This Web Exclusive is contributed by Ezra Phillips, senior product manager at Zurn Wilkins where he is currently in charge of lead-free conversion efforts. He holds a bachelor of science in industrial technology from Cal Poly and project management certification from Cal Tech.
The effective date is fast approaching for the new federal mandate for lead-free plumbing products — and decisions made now by facility managers and everyone else involved in the specification, purchase, installation, and design of plumbing systems can be impacted by it.
The Reduction of Lead in Drinking Water Act (42 USC 300G–6) complements the federal Safe Drinking Water Act (SDWA). It requires any valve, fitting, or fixture coming in contact with potable water to be lead-free.
Specifically, the affected plumbing products must have a weighted average of no more than 0.25% lead content, as per NSF International/American National Standards Institute (ANSI) Standard 372, Drinking water system components–Lead Content.1 The previous allowable lead content level was 8%. This new law takes effect January 4, 2014.
The Reduction of Lead in Drinking Water Act states that exemptions include “pipes, pipe fittings, plumbing fittings, or fixtures, including backflow preventers, that are used exclusively for nonpotable 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.”
The law does not require existing installations to be replaced, but its general language has many professionals in the plumbing and water systems industries wondering if even end-users could be held liable – along with manufacturers, contractors, specifiers, and others – for the distribution or installation of products that do not meet the new standard. Some wonder about hypothetical possibilities in which plumbing products could be installed, but later repurposed in a different way than the “anticipated” use. Should the repurposed use have been anticipated?
Further complicating things, the law does not address enforcement or compliance certification, although the U.S. Environmental Protection Agency (EPA) is expected to eventually issue regulations governing the new law. Thus far, however, no timetable for them has been disclosed.
So, what is a facility manager to do? First, be sure that any current or near-future job bids that include “standard” lead-containing products can, in fact, be installed prior to the law’s effective date of January 4, 2014. Otherwise, it will be illegal to sell or install them.
In addition, pricing expectations for many plumbing products will need to be adjusted because lead-free products are often more expensive to manufacture. If it is required to install lead-free products on a job after less expensive leaded products were bid, the project could cost more to complete than budgeted.
It’s recommended that every facility manager, building owner, contractor, and specifier make certain they know where each other and their plumbing sources stand on this issue.
Some manufacturers have taken aggressive, proactive measures to convert their product offerings to comply with the law. In addition, manufacturer efforts can take extend to order processing — by including lead-free part numbers for ease of doing business and to avoid mix-ups, for instance. Companies can also initiate education by reaching out to business partners — contractors, wholesalers, and distributors — by providing them tools to assist with their inventory conversions; meanwhile, engineers can be notified to update their specs.
It’s also important to keep in mind that, in addition to lead-free products, some manufacturers will continue making standard products for uses exempted by the new law. Facility managers should check with vendors to be certain they have manufacturing measures in place to avoid cross contamination of even minute levels of lead into the lead-free products.
The EPA itself acknowledges that many uncertainties arise from the way the law is written. As one example, during a public meeting last summer at EPA headquarters, one agency engineer gave voice to an issue many have wondered about: “Can the product in the [water] system or facility be repaired using lead-free component parts and returned to service, even if the other component parts that are not repaired do not meet the definition of lead-free?” He said the EPA gets a lot of questions like that related to water meters: does the entire meter have to be replaced or just a component part?
Thus far, no definitive decision on that issue, among others, has been made.