Audit Objective
Did Poland Central School District (District) officials identify, report and implement needed remediation to reduce lead exposure in potable water outlets?
Audit Period
July 1, 2019 – September 30, 2024
Understanding the Program
Lead is a metal that was commonly used in plumbing and has since been identified as toxic to people, especially young children. Lead poisoning can cause neurological issues such as slowing children’s growth, causing learning and behavioral issues or causing hearing and speech problems which can lead to greater difficulty performing well in school and beyond.1 To aid in combating lead poisoning, New York State (NYS) requires all public school districts and Boards of Cooperative Educational Services (BOCES) to test potable (i.e., consumable) water for lead, report the results and implement necessary remediation. Testing and reporting for lead contamination began in 2016, and subsequent testing cycles have followed:
- Cycle One: September 6, 2016 to October 31, 2016.
- Cycle Two: January 1, 2020 to December 31, 2020 (extended to June 30, 2021 due to the COVID-19 pandemic).
- Cycle Three: January 1, 2023 to December 31, 2025.2
Audit Summary
District officials did not properly identify, report or implement needed remediation to reduce lead exposure in all potable water outlets as required by NYS Public Health Law and Department of Health (DOH) regulations.3District officials were unable to determine which of the 176 water outlets we identified at select areas, that students, staff and the public may have access to and could consume water from, were sampled for testing. Therefore, we determined 132 of the 176 (75 percent) water outlets we identified were not properly secured against use for Cycle Two.
Further, although 28 of the 129 water outlets that the District sampled and tested exceeded the lead action level, because District officials could not identify which water outlets exceeded the lead action level, and because there was no information on the lead levels of the 132 water outlets that we determined were not properly secured against use, we were unable to determine whether officials identified and remediated all water outlets that would have required it. This occurred because District officials did not have a sampling plan to identify all water outlets for sampling or exemption.
Although District officials learned on December 22, 2020 that 28 water outlets exceeded the lead action level, as of the conclusion of our fieldwork on March 21, 2025, officials had not performed any remedial action on the 28 water outlets that exceeded the lead action level. Although the former Director of Facilities (Director) had a remedial action plan that described what remedial actions were planned or enacted for water outlets that tested above the lead action level, we were unable to determine whether such actions were implemented, because current District officials could not identify the water outlets’ locations.
For Cycle Two, District officials did not report exceedances directly to the local health department and did not have any documentation to support that staff, parents and/or guardians were notified of the exceedances in writing. Additionally, District officials reported results through the DOH’s Health Electronic Response Data System (HERDS) 267 days after the required reporting deadline. Finally, while the results were posted on the District’s website, we were unable to determine whether the results were posted within the required time period.
For Cycle Three, District officials did not report exceedances to the local health department, and did not notify staff, parents and/or guardians in writing within the required time period. Additionally, District officials did not report the results through HERDS or post them on the District website.
This final report includes 10 recommendations to that effect. District officials generally agreed with our findings and their response is included in Appendix C.
The Board of Education (Board) has the responsibility to initiate corrective action. A written corrective action plan (CAP) that addresses the findings and recommendations in this report must be prepared and provided to our office within 90 days, pursuant to Section 35 of the New York State General Municipal Law, Section 2116-a (3)(c) of the New York State Education Law and Section 170.12 of the Regulations of the Commissioner of Education. To the extent practicable, implementation of the CAP must begin by the end of the next fiscal year. For more information on preparing and filing your CAP, please refer to our brochure, Responding to an OSC Audit Report, which you received with the draft audit report. The CAP should be posted on the District’s website for public review.
1 Lead Exposure Symptoms and Complications – https://www.cdc.gov/lead-prevention/symptoms-complications/index.html
2 As of December 22, 2022, schools are now required to test for lead in the water every three years beginning January 1, 2023 for Cycle Three.
3 Public Health Law section 1110; 10 NYCRR subpart 67-4 – Lead Testing in School Drinking Water