California Code § 101700.3(b)(1): Lead Action Level

📋Type A Violation🏢Affects: Child Care Centers
ℹ️ Educational reference based on public CCLD inspection records. Not legal or compliance advice. Verify requirements with official sources. Full disclaimer →

What Is California Code § 101700.3(b)(1): Lead Action Level?

California Code § 101700.3(b)(1)

A result with values of 5.5 ppb or greater shall be deemed an Action Level Exceedance.

💬What Providers Tell Us

Based on community experience — not official guidance

Inspectors don't just check whether you tested your water. They check whether you tested every fixture children can access, including that hallway fountain nobody thinks about. The biggest trip-up I see is providers who test kitchen sinks but skip classroom sinks or outdoor spigots. If your results come back at 5.5 ppb or above, you need to shut off that fixture immediately and post signage. Don't wait for the official letter. Inspectors also verify you kept chain-of-custody documentation for your samples, so use a certified lab and keep every receipt.

8
facilities cited (last 90 days)
That's 1 in 5000 facilities
3
counties affected
35
most common citation
📉
Decreasing
Last 90 days vs. previous 90 days
8 facilities (was 11)3 facilities

Source: California CCLD inspection records | Data as of Apr 6, 2026. Last updated April 6, 2026.

8 facilities were cited for this in the last 90 days.

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What Other Providers Do for Lead Action Level

Common practices shared by providers. Confirm requirements with your licensing analyst.

✓ Common Practices

❌ Common Mistakes

  • Confusing California's 5.5 ppb action level with the federal EPA standard of 15 ppb. Providers assume they're safe at 10 ppb because it's below the federal threshold, but California's childcare standard is nearly three times stricter.
  • Testing only the main kitchen faucet and missing classroom sinks, bathroom taps, or outdoor drinking fountains. Inspectors verify that every water source accessible to children was included in the testing report.
  • Failing to immediately shut off a fixture that exceeds 5.5 ppb. Some providers wait for remediation scheduling while children continue using the tap, which inspectors document as a separate violation.
  • Not retesting after remediation. Replacing a fixture or installing a filter doesn't close the citation until follow-up lab results confirm levels dropped below 5.5 ppb.
  • Losing chain-of-custody paperwork for water samples. If you can't prove a certified lab handled the testing, inspectors treat the results as invalid.

What's Being Cited in Each Region Over the Past 90 Days

Based on facility inspection reports filed with California's Community Care Licensing Division, here's how this citation appears across different regions in the past 90 days.

Data updated weekly from CCLD public records. Last update: 4/6/2026

A single Type A citation can cost $150-$500+ in civil penalties, not counting the follow-up inspection it triggers.

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Frequently Asked Questions

Answers based on public CCLD data and regulation text. May not reflect recent changes.

What is Lead Action Level?
California Code 101700.3(b)(1) sets the lead action level for child care centers at 5.5 parts per billion (ppb). Any water test result at or above this threshold constitutes an Action Level Exceedance, triggering mandatory remediation steps. This standard is nearly three times stricter than the federal EPA threshold of 15 ppb, which means your facility can fail California's test while technically passing federal guidelines.
How common is this citation?
According to California CCLD inspection records as of February 08, 2026, 11 facilities have been cited for this violation in the past 90 days across 5 California counties. That's roughly 1 in 3,636 inspected facilities. Los Angeles County leads with 4 citations, followed by Sacramento with 3 and San Diego with 2. Older buildings with original plumbing are disproportionately affected, especially in areas with aging water infrastructure.
What triggers this citation during an inspection?
Inspectors verify that every water source accessible to children was tested, not just the kitchen faucet. Based on CCLD inspection patterns, common gaps include classroom sinks, bathroom taps, and outdoor drinking fountains that weren't included in the testing report. They also check whether fixtures that exceeded 5.5 ppb were immediately shut off and posted with signage. If a fixture tested above the limit and children are still using it, that's documented as a separate violation. Inspectors also verify chain-of-custody paperwork proving a certified lab handled the samples.
How can I prevent this citation?
Test every water source children can access, including hallway fountains, classroom sinks, bathroom taps, and outdoor spigots. Use a certified lab and keep all chain-of-custody documentation and receipts. If any fixture comes back at or above 5.5 ppb, shut it off the same day and post signage. Don't wait for an official letter. Schedule retesting after any remediation to confirm levels dropped below the threshold before putting the fixture back in service.
What should I do if I receive this citation?
Shut off the affected fixture immediately and post clear signage that it's not for use. Provide alternative water access for children while the fixture is out of service. Arrange remediation, which may involve replacing pipes, fixtures, or installing certified lead-removal filters. After remediation, schedule follow-up testing with a certified lab. The citation stays open until you submit lab results showing levels below 5.5 ppb. For complex situations, consider consulting a licensed childcare compliance specialist.

This information is educational and does not constitute legal advice. Consult a licensed childcare compliance consultant for guidance specific to your facility. Citation data is sourced from California Community Care Licensing Division public records and is refreshed regularly.