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The New Low Lead Regulations

The New Low Lead Regulations. 2014 AWWA Meeting February 26, 2014 LAURA A. TAYLOR (334) 271-7820 lat@adem.state.al.us. Overview. Sources of Lead in Drinking Water Health Affects of Lead in Drinking Water Current Safe Drinking Water Act Requirements NSF/ANSI 61

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The New Low Lead Regulations

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  1. The New Low Lead Regulations 2014 AWWA Meeting February 26, 2014 LAURA A. TAYLOR (334) 271-7820 lat@adem.state.al.us

  2. Overview • 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

  3. 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

  4. 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

  5. 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

  6. 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.

  7. 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

  8. 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)

  9. 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

  10. NSF Standards Development Process

  11. Certification Marks

  12. 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

  13. Safe Drinking Water Act RevisionExemptions • 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

  14. Safe Drinking Water Act RevisionExemptions • 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.

  15. Safe Drinking Water Act RevisionExemptions Fire Hydrants • Fire Hydrants has been exempted. • Became Public Law on 12/20/2013 • Community Fire Safety Act of 2013 • H.R. 3588

  16. Safe Drinking Water Act RevisionsDefinitions • 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)

  17. NSF Evaluations

  18. Safe Drinking Water Act RevisionLead Content Calculation • Core requirement: Weighted average lead content < 0.25% • Formula:

  19. Sample Faucet

  20. Example weighted average lead content calculation

  21. Safe Drinking Water Act RevisionsEffective 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.

  22. Issues With the RevisionsOverview • 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

  23. 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)

  24. Scope of the Exemptions • To qualify for the “used exclusively for non-potable 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.

  25. 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

  26. 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

  27. 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

  28. 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

  29. Certification Labeling Examples

  30. Questions Laura A. Taylor Drinking Water Branch - ADEM (334) 271-7820 lat@adem.state.al.us

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