Environment Oregon State Director, Celeste Meiffren-Swango, submitted the following comments to the Early Learning Council, calling for strong action to protect Oregon's littlest kids from the threat of lead in drinking water at child care facilities across the state. The proposed rules are set to be voted on at a meeting on January 25, 2018:
January 9, 2018
Sue Miller, Chair
Early Learning Council
Oregon Department of Education
Re: Lead Testing in Licensed and Regulated Child Care Facilities
Chair Miller and Members of the Early Learning Council,
Environment Oregon urges you to take strong action to ensure that child care centers are providing Oregon’s children with lead-free drinking water. The rules that you have proposed are a step in the right direction, but more must be done to protect Oregon’s most vulnerable kids from the dangers of lead.
Lead is a potent neurotoxin and especially damaging to children – impairing how they learn, grow and behave. We have known for some time that high levels of lead can cause severe health impacts – including anemia, kidney disease, abnormal brain function and even death.
Yet the medical science now confirms that even low levels of lead can cause permanent damage to our children. According to EPA, “In children, low levels of [lead] exposure have been linked to damage to the central and peripheral nervous system, learning disabilities, shorter stature, impaired hearing, and impaired formation and function of blood cells.”
The science now makes clear that there is no safe level of lead exposure for our children.
We realize that the Council’s initial charge was framed around testing for lead. But lead testing, even when properly done, often fails to capture the lead contamination or its full extent. Moreover, testing simply confirms a serious health threat; only preventative action will protect Oregon’s children from that threat.
Accordingly, we urge the Council to require the following three measures to eliminate lead exposure via water at child care centers. First, because contamination is inherent wherever there is lead, the most health-protective policy is simply to “get the lead out” of water delivery systems at our child care centers. Most critically, we know that lead service lines are such a major source of lead contamination that they have been replaced throughout the entire city of Portland. Children in the rest of Oregon deserve no less protection. Moreover, lead-bearing faucets and fixtures also pose an inherent contamination risk and should be replaced as soon as possible.
Second, child care centers must begin protecting our children from lead immediately by installing filters that are certified to remove lead at taps used for drinking or cooking.
Installing filters is an effective, affordable step that child care providers can take immediately to begin reducing the threat of lead in drinking water. In 2016, the Environmental Protection Agency did a study documenting the efficacy of certified filters in removing lead. The Agency for Toxic Substances and Disease Registry (ATSDR), who analyzed the results, concluded that, “the Brita and Pur filters distributed in Flint are effective in consistently reducing the lead in tap water, in most cases to undetectable levels, and in all cases to levels that would not result in a significant increase in overall lead exposure… the ATSDR also reported that the filter test data supports the conclusion that the use of filtered water would protect all populations, including pregnant women and children, from exposure to lead-contaminated water.”
We urge you to consider requiring the installation of certified filters at all taps used for drinking or cooking at child care facilities in Oregon. According to the “Water Filter Buying Guide” from Environmental Working Group, these certified filters range from $20 - $500, depending on the brand and type.
Finally, given the science on the health impacts of lead exposure for children, the Early Learning Council should establish a one part per billion standard for lead in water at child care facilities. The American Academy of Pediatrics is urging adoption of this 1 ppb standard for elementary and secondary schools, and pre-school-aged children are even more vulnerable to damage by lead.
Furthermore, we recommend that child care centers should test their water annually, not once every six years, with sampling methods that are designed to capture the full extent of lead contamination, and provide parents with easy access to all testing data and the status of remediation plans, regardless of the test results.
We urge you to encourage preventative measures to limit lead exposure, require annual testing of water outlets used for drinking and cooking, and adopt a standard of one part per billion.
These important and protective steps will have an immediate positive impact on the health of our children and their development.
Thank you for your time and consideration.
State Director, Environment Oregon
 U.S. Environmental Protection Agency, “Basic Information about Lead in Drinking Water,” EPA.gov, updated December 2016, accessible at https://www.epa.gov/ground-water-and-drinking-water/basic-information-about-lead-drinking-water
 Agency for Toxic Substances and Disease Registry; https://www.epa.gov/sites/production/files/2016-06/documents/filter_challenge_assesment_field_report_-_epa_v5.pdf
 Environmental Working Group, Water Filter Buying Guide, July 2017, available at https://www.ewg.org/tapwater/water-filter-guide.php#.WlUglt-nHIU
 American Academy of Pediatrics, Prevention of Childhood Lead Toxicity, (policy statement), July 2016, page 11, available at http://pediatrics.aappublications.org/content/pediatrics/early/2016/06/16/peds.2016-1493.full.pdf