of Health and Human Services
Administration for Children and Families
To: All Head Start and Early Head Start Grant Recipients
Subject: The Role of Head Start Programs in Addressing Lead in Water
Lead is a toxic metal and there is no safe blood lead level for children.[i] Because their bodies are still developing, children under the age of 6 are at greatest risk for significant and potentially lifelong health problems as a result of exposure. They are more likely to come into contact with lead through paint or dust since young children often put their hands or objects in their mouths. However, lead in drinking water can also be a significant contributor to overall exposure to lead. This is particularly true for infants whose diet consists of food and liquids made with water, such as baby food or formula. The adverse health effects of lead exposure can be both physical and behavioral. Even low levels of lead in children can lead to anemia, behavior and learning problems, and other concerns.
Head Start programs have a critical role to play in preventing lead poisoning in children. Programs are required to maintain a facility that is free from pollutants, hazards, and toxins that are accessible to children and could endanger their safety — and that includes lead in water and paint. As part of Head Start monitoring, programs can expect to be asked about their processes to identify lead hazards and mitigate them. This Information Memorandum highlights available resources for programs to address lead in water specifically.
Testing for and Addressing Lead in Water
The U.S. Environmental Protection Agency (EPA) has developed a number of resources to guide programs to test and remediate for lead in water.
There are no specific funds designated for the purpose of lead assessments in Head Start programs. However, grant recipients may budget program funds to address lead in water, including necessary minor renovations to facilities. Allowable uses of program funds may include:
- Testing for lead in water
- Remediation actions such as purchasing, installing, and maintaining point-of-use devices for lead removal, such as water filters
- Replacing water fixtures and plumbing, including lead service lines[ii]
As programs consider their needs related to addressing lead in water in Head Start facilities, the Administration for Children and Families encourages grant recipients to submit one-time funding applications for facility needs not supported by operations funding. Note these one-time requests are addressed by priority and subject to availability of funds.
Other Federal Funding Sources
Head Start programs may be able to leverage EPA funding to eliminate lead in their facilities. The Bipartisan Infrastructure Law, 2022, authorized increased funding of $700 million over 5-years across two grant programs:
- Voluntary School and Child Care Lead Testing and Reduction Grant Program
- Reducing Lead in Drinking Water Grant Program
These programs aim to address lead in water through testing, remediation, and infrastructure improvements, including in child care and school settings. Grant recipients should reach out to their respective state agency to learn more about the EPA programs and other available resources.
Partnering with Families to Promote Children's Healthy Development
Head Start programs are already working closely with families and health care providers to make sure children are screened for lead poisoning (45 CFR §1302.46). These screenings align with the Centers for Medicare and Medicaid Services' (CMS) universal blood lead screening requirement for all Medicaid-eligible children, under their states' Early and Periodic Screening, Diagnostic and Testing schedule.[iii] The Office of Head Start (OHS) applauds programs' ongoing efforts to partner with parents and caregivers to make sure all enrolled children receive required blood screening.
OHS continues to encourage programs to leverage available resources in discussing with families how to prevent and address lead exposure in the home, such as through:
- Testing for lead in paint hazards and in water
- Minimizing children and pregnant persons' exposure to paint hazards, especially in homes built before 1978
- Creating barriers between living or play areas and possible lead hazards
- Cleaning and hygiene practices, such as regularly mopping and washing hands and toys
To learn more about the role Head Start programs play in keeping children safe and supporting families to prevent lead poisoning, visit the Early Childhood Learning and Knowledge Center and Office of Early Childhood Development websites.
Thank you for the work you do on behalf of children and families.
/ Khari M. Garvin /
Khari M. Garvin
Office of Head Start
i The Centers for Disease Control and Prevention has established a blood lead "reference value" that serves as a screening tool to identify children with higher levels of lead in their blood compared with most children. However, no safe blood lead level in children has been identified: https://www.cdc.gov/nceh/features/leadpoisoning/index.html
ii As long as total costs for any proposed plumbing improvements, such as replacing water fixtures and lead service lines, are less than $250,000, they would be considered minor renovations and allowable expenditures with program funds. If costs are anticipated to exceed $250,000, programs should contact their regional office to determine appropriate next steps.
iii Arizona is currently the only state approved by CMS to implement a targeted lead screening program.