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Testing of drinking water at Colorado schools shows more work needs to be done to eliminate lead contamination.
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Former Public Health Advocate, CoPIRG Foundation
Executive Director, CoPIRG Foundation
Clean Air Advocate, CoPIRG Foundation
A 2022 Colorado law required most elementary schools and child care centers to test drinking water sources for lead, report results publicly by May 2023, and act to remediate any source that had levels of lead of 5 parts per billion (ppb) or more. Facility staff are required to shut off fixtures requiring corrective action until fixes are complete and a confirmation sample test shows the remediation has been successful.
According to a December 2023 Legislative Report by the Colorado Department of Public Health and Environment (CDPHE), the schools and child care centers covered under the law serve almost 600,000 children in Colorado.
Some school districts have also tested at schools serving kids beyond elementary school.
The testing found some fixtures had extremely high levels of lead. One fixture tested as high as 4500 ppb – 900 times the 5 ppb threshold set by the law (see Table 2 below).
Our analysis of the lead levels in drinking water reported by schools found there are lead contaminated fixtures in all of Colorado’s largest school districts, and much of the required remediation remains incomplete, some more than one year after testing.
Our report focuses on the state’s ten largest school districts, pulling data on May 1, 2024, to see how many fixtures that require remediation have been resolved.
The number of fixtures in the ten largest districts that returned results at or above 5 ppb varied across the state, ranging from 0 in one district to hundreds in others.
Table 1 shows the total number of fixtures requiring remediation for Colorado’s ten largest school districts alongside the number of fixtures where remediation is still underway.
Across the state’s 10 largest school districts, 2,201 drinking sources recorded excessive amounts of lead in their water samples, so far, based on the 5 ppb limit. Of those fixtures, progress for approximately 64% of them – 1,417 fixtures – was still listed as “underway” or “further fixes underway” on the state’s website as of May 1, 2024 despite many of the samples getting submitted over a year ago.
Source – number of schools enrolled in program, fixtures requiring remediation: Colorado Department of Public Health and Environment Test and Fix Water for Kids Lead Testing Results, data pulled 5/1/24. Source – number of students – Niche: https://www.niche.com/k12/search/largest-school-districts/s/colorado/. For details, see ‘Methodology’ below. NOTE – While most of the testing was done over the past year, some school districts participated in Colorado’s voluntary state lead testing program, which ran from 2017-2020. For some school districts, these older results are also included in the database.
Under Colorado’s 2022 legislation, public schools that serve preschoolers through fifth graders, early child care facilities and family child care homes are required to do lead testing on all water fixtures (such as drinking fountains and classroom faucets) and submit the results to the Colorado Department of Public Health and Environment (CDPHE) by May 31, 2023. Some school districts have begun testing schools that serve students beyond fifth grade.
The law requires all test results to be posted online and the state created the Test & Fix Water for Kids Lead Testing Results database. For samples that come back with lead at 5 parts per billion (ppb) or greater, the school must notify parents, guardians and employees, stop using the source and begin remediation. Colorado’s bill also provided some funding to school districts to support testing and lead remediation.
While testing and remediation can reduce exposure to lead in drinking water, for two reasons, the law fell short of fully protecting children from lead by only remediating taps where testing confirms lead concentrations at or above 5 ppb:
CoPIRG Foundation plans to do a second analysis of this data based on any traces of lead. We recommend any schools or daycare centers that have fixtures at 1 ppb or above take the same remediation steps as are required for 5 ppb.
However, because the current law sets the level that requires remediation at 5 ppb, this initial analysis focuses on how well school districts are remediating at that threshold.
Lead is a potent neurotoxin that affects how children learn, grow and behave. According to the American Academy of Pediatrics, there is no known safe level of lead for children.
The EPA describes the dangers of lead for children as such: “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.”
A 2021 study found that 72% of Colorado children under 6 who were tested had detectable levels of lead in their blood – well above the national rate of 51% (see Results, Figure 1 for details). While lead exposure can come from many sources, the water kids drink at school should not be adding to that health risk.
According to a Legislative Report issued by CDPHE in December 2023, nearly all of Colorado’s 178 school districts in Colorado had fully complied with the testing requirement of the law, meaning they tested all drinking water sources.
According to CDPHE’s Legislative Report, across all schools and child care centers statewide there were 3,700 fixtures that tested above 5 ppb and required remedial action. However, those fixtures only reflect values of lead that tested at 5 ppb or more, leaving a number of taps contaminated with lead levels between 1 ppb and 5 ppb. CoPIRG’s future report will look at the total number of fixtures that contained ANY trace of lead – since we know even very small amounts can be dangerous for children.
Of the 3,700 fixtures returning results at or above 5 ppb, 600 fixtures, or 16%, have fully completed the remediation process as of September 15, 2023. The other locations are listed as “working towards final corrective actions,” according to the CDPHE report.
When a water sample is returned with lead levels greater than or equal to 5 ppb, a follow-up flush test is required to determine if piping beyond the fixture is also contributing to elevated lead levels. Based on the results of the flush test, the law gives schools wide discretion in choosing remediation steps, which can range from a “not safe for drinking” sign, replacing a faucet or drinking water fountain, and replacing aerators to permanently removing fixtures.
In our view, schools should install point-of-use filters certified to remove lead on all taps that remain in service as drinking water sources. Replacing a fountain with a new water bottle station with such a filter not only eliminates a common source of lead (the fountain) but also captures lead coming from interior plumbing or pipes.
For fixtures that tested at the state limit of 5 ppb or higher, a follow up flush sampling kit was provided. This kit takes a second sample at the fixture with specific instructions around flushing the water out, that can help determine whether there is lead within the plumbing system at the facility beyond the immediate fixture. After each facility has collected flush samples and received results, the program coordinator for that facility must come up with a remediation plan for all fixtures. Remediation options vary depending on the type and location of the fixture. The chart below shows remediation options presented in the state’s legislative report.
Source: HB1358 Legislative Report, published December 1, 2023, page 13.
Facility staff are required to shut off fixtures requiring corrective action until fixes are complete and a confirmation sample test shows the remediation has been successful.
CoPIRG Foundation did a deeper dive for the state’s ten largest school districts, pulling data on May 1, 2024, to see how many fixtures that require remediation have been resolved, some one year after testing occurred.
The number of fixtures in the ten largest districts that returned results at or above 5 ppb varied across the state, ranging from 0 in one district to hundreds in others.
Table 1 shows the total number of fixtures requiring remediation for Colorado’s ten largest school districts alongside the number of fixtures where remediation is still underway.
Source – number of schools enrolled in program, fixtures requiring remediation: Colorado Department of Public Health and Environment Test and Fix Water for Kids Lead Testing Results, data pulled 5/1/24. Source – number of students – Niche: https://www.niche.com/k12/search/largest-school-districts/s/colorado/. For details, see ‘Methodology’ below. NOTE – While most of the testing was done over the past year, some school districts participated in Colorado’s voluntary state lead testing program, which ran from 2017-2020. For some school districts, these older results are also included in the database.
Across the state’s 10 largest school districts, 2,201 drinking sources recorded excessive amounts of lead in their water samples, so far, based on the 5 ppb limit. Of those fixtures, progress for approximately 64% of them – 1,417 fixtures – is still listed as “underway” or “further fixes underway” on the state’s website as of May 1, 2024 despite many of the samples getting submitted over a year ago.
Of the 10 largest school districts, the ones with the highest percent of fixtures with lead remediation work reported as still underway include Adams Arapahoe 28J, Denver Public Schools, Cherry Creek School District No. 5, and Jefferson County School District No. RE-1 – all of which have more than 70% of tainted fixtures left to complete remediation as of May 1, 2024.
Adams 12 Five Star Schools, Poudre School District R-1 and Boulder Valley School District have all successfully remediated more than half of the fixtures requiring remediation based on the 5 ppb limit.
St. Vrain Valley School District No. Re1J was the only district to have reported no fixtures test at or above 5 ppb, and therefore no remediation is required under the law.
Across the 10 largest districts, some of the highest amounts of lead have been found at a drinking water fountain at Eagleview Elementary School in Adams 12, with test results showing lead levels of 4500 ppb. Evergreen Middle School in Jefferson County had a fixture classified as “other” and described as a sink in a resource room that tested at 2080 ppb, and Holly Hills Elementary School in Cherry Creek showed lead results of 1100 ppb in a classroom faucet. Eagleview Elementary replaced the drinking water fountain in March of 2023, while remediation at Evergreen and Holly Hills remains “underway” (fixtures requiring corrective action must be shut off pending remediation and a confirmation test result showing lead levels under 5 ppb).
Source: Colorado Department of Public Health and Environment Test and Fix Water for Kids Lead Testing Results; data pulled 5/1/24. Source – number of students – Niche: https://www.niche.com/k12/search/largest-school-districts/s/colorado/.
While the 2022 law provided some funding for remediation, the law only requires addressing taps where testing confirms lead concentrations in drinking water at or above 5 parts per billion (ppb), allowing for significantly more lead in the water than the 1 ppb recommended for children by the American Academy of Pediatrics. Furthermore, lead concentrations in water can be highly variable, which means even proper sampling can mislead contamination or fail to capture its full extent.
Colorado school districts can and should take stronger action to ensure safe drinking water for kids. Given the widespread use of lead in fixtures and the unreliability of testing, school districts should be preventing contamination at every tap, not just fixing those where a single sample finds lead.
Our Get the Lead Out report strongly recommends replacing fountains with filtered water stations, which eliminates a common source of lead (like fountains) and also captures lead coming from plumbing or pipes.
Through the CDPHE report and in conversations with our staff, school districts reported a number of challenges including a shortage of plumbing contractors and lack of familiarity among school staff around testing protocols and performing fixes. Additionally, school districts noted that the additional operating costs associated with monitoring and replacing filters were not covered by available funding sources.
Local, state and federal policymakers should consider strategies that can help address these challenges including technical support and additional resources.
We’ve put together a report on getting the lead out of school drinking water. Our recommendations for schools include:
Parents in Colorado concerned about lead in schools water should work with school leadership and school boards to get the lead out. Here are three steps to take.
Step 1 – Get the facts. Check lead testing data for your school by using the state’s Test and Fix Water for Kids website. This will show you how many fixtures came back positive for lead, and what remediation actions your school has done so far.
Step 2 – Confirm remediation timeline. If your child’s school has fixtures that require remediation, but have not been remediated yet, ask your principal or other school leadership what the timeline is for completion and confirmation testing.
Step 3 – Request prevention at every tap. Regardless of the number of taps that exceed the state cut-off of 5 ppb, we recommend filtration at all fixtures. This can actually be a cost effective approach compared to continuous testing and remediation. Reach out to school leadership or school board members (sample message below) to request action above and beyond the current system of testing and replacing. At the very least, all fixtures testing above 1 ppb of lead should be remediated, which is the threshold recommended by the American Academy of Pediatrics.
SAMPLE EMAIL – FEEL FREE TO COPY THIS AND USE
Dear School Board Member / Principal,
As a parent concerned about the health of all the children in our school, I’d like to suggest that [school name] consider preventing lead in water at every tap by installing lead-removing filters on all drinking water sources. Because 5 ppb is significantly more lead in water than the 1 ppb recommended for children by the American Academy of Pediatrics, I am concerned about the lead that can remain in water even under the state’s current testing and remediation program. Additionally, because lead concentrations in water are highly variable, even proper sampling can miss lead contamination or fail to capture its full extent.
Providing filters at drinking water sources can be a cost effective way to ensure the water our kids drink at school is safe. I believe prevention at every tap by using certified lead-removing filters will provide the healthy, safe learning environment every child and staff person at our school deserve.
Thank you,
[Your name]
The data we used came from the state’s Test and Fix Water for Kids website, which is a database maintained by CDPHE that shows lead testing results for all elementary schools and child care centers across the state covered by the 2022 law. First, we exported the data from the dashboard by school district. Then we looked at how many fixtures required remediation by counting the number of unique fixtures that had an “action required – YES” designation. From that list, we counted the number of remediations that had been labeled as “successful.” We subtracted the number of successful remediations from the total number of remediations to determine the number of fixtures where remediation was still presumed underway.
Former Public Health Advocate, CoPIRG Foundation
Danny has been the director of CoPIRG for over a decade. Danny co-authored a groundbreaking report on the state’s transit, walking and biking needs and is a co-author of the annual “State of Recycling” report. He also helped write a 2016 Denver initiative to create a public matching campaign finance program and led the early effort to eliminate predatory payday loans in Colorado. Danny serves on the Colorado Department of Transportation's (CDOT) Efficiency and Accountability Committee, CDOT's Transit and Rail Advisory Committee, RTD's Reimagine Advisory Committee, the Denver Moves Everyone Think Tank, and the I-70 Collaborative Effort. Danny lobbies federal, state and local elected officials on transportation electrification, multimodal transportation, zero waste, consumer protection and public health issues. He appears frequently in local media outlets and is active in a number of coalitions. He resides in Denver with his family, where he enjoys biking and skiing, the neighborhood food scene and raising chickens.
Kirsten joined CoPIRG's staff in 2022 and is focused on fighting for clean air for Coloradans and transforming transportation systems. Previously, she oversaw The Public Interest Network's efforts to engage alumni/former employees and volunteers in the network's work, specializing in communications and organizing events in dozens of cities. Kirsten lives in the Denver area with her husband and two children, where she is an avid hiker, biker, church choir member and gardener.