each respective section: Permanent Removal, Signage, Filters, Taps, Fountains/Bubblers, Engineering Controls, Other (only enter information here if you remediated using methods OTHER than already described. This could be a specialized filtration system, mass plumbing replacement, etc.), Post-Remediation Sampling, Total Reimbursement Requested.
  • Review all inputted information to ensure accuracy. Ensure your reported costs add up to the total amount of reimbursement requested.
  • Submit