Transcript The New Low Lead Regulations

The New Low Lead Regulations
2014 AWWA Meeting
February 26, 2014
LAURA A. TAYLOR
(334) 271-7820
[email protected]
Overview
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Sources of Lead in Drinking Water
Health Affects of Lead in Drinking Water
Current Safe Drinking Water Act Requirements
NSF/ANSI 61
Safe Drinking Water Act Revisions
Issues with the Revisions
Certification Labeling Examples
Questions
Sources of Lead in Drinking Water
• Sources of lead
– Natural deposits
– Household plumbing materials
– Water service lines
– Homes built before 1986
• Most common problem – brass or chrome-plated
brass faucets and fixtures
• Lead is rarely found in source water
Health Affects of Lead in Drinking Water
• Affect on adults
– Increase blood pressure
– Kidney problems
• Affect on children
– Delays in physical and mental development
– Slight deficits in attention span
– Learning disabilities
Current SDWA Requirements
• SDWA 1417(a)(1)(A)
– No person may use any pipe, plumbing fixture, solder,
or flux that is not lead free, after June 19, 1986 for
installation or repair of:
• any public water system
• any plumbing in a facility providing water for human
consumption
Current SDWA Requirements
• SDWA 1417(b) State Enforcement
– States shall enforce the lead free requirements
through State or local plumbing codes, or other such
means of enforcement as the State may determine to
be appropriate.
• SDWA 1417(c) Penalties
– EPA may withhold up to 5% of Federal funds available
to the State under 1443(a) if the State does not
enforce the lead free requirements.
Current SDWA Requirements
• 1417(d) Definition of lead free
– Solders and flux cannot contain more than 0.2% lead
– Pipe and fittings cannot contain more than 8.0% lead
• The standard for lead free plumbing fittings and
fixtures is established in Section 9 of NSF/ANSI
Standard 61
NSF/ANSI Standard 61- Scope
• Pipes and Related Products (pipe , hose, fittings)
• Protective and Barrier Materials (cements/coatings)
• Joining and Sealing Materials (gaskets, adhesives,
lubricants, solvent cements)
• Process Media (activated carbon, filter media)
• Mechanical Devices (water meters, valves, filters)
• Mechanical Plumbing Devices (faucets, drinking
fountains, and components)
NSF/ANSI 61 lead content restrictions
• There should be no lead added as an intentional
ingredient in any product, component, or
material submitted for evaluation to this
standard, with the following exceptions:
– Brass or bronze meeting the definition of “lead free”
– Materials of components with a diluted surface area
less than or equal to 0.0001 in2/L
NSF Standards Development Process
Certification Marks
Safe Drinking Water Act Revisions
Overview
• Amends SDWA Section 1417
– Creates exemptions
– Changes the definition of lead free
• Reduces lead content from 8.0% to a weighted average
of 0.25% in the wetted surface material (primarily
affects brass/bronze).
– Eliminates provision that certain products comply
with voluntary standards for lead leaching.
– Establishes statutory requirement for calculating
lead content
– Effective date January 4, 2014
Safe Drinking Water Act Revision
Exemptions
• 1417(a)(4)(A)
– pipes, pipe fittings, plumbing fittings, or fixtures,
including backflow preventers, that are used
exclusively for non-potable services such as
manufacturing, industrial processing, irrigation,
outdoor watering.
– or any other uses where the water is not anticipated
to be used for human consumption
Safe Drinking Water Act Revision
Exemptions
• 1417(a)(4)(B)
– toilets, bidets, urinals, fill valves, flushometer valves,
tub fillers, shower valves,
– service saddles, or water distribution main gate
valves that are 2 inches in diameter or larger.
Note: Any item covered by either exemption can
have any amount of lead. Also, meters have not
been exempted.
Safe Drinking Water Act Revision
Exemptions
Fire Hydrants
• Fire Hydrants has been exempted.
– Became Public Law on 12/20/2013
– Community Fire Safety Act of 2013
– H.R. 3588
Safe Drinking Water Act Revisions
Definitions
• 1417(d) Definition of lead free
– Revises lead content from 8% to not more than a
weighted average of 0.25% with respect to the
wetted surfaces of pipes, fittings, and fixtures.
– Provides calculation procedure for determining the
weighted average lead concentration of a product
from the components that make up the product.
– Eliminates requirement that certain products comply
with standards for lead leaching (NSF/ANSI Standard
61 Section 9)
NSF Evaluations
Safe Drinking Water Act Revision
Lead Content Calculation
• Core requirement:
Weighted average lead content < 0.25%
• Formula:
Sample Faucet
Example weighted average lead
content calculation
Safe Drinking Water Act Revisions
Effective Date
• Effective Date January 4, 2014
– A product introduced into commerce legally on
January 3, 2014 can’t be used on January 4, 2014
– The effective date will affect plumbers, plumbing
product retailers, developers, schools and water
systems
– Any inventory that does not meet 0.25% lead free
calculation cannot be installed after January 3, 2014,
unless it is exempt from the prohibitions.
Issues With the Revisions
Overview
• Demonstrating that products are lead free
• Scope of the exemptions
• Identifying non-potable products if dual product
lines are allowed
• Identifying lead free products
• Calculating lead content
• Repairing and returning products to service
Demonstrating Products are Lead Free
• Should manufacturers be required to
demonstrate that a product is lead free and if so
how?
• Potential approaches
– Require manufacturers to have products certified by
a qualified independent third party (e.g., NSF/ANSI
Standard 372 certification)
Scope of the Exemptions
• To qualify for the “used exclusively for nonpotable services,” must the product be physically
incapable of use in potable services or could it be
physically capable of use in potable services?
• Potential approaches
– Allow interchangeable dual product lines labeling the
non-potable version as “not for potable use.”
– All interchangeable products must meet the new lead
free content limit.
Identifying Non-Potable Products
if Dual Products Lines are Allowed
• If dual product lines are allowed, what kind of
label should be used?
• Potential approaches
– Require labeling of package
– Require labeling of product
– Require labeling of package and product
Identifying Lead Free Products
• How can consumers know if a product meets the
revised lead free definition?
• Potential approaches
– Require independent third-party certification
including certifier’s mark
– Require manufacturers to label products if
certification is not done via a third-party certification
– Do not require labeling of lead content
• Just label as non-potable
Calculation of Lead Content
• What constitutes the lead content of the
material used to produce wetted components?
• Potential approaches
– Lead content at the surface of the product is used
– Lead content of the alloy used to produce the wetted
component is used and not just the lead at the
surface layer
• Acid washing issue
• Coating erosion issue
• This approach is consistent with NSF/ANSI Standard 372
Repairing and Returning
Products to Service
• Can a product in the system be repaired using
lead free component parts and returned to
service even if other component parts were not
repaired and are not lead free?
• Potential approaches
– Entire unit would need to meet lead free requirement
– Only components replaced would need to meet lead
free requirement
Certification Labeling Examples
Questions
Laura A. Taylor
Drinking Water Branch - ADEM
(334) 271-7820
[email protected]