Interested in learning how to identify properly labeled products? Click here to see recent EPA Guidelines.
The EPA has posted a revised list of frequently-asked-questions (FAQs) to assist manufactures, retailers, regulators and the general public in complying with and understanding the requirements of the Reduction of Lead in Drinking Water Act. The FAQs address the definition of lead free, the effective date, calculating lead content, 3rd party certification, product labeling, repair and replacement parts, and exemptions. The FAQs can be found here.
Are you preparing to go Lead-free?
Whether you are a distributor or manufacturer, the Clean Water Act and the changes made by to it by the Safe Drinking Water Act will play a vital role in your business.
Read the EPA's DRAFT Guidance on implementing the Reduction of Lead in Drinking Water Act here.
On August 16, 2012, the EPA held a stakeholder meeting for interested parties. To review the presentations made, click here.
The Safe Drinking Water Act (SDWA) requires that only lead-free pipe, solder, or flux may be used in the installation or repair of a public water system, or any plumbing in residential or non-residential facility providing water for human consumption. "Lead-free" under the SDWA means that solders and flux may not contain more than 0.2 percent lead, and pipe, pipe fittings, and well pumps may not contain more than 8.0 percent lead. Beginning in January 2014, changes to the SDWA will further reduce the maximum allowable lead content of pipes, pipe fittings, plumbing fittings, and fixtures to 0.25 percent.
This information will help explain the purpose, scope, and content of NSF/ANSI Standard 61.
- NSF/ANSI Standard 61 Drinking Water System Components - Health Effects is the standard that establishes minimum health effects requirements for materials, components, products, or systems that contact drinking water, drinking water treatment chemicals, or both.
- NSF/ANSI Standard 61 (NSF 61) covers many items, including, but are not limited to:
- Pipes, fittings and related products
- Protective barrier materials (coatings, linings, liners, cement, cement ad-mixtures, etc.)
- Joining and sealing materials (adhesives, lubricants, elastomers, etc.)
- Process media (activated carbon, sand, ion exchange resin, regenerated media etc.)
- Mechanical devices used in treatment and distribution (valves, pumps, filters, chlorinators, etc.)
- End-point devices dispensing drinking water (faucets, end-point control valves, riser tubes, supply stops, etc.)
Learn what the pending changes in plumbing materials mean and how they could impact your business.
- What do I need to know about California with respect to low-lead laws?
The State of California enacted legislation (AB 1953) revising the term "lead free" relative to any pipe, pipe or plumbing fitting, or fixture intended to convey or dispense water for drinking or cooking. For these products, "lead free" means not more than a weighted average lead content of 0.25 percent. The weighted average is determined by multiplying the lead content of each wetted component times the proportion of the total wetted surface area represented by that component and summing up the results.
The legislation went into effect on January 1, 2010, which states that no person will be able to use, install, or bring into commerce these products unless they comply with new "lead free" requirements of the law.
- Does NSF/ANSI Standard 61, Annex G satisfy the requirements of California law?
Yes. NSF/ANSI Standard 61, Annex G was developed to meet the requirements of California's AB 1953. Therefore, being certified to NSF/ANSI Standard 61, Annex G means that you comply with California's Health & Safety Code Section 116875 (commonly known as AB 1953).
- Will certification to NSF 61-Annex G or NSF 372 meet the new requirements of the U.S. Safe Drinking Water Act?
Yes. The lead content requirements for plumbing products in the U.S. Safe Drinking Water Act were revised to require compliance with the weighted average content of 0.25% beginning in January 2014. Certification to NSF 372 or NSF 61 Annex G will meet these requirements.
- What is the difference between products that are certified to NSF 61-G or NSF 372?
Certification to NSF-372 means that a product meets a weighted average lead content of ≤0.25%.
Certification to NSF-61 Annex G means that a product meets the leachate requirements of NSF 61 for all contaminants (metals and non-metal) as well as the weighted average lead content requirements of NSF 372.
The overwhelming majority of plumbing codes in the US as well as most State regulations for public drinking water systems require compliance to the NSF 61 leachate requirements. Certification to NSF 61-G means compliance to both requirements.
- As a manufacturer of plumbing products, what should I be doing to comply with the new low lead legislation?
Contact NSF (firstname.lastname@example.org) today to begin getting certified to NSF's Annex G, which is the best method for demonstrating compliance with the new legislation.
- Can a manufacturer use plating, coatings or acid wash treatments to make a device comply with the California low lead regulations?
No. While NSF Standard 61 allows the use of platings, coatings, or acid wash treatments, these cannot be used to meet the 0.25% weighted average lead content requirements of Annex G. The weighted average must be based on the lead content of the component, not just the lead content on the surface. This requirement was incorporated into Annex G based on a letter expressing the legislative intent of AB 1953 sent to NSF from the California legislator who authored AB 1953. This is also reflected in a legal opinion from East Bay Municipal Utility District's counsel, the utility that sponsored AB 1953. While the California legislation does not specifically address coatings, platings or acid wash systems, manufacturers that attempt to use these techniques to comply with the California requirements may face legal challenges.
- Is laboratory testing required as part of the NSF/ANSI Standard 61, Annex G and NSF 372 certification programs?
Yes. NSF 372 contains requirements for evaluation of the lead content based on the requirements developed by the California Department of Toxic Substance Control. Basically this allows for a screening method (such as X-ray fluorescence) as well as a digestion of the material to determine lead content.
- Is there an NSF/ANSI Standard 61, Annex G certification mark for my product and literature? How will my NSF online listing be updated?
Products that are NSF Certified to NSF/ANSI Standard 61, Annex G utilize a special certification mark that should be used on products, literature, and in other promotional ways. NSF's online listings are also updated to include the addition of Annex G for those certified products. Listing information for those products certified to Annex G will bear a listing note stating, "Product also Certified to NSF/ANSI Standard 61, Annex G (weighted average lead content of ≤0.25%) and is in compliance with California's Health & Safety Code Section 116875 (commonly known as AB 1953.)"
For samples and more information, see the Annex G and NSF 372 Product Marking section.
- Can a product be certified only to the lead content requirements of Annex G and not the lead leaching and other requirements of NSF/ANSI Standard 61?
No. Annex G requires that products must be compliant with the full requirements of NSF/ANSI 61 plus the weighted average lead content to comply with Annex G. NSF can, however, certify products to NSF 372 demonstrating compliance with only the low lead content requirements.
- Do all products that are certified to NSF-61 now comply with Annex G and the 0.25% weighted average lead requirement?
No. Annex G as well as NSF 372 is an optional additional certification. To further clarify, some products are certified only to NSF-61 requirements, while others are certified to both NSF-61 and to Annex G (NSF 372), the additional lead content certification. Products that are certified only to NSF 61 have not been evaluated for weighted average lead content.
NSF/ANSI Standard 61 requires analysis for any chemicals that leach from a material into drinking water. It requires a toxicological evaluation of chemical concentrations to ensure that they are below levels that may cause potential adverse human health effects.
By referencing NSF 372, Annex G contains an optional evaluation criteria for determining the weighted average lead content of drinking water system components. It is based on legislation in California which requires products that convey or dispense drinking water to comply with a 0.25% weighted average lead content.
Products that are certified to NSF-61 and Annex G have met the 0.25% weighted average lead content as well as all the health effects and leachate requirements of NSF-61.
NSF has listings of products certified to NSF-61. Products certified to the 0.25% weighted average lead content requirements (Annex G) have a listing footnote to denote the additional certification.
- Are other U.S. states considering enacting low-lead legislation for plumbing products?
Vermont recently enacted a law similar to California's, which is also scheduled to take effect January 1, 2010. Maryland has a similar law going into effect on January 2012 and the U.S. Safe Drinking Water Act will make this a national requirement in January 2014.