10-31-2013 Lead in Plumbing Products

Safe Drinking Water Act:
2014 Requirements for
Lead in Plumbing
Products
Shawn Martin
Director of PMG Activities
International Code
Council
10/31/2013 VersionSafe Drinking Water Act

Disclaimer
This presentation is for information purposes
only and is not intended to be legal advice.
Should any party need legal advice
regarding the information contained herein,
they should contact their own counsel who
specializes in this area of law.
Safe Drinking Water Act 2

Description
 Overview of the critical concepts of the "Reduction of
Lead in Drinking Water Act”
 Focuses on the role of the code official implementing the law.
 Note: References to FAQ in the document are to the Summary
Of The Reduction Of Lead In Drinking Water Act And Frequently
Asked Questions, U.S. EPA, October, 2013 which was recently
released in October, 2013.
 Brought to you by the by ICC PMG Membership Council
and ICC Evaluation Service

Why Lead in Plumbing?
Lead has a long association with plumbing.
 Term plumbing is based on the Latin
word “plumbum”
 Wide use for plumbing pipes and fittings
and solder even into modern times.
 More recently it is used as an
alloying element in cast bronze and
brass
 Improves machinability
 Reduces porosity
 Resistant to corrosion

Health Effects of Lead
 Lead causes a range of issues in adults and
children – many are lifelong
 Neurotoxin that affects central nervous and
reproductive systems
 Especially harmful to children and pregnant
women
 Builds up - accumulates in bone and fat tissue
 Lowers IQ, create behavioral issues, slow growth
 “No safe blood level of lead has been identified.”1
Safe Drinking Water Act 51: CDC: Blood Lead Levels in Children Aged 1-5 Years – U.S., 1999-2010
 Sources: food, water, contaminated soil, dust, paint, ceramics

Lead Poisoning Prevention Policy and
Children’s Average Blood Lead Levels
‘92‘76 ‘80 ‘82 ‘84 ‘86 ‘88 ‘90 ‘94 ‘96 ‘98
Year
‘72
BloodLeadLevels(µ/dL)
18
2
4
6
8
10
12
14
16
0
‘00‘78
Residential
Lead Paint
Ban (1978)
Lead Contamination
Control Act (1988)
Virtual Elimination of
Lead in Gasoline
2.7 %
2.2 %
Lead in
Plumbing <8%
(SDWA 1986)
‘02 ‘04
1.2 %
‘06
0.6 %
Ban on lead solder
in food cans (1995)
Lead Title X
(1992)
Housing units with
lead based paint
hazards reduced by
40% since 1990
‘74
Lead
Gasoline
Phase-out
(1973)
Source: U.S. Centers for Disease Control

Why Change?
 EPA: Drinking water remains a
significant source of lead exposure:
10-20% of ingested lead
 CDC: No safe blood level of lead.
 NSF: Lead leaching is not directly
proportional to the level of lead in
the product.*
 Lower lead alternative materials.
 Better lead detection methods.
* McLellan, C., Purkiss, D., & Greiner, P., Interim Report on Extraction Results on Leaded
Products Submitted for Evaluation Under NSF/ANSI 61, NSF International, June 2005.

Current Safe Drinking Water Act
No person may use any pipe, any pipe or plumbing fitting or fixture,
any solder, or any flux, after June 19, 1986, in the installation or
repair of—
(i) any public water system; or
(ii) any plumbing in a residential or nonresidential facility providing water for
human consumption, that is not LEAD FREE (within the meaning of subsection
(d) of this section). [42 USC § 300g-6]
< 8.0% for
Pipes, Pipe
Fittings
< 0.2 % for
Solders and
Flux
Drinking. Teeth
Brushing,
Food Prep,
Maintain Oral
Hygiene
(FAQ #7)

Reduction of Lead in Drinking
Water Act
 Reduction of Lead in Drinking Water Act
 Signed January 4, 2011
 Effective January 4, 2014
 Amends the Safe Drinking Water Act
 The amended definition of “lead free” is provided
 0.20% max lead for solder and flux
 0.25% max lead for products by weighted average
 Multiple component products are calculated to address total
wetted exposure based upon wetted surface area of each
component and that component’s lead content by percentage
Safe Drinking Water Act 10Source: Get The Lead Out Consortium Presentation

New Calculation Method
 Applies only to wetted surface area
 Averages lead content at the surface of each wetted part
Weighted Average Lead Content

2012 International Plumbing
Code
 605.2 Lead content of water supply pipe and
fittings. Pipe and pipe fittings, including valves
and faucets, utilized in the water supply system
shall have a maximum of 8-percent lead content.
 NSF 61-2008 compliance required for
 Faucets & fixture fittings
(424.1)
 Water service pipe (605.3)
 Distribution pipe (605.4)
 Fittings (605.5)
 Ball, gate, globe valves
(605.7)
 DWTU tubing (611.3)
 Fountains and coolers
(410.1)

2015 International Plumbing
Code
 Previous section on 8% lead remains. (FAQ #11)
“605.2 Lead content of water supply pipe and fittings. Pipe and
pipe fittings, including valves and faucets, utilized in the water supply
system shall have a maximum of 8-percent lead content.”
 New proposal approved to add the following provision
(FAQ #19,21) :
“605.2.1 Lead content of drinking water pipe and fittings. Pipe,
pipe fittings, joints, valves, faucets, and fixture fittings utilized to supply
water for drinking or cooking purposes shall comply with NSF 372 and
shall have a weighted average lead content of 0.25 percent lead or
less.”
 NSF 61 requirements remain. (FAQ#18)

What Products Are Covered?
Specifically Excluded Not Specifically Addressed
Toilets, Bidets, Urinals and Associated Flush
and Fill Valves
Water Heaters, Hot Water
Fixtures and Fittings
Tub fillers, Shower Valves Replacement Parts
Service Saddles Showerheads
Main Dist. Gate Valves >2” Diameter Hose Bibbs
Includes: “…any pipe or plumbing fitting or fixture… in a
residential or non-residential facility providing water for human
consumption.”
Excludes: “other uses where the water is not anticipated to be
used for human consumption.”
FAQ #6
FAQ #23-30
FAQ #9

Determining Applicability
Safe Drinking Water Act 15Source: EPA - How to Identify Lead-Free Certification Marks
for Drinking Water Plumbing Materials

Dual-Use Potable and Non-
Potable Products
 Guidance Released by EPA in October, 2013
(FAQ #10, 12, 13) allows for higher lead content
product to be sold if labeled for exclusive non-
potable use.
 Clear and prominent marking
 Separate packaging and product labeling
 Code enforcement officials should watch for and
flag installation of non-potable components in
potable applications.
Safe Drinking Water Act 16Summary of the Reduction Of Lead In Drinking Water Act &
Frequently Asked Questions, U.S. EPA, October, 2013

Standards Comparison

Enforcement – Role of the Code
Official
 Enforcement of lead requirements for
installation/use is assigned to the states.
 EPA can sanction states for failing to enforce
 Primary enforcement mechanism through
building/plumbing codes.
 States may assign other responsible parties
(e.g. DTSC in California)

Other Important Questions
 What about replacement parts?
 What about repair and return to service?
 Are hot water systems considered sources
of potable water?
 What about fire sprinklers, hydrants?
 Do coated products comply?
 Is retrofit required?
 What about projects in progress?
?
FAQ #6
FAQ #23,29
FAQ #23
FAQ #17
FAQ #15
FAQ #23-30
FAQ #5

What about the states?
 States may impose additional restrictions,
requirements – cannot be less stringent.
 CA, LA, MD, VT currently have similar low-lead
requirements in place.
 Certification, compliance requirements vary
 Differing guidance on affected products
 BE AWARE OF YOUR LOCAL STATE
REQUIREMENTS
 8% lead limit
 NSF 61

Key Difference Between
State and Federal Laws
 California/Vermont/Maryland/Louisiana – applies
to any product intended to convey or dispense
water for human consumption through drinking
or cooking
 Federal – Applies to any product used in
systems where water is anticipated to be used
for human consumption
 Could be interpreted to cover a much broader group
of products than state laws

Identifying Compliant Product
 NO SINGLE WAY TO SHOW COMPLIANCE – VARIES
BETWEEN MANUFACTURERS
 Options
 Third-party certification to NSF 372, NSF 61 Annex G
 Third-party certification to SDWA, State Lead Laws
 Self-certification
 Vehicles
 Third-party certification listing
 Product or packaging marking
 Specification sheet
 Manufacturer declaration (document, website)
Third Party
Certification
NOT
required by
SDWA
(FAQ #19)

Certification Marks
Safe Drinking Water Act 23How to Identify Lead-Free Certification Marks for Drinking
Water Plumbing Materials, USEPA

Product Identification Examples:
Handle Coatings & Product Packaging

Carton Labels and Hang Tags

Body Markings
LF


Source: Get The Lead Out Consortium Presentation

Summary and Conclusion
 New federal lead requirements effective January 4, 2014
 Reduce allowable lead content in potable plumbing
components to 0.25% (installed or sold)
 No requirement for retrofit.
 Enforcement at state level usually through codes
 No single compliance mark – varies widely
 States may have additional, more stringent requirements
 More clarification and guidance from the EPA and states
is expected…

More Information from ICC
 Resource Links: www.iccsafe.org/pmg
 PMG Membership Council (free for members)
 ICC-ES PMG: www.icc-es-pmg.org
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10-31-2013 Lead in Plumbing Products

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